I am reflecting upon last month’s NAI Member Summit and thought I would share some thoughts as well as my vision for the future of NAI.
First, it was incredibly gratifying to hear the remarks of FTC Commissioner Julie Brill at the Summit. Commissioner Brill is a strong advocate for consumer privacy and a leading proponent of privacy legislation and tough FTC enforcement. And yet Commissioner Brill recognized the value of industry self-regulation and praised NAI’s strong leadership in setting high standards. Commissioner Brill highlighted NAI’s approach to the collection and use of sensitive information and was particularly impressed with our requirements around sensitive health information and transparency. No other self-regulatory framework for online advertising has higher standards for health data and Commissioner Brill recognized the high bar we set for our members. Commissioner Brill also called out NAI’s pre-certification review process which vets applicants to NAI and confirms that prospective members are capable of complying with the NAI Code even before they join. That, Commissioner Brill explained to a packed room, is the kind of accountability that she is looking for in effective self-regulation. We didn’t agree on everything. But we did agree that the work of the NAI is incredibly important.
Also at the Summit, former United States Senator Byron Dorgan moderated a panel of key legislative staff from both the Senate and House of Representatives. The Senator noted the value of online advertising during his remarks, highlighting the benefits that such innovation has brought to the Internet and the U.S. economy. The panel agreed that privacy legislation is highly unlikely in this Congress, but also noted that many historic legislative efforts took over a decade to wind their way through Congress. I worked on some of those efforts in the 111th Congress and I wouldn’t rule out data breach, data security or a limited privacy bill in the years to come. We must continue to develop and honor high standards not just for more traditional interest-based advertising, but for new business models and technologies like potential new uses of precise location information.
It was great to hear Commissioner Brill praise the leadership of NAI and listen to Senator Dorgan tout the many benefits of online advertising enabled by third-party ad tech. I was, however, most inspired by the over 100 NAI members who participated in our Summit. We discussed the future of the third-party advertising ecosystem and there was a consensus that the future looks bright. But there was also consensus that industry must step up to the plate and continue to develop and honor best practices for the collection and use of consumer data. That means having in-depth discussions about new tracking technologies, best practices for the use of precise location information, and continued work in the areas of health and financial data for marketing. It means that, working together, we must develop meaningful standards and enforce those standards through NAI’s multi-pronged approach to compliance - pre-certification reviews, ongoing technical monitoring, responding to consumer inquiries, annual compliance reviews, and reporting.
I heard calls from NAI members to move faster to develop new Codes of Conduct and issue guidance around innovative business models such as new methods for maintaining state across websites. We’re working on it. We are also revisiting sections of the Mobile App Code and reexamining some of the requirements in the 2013 Code of Conduct. We don’t want to get too far ahead of the marketplace and we want our initiatives to be in sync with that of our sister associations. Finally, many members asked us to engage in more outreach to policy makers to explain the role and value of responsible third parties. We will do just that. In sum, I look forward to working with our Board and membership as we seek to ensure a thriving, diverse, innovative and competitive digital advertising ecosystem while promoting responsible data management practices and consumer trust. On the heels of the NAI Summit, I am more energized, more engaged and more optimistic than ever before.