By Kevin Trilli
VP Product Development | TRUSTe
Last week we launched our IE9 TPL program, which we blogged about here. It has been a great week to monitor and receive the reaction to the overall TPL program and TRUSTe’s list. In this post, we are following-up with more details around our program..
TPL Initial Launch and Background
As some background, TRUSTe released its initial list last week to be simply that – a starting point. As with any new product or program, we released the list very transparently, both to reflect our early thinking, but also to get feedback. Coupled with our spirited internal debates, we have had several very insightful discussions with the community.
Our TPL strives to be a balanced list of ALLOW and BLOCKS vs. the BLOCK-only lists that have existed in the Ad Block world and that were also released as part of the IE9 TPL launch. We truly believe there are good advertisers with respect to privacy and that many consumers prefer targeted and more relevant ads if they can be assured their privacy is respected and their choices honored.
To achieve this balanced vision, we have a lot of hard work to do with the initial launch just serving as a starting point. On the ALLOW side, we included those domains of current TRUSTe customers that have submitted themselves to TRUSTe privacy certification and testing and are in good standing. These customers prove to us on a recurring basis that they live up to our program requirements for responsible privacy practices and comprehensive disclosures.
TRUSTe’s mark elevates responsible players and the “ALLOW” status on our TPL provides an additional way to recognize companies with responsible privacy practices in an easy way for consumers to understand.
TPL Phase II
For this next phase, we are reviewing each ALLOW domain to better understand what data collection practices are taken at each domain and in what fashion (e.g., 1st party vs. 3rd party). There are some nuances that keep this from being a straightforward exercise. But this process is what TRUSTe has become very accustomed to doing. However, this process will take some time, so we’ll be updating our list as we process each of the domains on our list.
We stated in our initial blog post that we feel a great responsibility to the consumer due to our brand presence and meaning to consumers for good privacy. As such, we also intend to begin including companies we feel should be BLOCKed as part of this service.
As part of TRUSTe Website certification products, we provide our customers with reports on what trackers are on their websites through our site crawling technology platform. In performing that service, we have assembled a database on hundreds of trackers that provide cookies and other mechanisms for collecting data. We use this data source to prepare a preference service (opt-out) for our Trusted Ads product. In doing that, we manually inspect each tracker’s website, privacy policy and opt-out.
As we find companies that do not meet the standards that we are establishing for best practices, we’re going to add these companies to our BLOCK list. As part of this assessment, we’re going to reach out to each one of these companies to notify them through the contact info on their privacy policy and enable them to provide evidence of compliance to our criteria, whether they are a customer of TRUSTe or not.
If they successfully do this within 30 days, we’ll remove them from our TPL list and not BLOCK them. That said, we have found some tracking companies that will be immediately placed on our BLOCK list as they do not have some basic privacy fundamentals covered (i.e., unclear or lacking privacy policies for a companies data collection practices). To set expectations, look for the BLOCK portion of our list to build over the next 30-60 days.
Published Criteria for TPLs
As we require TRUSTe clients to be transparent about their practices, TRUSTe is being transparent about its list creation and curation process through a clearly defined set of standards and mechanisms for trackers to demonstrate they truly are doing the right thing.
It should be stated that this is an evolving space with many unknowns. As such, we will continue to refine and evolve our requirements as the industry matures, and we can better understand the tracking use cases our customers and others in the industry are employing.
Our current standards are reflected in any early set of principles and some specific requirements. You can find them here and we welcome feedback from you.
New Products
The core of our requirements for our ad-based products is demonstration of industry best practices for notice and choice. As such, we have two new products for those looking to participate in our program. These products offer a solution to hold tracking companies accountable for their practices, verifying they have internal controls in place to meet our standard, and mechanisms to enable tracking companies to demonstrate they are doing the right thing to consumers.
Data Collection Certification Program
We have been working on a new 3rd Party Data Collection Certification and Audit program for almost 6 months, which we are about to release in a generally available format very soon. This program will be one of the centerpieces for qualifying for an ALLOW status on our TPL and is especially geared for companies that do not have a consumer-facing interface. Look for an announcement very soon.
DAA Trusted Ads
Our DAA-approved Trusted Ads product is industry’s choice of solution for Notice and Choice. It presents advertisers, ad networks and publishers with a unique solution for providing in-ad and on-site notice and choice services.
Only companies that implement one of these products will remain on our ALLOW list, since it provides us with the direct oversight of their data collection requirements through our on-going monitoring, customer feedback and dispute resolution programs.
We ultimately want to be the single list that consumers can trust for good relevant ads, but without compromising their privacy. We think this is important, as without this kind of approach, the world will shift the way of Adblock has shown, which is to block all content by default due to the lack of other easy-to-understand choices for the mass market of consumers.
We know there are many ways one can determine this complex calculation, and TRUSTe presents just one view, which we hope both consumers and businesses find valuable. We believe many consumers have associated TRUSTe with good privacy. As such, we feel an obligation to continue and to extend this trust through the provision of this service.
But, we also want to work with industry players and present solutions to help them manage this difficult conversation with consumers, as many data companies do not have consumer-facing businesses and thus have not build brand familiarity. TRUSTe’s trusted brand can shine a bright light on those companies that are doing the right thing.
As such, we look forward to evolving our offering, as the IE9 TPL program continues to roll-out. We realize there will be issues that come up, and new understandings formed with operational experience. Our perspective is that we’ll consider each issue carefully and make the proper balanced decision that reflects our corporate values and benefits both the consumer and the business.