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Technical Compliance & Education - Follow Up on the White House Big Data Report

This morning NAI President & CEO Marc Groman shared his thoughts and analysis with members about the recently-released White House report on big data. I would like to add my own thoughts to the conversation about two topics I’m particularly passionate about - technology and education. First, the Report to the President on Big Data issued last week by the President’s Council of Advisors on Science and Technology highlighted the need to use technologies to improve privacy protection. We at the NAI agree with that premise, and especially with regard to technologies that can be used for compliance and accountability by self-regulatory organizations such as the NAI. Since 2012, the NAI has been using in-house software designed to help us spot various potential problems with consumer opt-outs. Not only is this automated tool capable of detecting these infrequent and unusual issues that can affect the setting of opt-out requests, it can do this for 100 members in one hour. In building this tool, the NAI sits as a leader in using technology for compliance. The monitoring tool helped the NAI develop new guidance for members to maintain continuity between technology upgrades, and it regularly confirms that consumers have an easy-to-use mechanism that will opt them out of many online advertisers’ IBA practices. One notable privacy advocate, Pam Dixon of the World Privacy Forum, described the NAI’s use of technology for compliance by publicly noting that "You shouldn’t have a bunch of ragtag privacy advocates clicking through and doing these reports, it needs to automated, it needs to be done by the organization, they need to pay for it, and they are. That’s good. These are positive advancements."

Two years later, the NAI continues to innovate. This year, we built new software that will notify staff when member companies make changes to their privacy policies. This tool reads text from members’ privacy-related pages and notifies NAI staff of additions and deletions, as well as page load errors. This automated privacy policy scanner is not a replacement for, but rather a supplement to the NAI’s manual, in-depth evaluations of privacy policies undertaken as part of each member’s annual compliance review. This new tool gives staff routine updates on changes to over 250 webpages comprising our members’ disclosures, making self-regulation even more thorough and efficient, while benefiting both consumers and the industry. For our next advancement, we are also working on a “mobile lab” to help us do compliance for business practices involving mobile applications, so stay tuned to learn more about that initiative in a future blog post. 

Second, the NAI also supports the Administration's recommendation to increase training opportunities for privacy professionals. That shouldn’t be surprising since Marc is on the Board of the International Association of Privacy Professionals and passionate about this topic. Marc requires staff to attend ongoing privacy and technology training throughout the year, and encourages us to find new opportunities for development. Moreover, this past year, the NAI started a new fellowship program for a qualified recent law school graduate with a background in technology. Our first fellow, Shaq Katikala, is a recent J.D. pursuing a graduate certificate in data science. Shaq is working on in-depth projects with each member of our staff, including the compliance review process, technical and policy research, and designing of in-house privacy software. In addition, we send our fellow to a number of industry training seminars and events to build privacy expertise in both the legal and technical sides. We are helping to train the next generation of privacy professionals - and in turn they are helping us maintain a state-of-the-art compliance and accountability program. 

We, like the Administration, believe that emerging technologies can be used to support privacy, enforce best practices, and promote consumer trust. We also believe that we must train and educate a new generation of privacy professionals. It’s an exciting time and we stand ready to work with industry, policymakers, advocacy groups, and consumers to ensure that data is used in innovative ways that benefits consumers while respecting privacy and other values.