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An Interview with Angelique Okeke, Senior Counsel, Lotame Q: What does Lotame do? A: Lotame is a marketing technology company and our proprietary unifying data management platform allows publishers, marketers and other agencies to collect or learn more about the data on their online properties and then activate that data through delivery of relevant advertising and content customized to match the interests of the user. Q: How long have you been a member of the NAI?

A: Lotame has been a member of the NAI since April 2009. We originally joined when Lotame was an ad network and approximately two years ago, when we changed our business model, we worked closely with the NAI to ensure compliance with the Code during every step of our evolution. Despite the change in our business model, NAI remains extremely relevant to Lotame and to the ecosystem as a crucial voice of third parties.

Q: You recently joined the NAI on a panel at the 2013 Computers, Freedom and Privacy event in DC to discuss the experience of being an NAI member and how it impacts your business. Can you share that here?

A: We have found that continuing our participation and becoming more involved with the NAI have been very helpful to our business, particularly for me in my role as senior counsel for Lotame. I review every contract the company enters and lead all negotiations, from third-party data provider partners to commercial contracts with our clients. Our membership and the compliance process that we go through on a quarterly basis really inform the way that I negotiate, particularly around some of the provisions in our contracts. Our membership with the NAI mandates a certain level of transparency.

What I have found is that even if some of the smaller companies with whom we are negotiating may not be members of NAI themselves, they have heard of the NAI and understand that our membership means that Lotame adheres to a rigorous and respected self-regulation model. This minimizes the back and forth negotiation during these contract reviews. We simply say affirmatively, ‘This is what we adhere to as part of our membership with the NAI, so here is what you, as our client, must adhere to as well.’ Lotame’s stance on respecting consumer privacy is strong and it is bolstered by our close alignment with the NAI.

We perform periodic privacy audits on our customers to make sure contractual obligations are, in fact, operational. We look for the presence of a prominent privacy policy with operable choice tools. Because our clients’ practices reflect on us during our annual NAI review, we do not want to take any chances when it comes to our compliance with the Code or Lotame’s reputation as a leader in protecting consumer online privacy.

Q: On the panel, Marc Groman, executive director, and Anthony Prestia, associate counsel for policy & technology for the NAI, discussed the NAI’s rigorous pre-certification and annual review.  Aside from these ongoing processes, how else does Lotame leverage its NAI membership?

A: We have used the NAI as a very close resource outside of the annual review process. For instance, we recently began working with a branded provider of medical data. Before the data aggregator provided us with any segments for our DMP clients to activate, we needed to see a comprehensive list of the segments that could be used for targeting. From there, I discussed with the NAI some of the interest segments that would mandate certain disclosure as required by the NAI’s Health Transparency Policy. We were able to review the list of segments with the NAI and received critical guidance that was a large part of the decisioning process when informing the provider which segments that we would ingest into our system for our platform clients’ access and use. 

Q: In your opinion, what is the primary value of NAI membership and the annual compliance review?

A: The annual compliance review process starts with me, but it really touches every department in our organization, from sales, technology, engineering, and client success teams – these are the folks who are helping our customers aggregate and understand the data and act on it. I conduct internal training sessions on the NAI Code, distilling it down for the various departments, so that everyone at Lotame is on the same page in terms of what we need to think about as we are activating new customers or as new use cases arise for existing clients. The review process keeps the entire Lotame team focused and ensures we are running a business that not only meets the needs of our clients but, is one we can confidently describe as privacy strong.

The NAI informs our business and impacts the way we do business. As a data company, and I’m sure I speak for all NAI members when I say that ultimately, we are all looking to do the right thing. We want to make sure we are providing consumers with privacy choices and the ability to control their data. We think of the NAI as our primary partner in achieving this goal.