Behavioral Advertising

Public Comments: April 2008 – WPF files comments on behaviorally targeted ads online; requests separate rulemaking for sensitive medical information

The World Privacy Forum filed comments in response to the Federal Trade Commission’s proposed self-regulatory guidelines for companies targeting online advertising to consumers based on consumer behaviors. The WPF requested a separate, formal rulemaking process for determining how sensitive medical information should be handled online regarding behaviorally targeted advertisements. The WPF also discussed genetic data and requests for genetic tests, and noted that genetic information should be included in any definition of sensitive medical information. The WPF reiterated that the definition of personally identifiable information should include IP address, and encouraged the FTC to work from a rights-based approach regarding online advertising. The WPF also urged the FTC to include all fair information practices in any self-regulatory regime, and to enforce the regime directly.

Legal and Policy Analysis: Personal Health Records: Why Many PHRs Threaten Privacy

New publication | PHRs and privacy — The World Privacy Forum has published a new legal and policy analysis examining Personal Health Records — or PHRs — and the privacy issues associated with them. This analysis, Personal Health Records: Why Many PHRs Threaten Privacy, was prepared by Robert Gellman for the World Privacy Forum. The analysis finds that significant, serious threats to privacy exist in some PHRs.

Updates to Top Ten Opt-Out List

Opt-out | Financial privacy — The World Privacy Forum has updated its popular Top Ten Opt Out list to reflect several new change made to the Direct Marketing Association opt outs. In the past, some of the DMA opt-outs, like the Direct Marketing Association’s mailing preference lists, used to cost $1. That fee has now been removed for people opting out online. Please see item #3 on the Opt Out list for the complete update.

WPF Release a Report: The Network Advertising Initiative: Failing at Consumer Protection and at Self-Regulation

Report | Internet privacy | NAI — The World Privacy Forum published a new report today, The Network Advertising Initiative: Failing at Consumer Protection and at Self-Regulation. The report is an in-depth analysis of the history and current operations of the National Advertising Initiative (NAI) self-regulatory agreement. The NAI was created to protect consumers’ online privacy in the behavioral advertising arena. The report finds that the NAI has failed. The report discusses the failure of the NAI opt-out cookie, the uses of persistent consumer tracking technologies that go beyond cookies, such as Flash cookies, browser cache cookies, XML super cookies, and other issues. The report also discusses the practice of re-setting cookies after cookie deletion. The report gathers the details of the difficult membership history of the NAI, as well as the enforcement history of TRUSTe regarding NAI.