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NAI Announces Privacy Protections for Hashed Email Addresses as Identifiers for Tailored Advertising

Email-based consumer opt-out is live; Scope will expand from Audience Matched Advertising to all Tailored Advertising

WASHINGTON, DC (July 22, 2021) – The NAI – the leading self-regulatory association dedicated to responsible data collection and its use for third-party digital advertising – announced that its email-based consumer choice mechanism is now live on the NAI site. NAI members have already begun integrating with this opt out, including Oracle Advertising, Neustar, Criteo, Inmar Intelligence (previously, OwnerIQ), and Verizon Media.

“Any shift to hashed email addresses as identifiers must come with robust privacy protections, such as the NAI’s universal opt-out from tailored advertising tied to an email,” said Leigh Freund, NAI President and CEO. “Our members will continue to focus on consumer privacy when evaluating any potential replacements for cookies and mobile ad IDs. Per our Code of Conduct, we expect member companies to provide consumer choice for all addressability solutions used in tailored advertising.”

The past year has brought significant disruption in the digital advertising space, with the announced deprecation of third-party cookies in the Chrome browser, as well as changes to the way mobile advertising identifiers are accessed in iOS. These challenges to traditional addressability methods have spurred considerable innovation from advertising technology companies. Some solutions propose to leverage hashed email addresses as a means of distinguishing between various users and devices.

NAI member companies that leverage hashed email addresses as an addressability method for tailored advertising are expected to provide a consumer choice mechanism tied to those hashed email addresses and are expected to integrate with the NAI’s email-based opt-out mechanism. Developed initially to provide a choice mechanism for first party data matched with online identifiers, like cookies, the scope of the NAI’s email-based opt-out mechanism will expand to all use of hashed email addresses for tailored advertising.

Scope of the New Opt-Out Mechanism

When the NAI published its 2020 Code of Conduct and developed the first industry PII-based opt-out mechanism for tailored advertising, the use of hashed PII in digital advertising was primarily focused on Audience Matched Advertising, allowing brands to reach their own customers while they browse the web or use mobile apps. In these use cases, the hashed PII is not used as an addressability method, but rather as a link between existing cookie IDs and/or mobile advertising IDs. 

At present, all NAI members engaged in Audience Matched Advertising must integrate with the email-based consumer choice mechanism. As tailored advertising associated with hashed email addresses develops, the NAI’s email-based opt-out mechanism will expand from only Audience Matched Advertising to all uses of hashed email addresses for tailored advertising.

The NAI is developing additional member guidance on the use of shared addressability solutions, as well as requirements that members provide consumers with appropriate notice, transparency, and choice.

Nat Wood

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