Comments on EASA –The World Privacy Forum submitted comments today on the European Advertising Standards Alliance’s Best Practice Recommendation on Online Behavioural Advertising. Our comments focus upon three key areas: First, the EASA recommendation fails to recognize the protection of consumer privacy in Online Behavioral Advertising (OBA) as a key policy goal. Second, the recommendation’s protections are narrow, creating illusory protections for user privacy, whether or not they opt out of OBA. Finally, we critique the oversight and compliance mechanisms, which are not likely to foster consumer confidence nor police the industry. Drawing upon the WPF’s 2007 report, The NAI: Failing at Consumer Protection and at Self-Regulation, the comments argue that EASA’s approach suffers from the same weaknesses as self-regulatory approaches deployed in the United States, and that European lawmakers should not replicate the failed American approach. Law students from the Samuelson Law, Technology & Public Policy Clinic helped draft the comments as part of an ongoing project on consumer privacy and OBA.
Opt-out and how-to — The popular WPF Top Ten Opt Out List has been newly updated. We have added a new section to our list with step by step details on how to opt out of RapLeaf. We encourage consumers to view any of their profiles that exist at RapLeaf and to opt out of RapLeaf permanently. We have also updated the phone numbers and other information on the rest of our opt out list. To see more, visit our Opt Out List.
Digital Signage Privacy Principles — The nation’s leading consumer and privacy groups released a set of baseline consumer privacy principles to be included in digital signage networks. The principles were released at the Digital Signage Expo in Las Vegas, Nevada, where World Privacy Forum executive director Pam Dixon spoke about the principles to a large group of digital signage industry professionals.
FTC Privacy Roundtable — Thursday, January 28, WPF Executive Director Pam Dixon will be speaking at the FTC’s Privacy Roundtable about the privacy implications of digital signage networks and will be specifically discussing the new report: The One-Way Mirror Society: Privacy Implications of the New Digital Signage Networks. Few consumers, legislators, regulators, or policy makers are aware of the capabilities of digital signs or of the extent of their use. The technology presents new problems and highlights old conflicts about privacy, public spaces, and the need for a meaningful debate.
Online privacy and government web sites — The World Privacy Forum filed comments with the Office of Management and Budget regarding its proposal to begin to allow the use of tracking cookies on government web sites. The proposal was published in the Federal Register, and outlined a three-tiered plan for how web tracking technologies might be used. The Forum’s comments focused on methods of opt-out, data retention, secondary use, user authentication, new tracking technologies such as Flash cookies, and the need for new opt-out mechanisms. The Forum also urged the federal government to not allow third party tracking of consumers’ use of government web sites, and to guard against any discrimination against consumers who do not want to be tracked.