Profiling, Targeting, Behavioural Advertising

Dear Reader,

My colleague, Yasmin Joomraty, attended a very interesting forum on 'Behavioural Targeting, Social Networking and the Challenges of Online Privacy' earlier this week. We were discussing her views and I asked her to blog about them so here follow her personal reflections on profiling, targeting and behavioural advertising...

(Yasmin writes) "I returned to my desk today to write up my take on the issues discussed at the Westminster eForum. At the forum, the Assistant Information Commissioner had mentioned the 'Personal Information Promise' on the ICO website to which companies can sign up. I Googled it to find out more. As soon as I had keyed "personal info" into the search bar, top of the list of Google's suggested search terms for my search was - you guessed it - "Personal Information Promise". In light of the comments the delegate from Phorm had made regarding search engines profiling and targeting users in more ways than Phorm would ever wish to, I chuckled to myself at this timely demonstration. 

I then went to look up "privacy enhancing technologies" and, again, no sooner had I typed "privacy e" but Google had guessed what I was looking for. Handy, yes. But a little disconcerting in light of the 'challenges for online privacy' I was contemplating.

We have written in the past about Google's raps on the knuckles over keyword advertising, legal battles over 'scraping' third party content, book deals struck, thumbnails infringing copyright, sniping over news snippets - the list goes on - and I thought I knew a lot about Google... Except for what Google knows about me.

Google's Privacy Overview states, predictably, that:

• "Google uses cookies and other technologies to enhance your online experience and to learn about how you use Google services in order to improve the quality of our services."

and 

• "Google’s servers automatically record information when you visit our website or use some of our products, including the URL, IP address, browser type and language, and the date and time of your request."

So that explains the customised search suggestions. Google knows my IP address and has tracked my online behaviour in order to provide me with this service - which, incidentally, I do not remember signing up for. This raises 3 questions for me:

1. What constitutes personal data? An IP address has been held to be personal data. So Google has obligations under the DPA here. 
2. Does it matter whether information about me constitutes personal data or not? As technologies evolve and trackers can find out more about me, should the obligations under the DPA stop at personal data? Do I have a valid objection to companies building up a profile of me which, although it does not constitute personal data, consists only of numbers and codes, and is never even read by a human but simply passes through a 'black box' (as the Phorm delegate called it), but which nevertheless corresponds to me and my habits, some of which may be private? As society understands the new technologies better, there is scope for data about my behaviour finding its way to third parties and even saying private things about me to others? For example, if a friend uses my laptop and notices that the suggested search terms and targeted ads are geared towards Botox, this may reveal something about me that is private and if not constitutes then relates to personal data. 
3. Have I consented? I would describe myself as protective over my online presence and reluctant to receive marketing communications - I tend to search for opt-outs and actively select my preferences. The notion of informed consent is often debated but it seems to me that if I find it difficult to ascertain what Google is doing with my information and how to opt out of the same, then how will the 'reasonable man' who is not actively looking or notified?  

More worryingly, another point in Google's Privacy Overview is: 

• "Google collects personal information when you register for a Google service or otherwise voluntarily provide such information. We may combine personal information collected from you with information from other Google services or third parties to provide a better user experience, including customizing content for you."

Does this include/anticipate collaboration with Phorm-like behavioural trackers?

As new technologies and social attitudes merge to cause the shift in media, publishing and entertainment from a 'one to many' broadcast to the two way dialogue of 'many to many' communication, so advertising is reaching its holy grail of targeting specific individuals with relevant messages. 

An individual's online presence makes him part of the online world (consumer, broadcaster, commentator, buyer, seller, MMORPG player all in one) in a way that he never was before TV remotes had red buttons. The fact that that individual has an online presence exposes him to risks which do not apply in the offline world. These risks mostly centre on that individual's data - the type he chooses to share and the type he does not know he is sharing.

However, advertising has rich benefits and should not be unduly stifled. It is the driver for online growth and funds much of our virtual activities. It offers choice to consumers and can entertain, inform and empower.

The difficulty, as always, is in getting the balance right."  

Yasmin Joomraty   

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