The NAI Releases Draft Guidelines for Deterministic Addressability Solutions, Seeks Input from Stakeholders
Since its inception twenty years ago, the NAI has sought to promote heightened standards in consumer privacy and data protection in digital advertising. The NAI is committed to ensuring that innovations and developments in advertising technology are matched with a set of guiding standards that ensure greater data privacy controls for consumers.
The movement in the marketplace away from the use of legacy pseudonymous identifiers, such as mobile advertising IDs and third-party cookies, has brought about a significant shift in the digital media ecosystem. Deterministic Shared Addressability Solutions (DSAIs) are one of a wide range of approaches gaining adoption across the digital media industry to maintain the effectiveness of data-driven advertising, which in turn provides consumers with free and low-cost digital content and services.
These Identifiers are created by converting directly identifying information, such as an email address or phone number, into a pseudonymous, indirect identifier to tailor digital advertising and measure its effectiveness. This shift also presents the opportunity for publishers and advertisers to play a more direct role in engaging their customers about the collection and use of data for advertising and marketing purposes.
The NAI believes that the use of DSAIs, if implemented with strong guidelines and a robust accountability program, can help to advance long-standing NAI priorities for consumer transparency and control, and ultimately increase consumer privacy and restore trust across the digital media ecosystem. Specifically, the NAI believes that DSAIs must be implemented in a way to ensure that data collected across sites and apps is not linked directly to identifiable individuals, and with heightened limitations on the retention and use of this data across the digital media ecosystem. We also seek to ensure that these limitations and controls are honored and implemented by all entities who wish to use these identifiers.
Today, the NAI is releasing a draft set of Guidelines for DSAIs (Guidelines) that propose a set of enforceable obligations for Participants using DSAIs, building on the NAI’s foundational goals of enhancing consumer transparency, control, and promoting trust in the digital advertising marketplace. This is a draft document, and the NAI is actively seeking input from the public for the next sixty days, until May 30, 2022. Comments may be submitted via email to compliance@thenai.org. We will also continue to work closely with our partner ad industry organizations to align our efforts with broader industry initiatives.
In these draft Guidelines the NAI proposes how to address some of the most significant challenges posed by DSAIs. To that end, we are specifically asking for feedback on the following questions:
- Consumer control:
Opt-in / opt-out choices: how can the NAI achieve the appropriate level of consumer control? Where should affirmative consent be required? Where does enhanced transparency and opt-out suffice?
Is there a need to preserve functionality such as measurement and attribution using DSAIs for consumers who do not consent to Tailored Advertising using a DSAI?
How can the NAI ensure an effective centralized control portal for consumers across various DSAI ecosystems? How could the portal ensure it can maintain and improve the NAI’s industry standard of centralized choice for consumers?
How can the NAI effectively distinguish between retargeting in cases where an advertiser merely shows an ad and provides for measurement on a publisher’s platform, as opposed to collection and combination of a consumer’s data across different websites, apps, or businesses they directly interact with?
- Linkage to directly identifiable data:
The NAI has observed email addresses as the predominant basis for DSAIs. However, advertisers and other businesses may utilize telephone numbers as well, and potentially street addresses, which may be more easily re-identified to a known individual. What types of additional controls can be provided to ensure that use of telephone numbers or postal addresses are not re-identified to specific individuals?
- Sensitive Information:
Is it possible to reconcile the use of DSAIs in measurement subsequent to contextual or other non-Tailored Advertising, where the context of the application or website communicates Sensitive Information, such as an app focused on the LGBTQ+ community, a medical condition, or a specific ethnic group?
- Accountability and enforcement:
What additional technical and administrative controls could the NAI consider to ensure the highest level of auditability and accountability across various participants?
For those digital advertising stakeholders interested in working in more detail with the NAI, its Board, and Members as the draft evolves based on feedback, we invite you to join our Data Governance Working Group and its Addressability Subcommittee as a formal participant. Please contact membership@thenai.org for details on how to join as a participant.
