Do Not Resuscitate Do Not Track, Part II
Since my latest blog in The Marketing Consigliere Blog this week on proposed Behavioral Advertising regulation, the Federal Trade Commission has issued “Online Behavioral Advertising – Moving the Discussion Forward to Possible Self-Regulatory Principles,” a 7-page proposal of voluntary guidelines with which businesses can regulate themselves.
After reading the document, I am satisfied that the FTC not responded in a knee-jerk reaction to the shrill, lone voices of those that do not fully appreciate the far-reaching benefits of Net-Centric Marketing. However, the Marketing and Advertising worlds should not rejoice yet – the “proposed principles” put forth in the document are broad enough to probably get a lot of nods of agreement, but are still quite a stretch when it comes to execution.
The of proposition of voluntary, self-regulatory actions is good and in line with the free market concept, and “Reasonable Security” should have no agrument but “Limited Data Retention” for consumer data flies in the face of data mining and busines intelligence, which demand terabytes of data over long periods of time to detect consumer trends.
Regarding “Affirmative Express Consent for Material Changes to Existing Privacy Promises,” there is an unusual logistical burden for a C4ISR Marketer to let every past visitor know that the lawyers have once again tinkered with the website’s language.
Also, regarding “Affirmative Express Consent to (or Prohibition Against) Using Sensitive Data for Behavioral Advertising,” to whose standard of “sensitive” must the Marketer adhere? How does one determine which customers are more apt to regard certain data points as more sensitive than others?
On the other hand, as a believer in technology, the business rules and logic can be implemented to be customized in the long run – it would be a tedious task and a big headache for Marketers until some best practices were to arise and be shared.
Let’s see how industry responds to this…