Three years ago, the Network Advertising Initiative (NAI) joined with a wide range of constituencies at the World Wide Web Consortium (W3C) Tracking Protection Working Group in an attempt to turn the phrase “do not track” into a meaningful global privacy standard that addresses both technical and policy challenges. NAI brought a unique perspective to the discussions because of our understanding of both privacy issues and online advertising our appreciation for the unique role of responsible third parties in delivering relevant digital advertisements. This perspective is reflected in our own tough standards that set a high bar for responsible data collection and use by our members.
Unfortunately, after investing significant resources into the Working Group’s “do not track” efforts over the past three years, we have concluded that NAI has no choice but to withdraw from the Group. The process, which has been so riddled with substantive and procedural flaws, will simply not produce a meaningful privacy standard. The remaining participants may well force through a standard, but that standard will be driven by a handful of stakeholders who represent only sliver of the ecosystem and who have competitive interests in the outcome. At this point, the prospects of wide scale adoption are remote at best and any “do not track” standard likely will be outdated before the first company can even sign on.
The concept of a new privacy choice mechanism is a laudable objective and many well intentioned individuals assembled at W3C, but the fact is that “do not track” is now so off track it is time to bring the process to close.
NAI is not alone in concluding that the W3C process is fatally flawed. The Working Group has gone from nearly 70 enthusiastic companies, trade associations, advocacy groups, and experts three years ago to barely a dozen individuals from a handful of organizations today. The reason is that, like NAI, many of these groups question the likelihood of a positive outcome and have been concerned about the integrity of the process. NAI joins these groups in concluding that the W3C effort cannot produce a responsible or practical standard.
While the W3C Tracking Protection Working Group’s process should end, this ending should mark the beginning of new efforts to help ensure the success of the global Internet and the protection of consumers’ privacy interests. Privacy in the digital age – and the era of big data -- is a legitimate concern. Innovation, personalization, and even customized advertising do not need to be at odds with privacy and responsible data governance. Moreover, privacy and profits are not zero sum game.
Responsible data collection and use are fundamental to the success of the commercial Internet, as are the principles of notice, choice, transparency, data minimization, use limitations, security, and accountability. Consumers should be able to express their preferences about the collection and use of their information — online and offline — and responsible actors of all shapes, sizes and labels should honor those preferences. These are the bedrock principles of the NAI Code of Conduct.
NAI believes in such high standards because consumer trust is fundamental to the success of the Web and the free, ad supported products and services consumers have come to expect. Consumer trust will be equally fundamental to the success of the “Internet of Things” as technology brings so many opportunities – and challenges – that could not have been imagined only a few years ago.
It is time to move on from the W3C “do not track” process. We look forward to working with other stakeholders on efforts to help ensure the health of our global online ecosystem. NAI is eager to invest our resources in new initiatives that address our core values of providing consumers with notice, choice, transparency, control, and accountability.