What Do We Really Mean When We Say We Will Not Track Online?

There's a Difference Between Do Not Collect and Do Not Target

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Over the past year there has been a lot of conversation about the do-not-track proposal the Federal Trade Commission outlined in its initial December 2010 draft report. Though a minor topic in the report, it has become the focus of discussions as the online-advertising industry grows rapidly and attempts to anticipate changes in the way it gathers and uses data to target consumers.

When do not track was proposed, the idea was that consumers should have a simple opt-out mechanism to prevent marketers from collecting information based on browsing activity and using it to deliver targeted online ads. But since the draft report was issued, what do not track means has been widely debated, and several definitions have developed. There is no consensus yet, a fact highlighted by the FTC recently.

The controversy comes down to the difference between data collection and targeted marketing: Does do not track mean do not collect or do not target ?

Do not collect would bar a website from gathering any data for any reason or use.

Do not target , on the other hand, would mean a brand could not display ads to a specific consumer based on data collected about that consumer. But the marketer could continue to gather information for other uses.

From the marketing industry's perspective, do not track reads more as do not target . In that case, the premise behind do not track is to let consumers choose not to be followed around the web by ads. For example, if they shop for a wireless printer on Amazon, they won't see ads in their email sidebar showcasing the printers they reviewed an hour before. But Amazon could leverage data about the consumer's browsing behavior on its own site to, among other things, improve search functionality or personalize the shopping experience for that user.

Consumer advocates and privacy groups have broadly and, arguably incorrectly, interpreted do not track to mean do not collect.

Was the do not track mechanism the FTC originally proposed intended as, "Do not collect any information about me online if I opt out?"

In evaluating the original concerns of the FTC and consumers, the answer should be no.

"If you ask the typical internet user what [tracking] means, they have visions of being followed around on the internet," said Lorrie Cranor, professor of computer science at Carnegie Mellon University and director of the CyLab Usable Privacy and Security Lab.

Consumers know that brands may be following their every move online so that they can target ads, which is what people may find invasive.

It's important to note that websites gather information for many reasons other than to fuel targeted advertising. They do it to better understand how people navigate and browse. They follow users on their own sites for general-market research and to enhance product development and analytics.

These findings help them improve functionality and features. It may also help maintain inventory and provide insights into consumer interest and intent.

Additionally, specific consumer data are often collected to record preferences and supply a customized experience -- all without displaying targeted ads.

Is there a perceived harm to the consumer if this type of information is collected but not used for targeted advertising? If not, why should the FTC and Congress prohibit its collection for this type of activity?

While we have not yet reached agreement the definition of do not track, considerable effort is being made to achieve understanding.

The FTC has pushed for the industry to work together on the meaning of do not track, and the World Wide Web Consortium has been working on the technical standard. How we define this opt-out mechanism remains to be seen, though we all recognize we cannot move forward until we do so.

Sarah Branam is privacy manager at Epsilon.

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