A Location Data Gut-Check

by Kirsten McMullen, Chief Privacy Officer "ad age", "location data", mobile, privacy
A Location Data Gut-Check

The good news? I got quoted in Ad Age this week!  The bad news? I got quoted in Ad Age this week! 

Ok, that’s only slightly tongue-in-cheek. But as chief privacy officer at an martech/adtech company, the aphorism “no news is good news” often applies when it comes to editorial news coverage.  In this case, while this article has elements of criticism, Kate Kaye’s coverage of “Why the Industry Needs a Gut-Check on Location Data Use” is well-researched, fair and comprehensive.
The advertising industry’s use of location data has quickly moved from simple “proximity targeting” for ad delivery on your mobile phone, to very sophisticated location profiling with ads delivered across multiple devices. Explicit media coverage of this trend has been minimal.  Awareness of the practice varies dramatically, and even for those agencies and brands who know that such things CAN be done, few know exactly how it’s ACTUALLY done. And unfortunately, consumers are likely the least informed of this practice. The article takes the advertising industry to task: “…what’s missing is industry self-reflection about whether it is acceptable for companies, many with no direct relationship with the consumer, to gather and use weeks’ or months’ worth of location data.”
In the case of 4INFO, I can say: we’ve done a LOT of reflecting. The data explosion is recent (IBM says 90% of the data in the world today has been created in the last two years alone), and in large part driven by mobile devices. I’ve been overseeing our privacy programs for much longer than that, dating back to our prior line of business revolving around SMS.  Our core ad targeting and delivery technology was built before the NAI or DAA had provided guidance for mobile advertising. But it had privacy built-in from the outset, based on 4INFO’s commitment to privacy by design principals, using the best practices established by these organizations for behavioral ad targeting on desktop. We’ve paid close attention to our role as a third party (we don’t have the direct relationship with the consumer) and our data collection, particularly focusing on elements such as location, IP address, and advertising identifiers.
Location data has long been one of the primary reasons we’ve put privacy principals at the front end of product development.  Although location data is not inherently personal, with the right data set it could be. So we treat all of our data as if it could be misused. Over the years we’ve thought a lot about how to limit our collection, secure the data, ensure quality, provide transparency and choice, limit use of data to specific purposes and most importantly: hold ourselves accountable as a company for appropriate protection, use and disposal of all of the data we receive.  This isn’t a one-time process. It’s ongoing, and it’s complex. Data and privacy are context relevant, so with every new product and every new technology, we must examine how we are upholding our commitment to privacy principals.
Sometimes that means we say “no” to our customers. That’s never easy. But 4INFO doesn’t undertake this commitment simply because we’re legally obligated to do so. We pay attention to these issues because it is ultimately good business. Strong privacy principals are good for us, good for our partners, good for the agencies and brands we work with, and good for the consumer.
But I’ll admit: I wish more folks were more explicitly aware of what they’re agreeing to when they accept privacy policies (without reading them), or when they opt-in to sharing their location data with an app or web site.  There’s still plenty progress to be made in education and proactive transparency. I will keep working on it, and working with the leaders in our industry to do the same.