Analyzing Behavioral Targeting Best Practices

Josh GordonOn Monday I wrote about the need for the discourse around behavioral targeting technology, in Congress and elsewhere, to be careful not to use a broad brush when determining the best practices for the technology. Not all forms of behavioral targeting are the same (network versus onsite); therefore the same rules should not govern all types of behavioral targeting.

In case you missed them, here are the proposed Seven Best Practices for Behavioral Targeting that has Congress and the Federal Trade Commission abuzz with cautious praise:

  • The Education Principle
  • The Transparency Principle
  • The Consumer Control Principle
  • The Data Security Principle
  • The Material Changes Principle
  • The Sensitive Data Principle
  • The Accountability Principle

The ongoing search for the fine line to walk between privacy and technology is the reason for the introduction of these initial guidelines. There are some excellent steps in here that have the potential to do a great deal for advancing direct digital marketing and behavioral targeting. However, the execution must match the ambition. Detail is necessary when so many lawmakers are poking about!

The first three are self-explanatory and all very important. While the Education and Transparency Principles are nice, it’s the Consumer Control Principle that is essential to provide the others with the support they need to be valid.

The principles also state that marketers will place an opt-out button on each behaviorally targeted ad, a process designed to make opting out very easy for consumers. It is an interesting idea, but here’s one cautionary note – network behavioral targeting companies must be careful to control the costs of the technology and manage pricing expectations with their customers. The rates network folks can charge will likely increase as opt-outs do. The more narrow a segment becomes, the more valuable it is to reach them effectively. However, if rates start low, they will stay low.

The last principle, Accountability, is, perhaps, the most interesting of all. The Accountability Principle states that violators of the principles are to be reported by other companies to the government, and the government will determine the punishment. While this has been labeled “self-regulation,” the government has tremendous control to levy punishments for violators. Some are arguing that an industry-group should be the ultimate governance and would be more reflective of true self-policing by the industry. It is clear that the Accountability Principle is a concession by the technology companies and is likely the primary reason why the government has received these principles favorably – for now.

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  1. […] the Education Principle is the key principle. The more effort put into education – and the wider the educational outreach (to include […]

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