Raising the COPPA flag for third parties

Melissa Juan – Director of Mobile Product Management | TRUSTe

The recent changes to the COPPA (Children’s Online Privacy Protection Act) rule put out by the FTC, attempts in part to address the confusion on who is really responsible for COPPA compliance, given that most digital properties are comprised of content or ads served by third parties.  According to the amended rule the onus is on the operator to comply.  Operators in this case, are companies that offer online services directed towards children or directly collect personal information from children.  Operators are typically first parties that include brands or publishers, but to complicate that statement further the COPPA changes state:

“…the definition of a website or online service directed to children is expanded to include plug-ins or ad networks that have actual knowledge that they are collecting personal information through a child-directed website or online service.”

This means third parties are indeed responsible, provided that they have “actual knowledge”.  There are two cases where third parties can obtain this knowledge.  One way is for the publisher to directly communicate the nature of their online service to all its partners and vendors.  Another way is for a representative from the third party to deem the site and/or app child directed after observing messaging, images and other artifacts that would appeal to just children.  In the mobile gaming world, there can be some blurred lines with the second method.

A developed flagging system to signal third parties would be much more scalable for the industry, rather than manually scanning sites and apps to discover if they’re child directed.  There are a few technologies already in place to enable first parties to communicate to third parties of whom their content and advertisements are being served to.  One mechanism of getting this knowledge isn’t any different than how they’re getting information to serve targeted ads and content to consumers via a JavaScript ad tag.

This comes from the Open RTB Specification, which is a protocol for communicating between the players of the ad ecosystem – SSPs, DSPs, ad networks, ad exchanges and data platforms.  In the spec is a user object, which contains information about the end user of a device or desktop that can be passed over to a third party content provider, or advertiser and the like.  It helps them determine what should be displayed in relation to the end user.  By passing another piece of information, for example a COPPA flag  (i.e. COPPA=Y in the buyerID field) stating that the embedding site is compliant to the rule, third parties can choose more appropriate content making a better experience for young audiences.   Using existing ad tags to receive this signal also creates efficient bidding in the exchange due to more accurate targeting.

In the case of mobile apps, understanding the end user of a device can be more challenging.  We live in a digital age, where children are more tapped into technology then ever before and devices are ubiquitous in day-to-day life.  Children may not own their own smartphones or tablets, but the vast majority of apps and media are targeted for young users’ consumption.  A friend told me that her son (who confessed that he loved the iPad more than his father) downloaded a seemingly harmless game.  She noticed that inappropriate ad images were being displayed so she immediately removed it from her device.  Something the app developer could do is pass the COPPA signal via an existing SDK, i.e. an SSP SDK.  This mechanism is specific to native mobile apps and also already used for online behavioral advertising practices.  At the time the app is initiated, it could transmit a signal to the third parties in the ad exchange.

Another avenue that app developers can take to ensure they’re COPPA compliance is communicated  is in the form of app monitoring and assessment.  These types of services audit the activity of the app including any data collection and transmission to third parties, as well as external calls made by the app.  This type of assessment can ensure compliance of self-regulatory governance such as COPPA and CalOPPA and create an insightful report, which can be used as a tool to communicate to all partnering companies who may collect and pass data from children using the app.  Each time an update is made to the app, the monitoring service can run a report and alert first parties to communicate to partners of COPPA compliance to send appropriate content and ads.

SDK work flow

Technology exists today for both the web and more importantly on mobile devices where children are the most vulnerable.  TRUSTe, the leader in global Data Privacy Management solutions, creates these technologies to allow for innovation and progress to continue and for self-regulatory mandates to be met by the industry for the consumer.  The TRUSTed Ads solution for display, mobile web and mobile app ads provides the mechanisms needed for involved parties in OBA to communicate end user opt-out preferences.  The preference reading JavaScript tag and SDK used to communicate consumer choice in online behavioral advertising can easily retrieve COPPA signals and propagate them to the industry.

TRUSTe also brings TRUSTed apps to the mobile industry, offering services that analyze app data collection practices, third party sharing for contractual provisions and data governance policies.  An enterprise version of this service additionally evaluates security and malware scanning of the app.   Raising the COPPA flag doesn’t require any heavy engineering or additional load to your site and/or app.  TRUSTe can provide the technology solutions to make it happen today.  It simply makes for a better, safer environment for all kids.


Managing Fourth Party Tags

I know what third parties are present on my website.

This is the response from a typical website operator when TRUSTe recommends an audit of all third party tracking on their site. How surprised they are to discover third parties on their site to which they were not aware. When this happens, and it happens often, the customer typically goes through reaction cycle:

  • First: Denial – “You made a mistake. We definitely do not deal with companies.”
  • Second: Prove it. Even though TRUSTe identifies the vendors responsible for allowing these additional third parties onto the site, customers often refuse to believe it. In one instance a customer went so far as to remove the identified vendor tag from the site and have TRUSTe rescan. Lo and behold, the unknown third parties were no longer present.
  • Third: Appreciation – “Wow this is great. We had no idea there there were other third parties on our site.”

So how do third parties get on a site?

I categorize third parties into two categories: “vendors” and “fourth parties.”

Vendors are those third parties your site calls directly, i.e. you have placed that third party tag directly into its HTML code.

Fourth parties are those third parties that may piggy-back off of a vendor tag to get to your site. As you are not calling them directly you may not be aware of their presence on your site.

Managing fourth parties

Are fourth parties “bad”? Not necessarily – in fact if you are relying on ad supported revenue then you should expect additional parties to be present in the ad chain, e.g., SSPs, DSPs, data providers, etc.

Do you need to know what fourth parties are present? Absolutely!

Step 1: Find out what vendors and fourth party tags are on your site.

Step 2: Effectively monitor and  manage these third party tags. Many companies opt for a tag management solution to help streamline third party tag management. Simply put, tag management involves replacing all third party tags on your site with one central tag container. All other third parties tags are then wrapped into this central tag container allowing a site operator to manage all tags in one central place. Tag management allows you to easily manage and remove a tags from your site.

Step 3: Ongoing site monitoring and tag management.

A tag management system alone, is not the silver bullet we would all hope it would be:

  • Tag managers can only manage the tags that they are allowed to see. They will not see any new tags added to your site outside of the central tag container – and let’s face it people are fallible. Even though internal policy might dictate that all tags must be added through the tag management system – mistakes happen.
  • There are limitations around managing and blocking redirects to fourth parties.
  • There is no insight given into client side behavior, e.g., what cookies, pixels or flash cookies are being set.
  • There is often no insight into who these parties are and what they do.

For this reason, TRUSTe’s Website Tracker Monitoring Service forms an important part of the tag management ecosystem. We Provide a comprehensive discovery of all vendor and fourth party tracking on your website and monitor your website on an ongoing basis for new parties and trackers.

Our service strengthens our customers’ overall tag management system by:

  • Providing complete initial discovery of all tags on a website.
  • Providing detailed information and privacy risk analysis on all fourth parties enabling customers to make informed decisions. TRUSTe’s database of over 17000 tracking domains is integrated into our reporting and is available as a standalone data set.  We know who these third parties are, what they do, their privacy practices and provide you with this information together with their overall privacy risk to your site and site users.
  • Providing detailed analysis of client side behavior e.g., what cookies, flash cookies, web storage, pixel tags and scripts are being dropped and by whom.
  • Continued monitoring and detection of unmanaged tags and fourth parties,
  • Verifying that the tag management system is operating as intended and only allowing authorized vendors onto the site.

TRUSTe provides integrated website consent mechanisms for users. Additionally, through partnerships with tag management, companies, e.g., BrightTag, TRUSTe has helped customers properly implement and manage their tag management solution. We can help you.







Through the looking Glass

By Clay Turk (@clayturk)
Product Manager | TRUSTe
View Kevin Trilli's profile on LinkedIn


Let me start by saying I am very excited about the upcoming release of Google Glass, and everything this means for the future of ‘enhanced’ reality (AR was so 2011). I suppose I should caveat this statement and say that my enthusiasm lies not so much in a Google specific version, but the release of this technology to the general consumer.

The idea of being able to walk down the street and quickly identify, route, or share your adventures as you experience them is simply fantastic. However, with this comes an inherent privacy concern; what if I don’t want to be ‘Googled’ when I walk past someone wearing Google Glass? What if I don’t want my location and activities witnessed or potentially recorded by an app or Google itself? How would one opt out?

It is not unreasonable to consider the following to be a common use case; a Glass wearing individual walks into a conference and is able to pull up LinkedIn or Facebook profiles simply by looking at someone. Taken a step further, Government could start wearing Glass to identify people by certain profile types, even picking out “criminals” based on historic data. There are certainly ample benefits to such applications, but I would argue that with these benefits come  at a definite cost.

Currently web profiling and targeting only pertains to the device used by the individual, providing the user the ability to maintain an online and offline “persona”. If a user decides they no longer wish to be targeted based on a profile they are able to opt out. Opt outs traditionally being a nullifying cookie which replaces the targeting cookie’s unique ID, resulting in the user either being removed or ignored by that “vendor’s” targeting on that browser/computer going forward.

This seemingly works well for a computer or device, but breaks down when it comes to an individual in the real world. Without a directory to store this information there would need to be something unique and trackable about the individual, a new “cookie”, which from an observer’s perspective, is most likely the face.

Taking this to be true, we are left with a rather interesting conundrum, in that assuming a person could “opt” their face out of recognition, they would inherently need to be identified each time for the device/service to know to block them. The currently recommended solution to this is simply telling the potentially affected party to not participate, but this really only applies for an on-premise video recognition system. How would this work when dealing with Glass apps that record in public spaces or even private property where the owner is unaware if a customer is wearing Glass? What about children? With COPPA finally here, privacy concerns for anyone under 13 are paramount to any online business. Does signage need to go up in our parks or on our streets? Or do we simply accept the situation and allow our right to privacy to shrink that much more.

We certainly don’t want to get in the way of technology evolving, nor do we wish to prevent this technology from becoming widely adopted, but feel we would be remiss for not asking the above questions. For the time being it appears it may take laws and regulation to ensure compliance, at least until people start caring more about their offline privacy enough to force a change.

Our entire lives are quickly migrating to the internet, which makes everything we do, say and experience available for the world to view and comment on. In this way, we are entering a new era, one where the potential reach of technology has far superseded our definition and scope of privacy. I can’t help but give pause and wonder if we aren’t letting our desire for this new technology get ahead of our ability to understand its potentially lasting effect on our lives, both public and private.


HTML5…I mean, Local…I mean, DOM…I mean, Web Storage!

By Kevin Trilli (@squawkt22)
VP Product | TRUSTe
View Kevin Trilli's profile on LinkedIn

As we have moved rather quickly into 2013, the subject of mobile privacy has brought a renewed focus to client-side storage of identifiers and attributes.  Initially, this was driven by the fact that mobile safari with its default-on cookie blocking policy is especially relevant in the huge adoption of IOS devices. Firefox has since elevated this discussion on the desktop side with their recently announced change in cookie policy. Classic third party http cookies can not be used for traditional uses that help facilitate the ad ecosystem and in particular the behavioral advertising systems.  As such, there has been a push to look at alternative methods to accomplish device identification within a browser.

This post will investigate one of those methods, the use of HTML5 or Web Storage, compare the current state of browsers and then make some recommendations around how they can be used to provide better operational processes, but also balance user privacy.

Web Storage
To start, we should all get on same page with what to call this thing, as initially it was derived from the HTML5 specification, but has subsequently been moved to a more general Web Storage specification in the W3C.  Many people still refer to this as “HTML5 storage” (inside TRUSTe also) but we are officially going with “Web Storage” so we do not have to keep using multiple names when we bring it up. Additionally, the term “DOM Storage” is also used but less so, especially by Mozilla and Microsoft and only appears in IE browsers externally.

The storage facility is similar to traditional HTTP cookie storage but offers some benefits commonly understood as:

  1. Storage capacity:  Browsers have enabled a minimum of 5Mb of storage inside a web storage object (IE has allowed 10Mb but it varies by storage type and browser).
  2. Data transmission:  Objects are not sent automatically with each request but must be requested.
  3. Client side access:  Servers cannot directly write to web storage which provides some additional controls from client-side scripting.
  4. Data storage:  Array level name/value pairs provides a more flexible data model

Privacy Implications
As has been discussed in the W3C spec and other forums, there are some considerations for privacy in place both within the spec design and implemented in the variable user agent controls present today in common web browsers.   Within the spec, there are options for user agents to:

  1. Restrict access to local storage to “third party domains” or those domains that do not match the top-level domain (e.g., that sit within i-frames).  Sub-domains are considered separate domains unlike cookies.
  2. Session and time-based expirations can be set to make data finite vs. permanent.
  3. Whitelist and blacklisting features can be used for access controls.

Consumer Controls
The immediate privacy controls exist within the user agents, and as with any user control, the degree to which the feature has been deployed and in what manner varies across the major browser in use.  This next section will provide a comparison of the four major browsers: (Note: This data is current as of the date of the post) 

Chrome Safari Firefox IE
Version Tested 24.0.1312.56 6.0.2 (8536.26.17) 19.02 10.0.9200.16521
Location Advanced>Privacy>
Privacy>Cookies and Other
Website Data; “Details”
Tools> Clear Recent History
> Cookies
Internet Options> General>
Browsing History>Delete>
Cookies and Website Data
Nomenclature “local data”, “Database
“Website Data”, “cache” “cookies” “Browsing History”, “Website Data”,
“DOM Storage”
Ability to see presence of Web objects Yes Yes No No
Ability to see contents of Web objects Yes No No No
Ability to block setting of Web storage objects Yes No No Yes (Internet Options>
Separate control Yes Yes
Combined with cookie control No – 3rd party cookie
setting separate
Default Off (Allowed) Off (Allowed)
Ability to delete content of Web Storage objects Yes Yes Yes Yes(2)
On exit of browser (Multiple) Yes Yes Yes(1) Yes
Individually Yes Yes No No

(1) DOM Storage can be cleared via “Tools -> Clear Recent History -> Cookies” when Time range is “Everything”. DOM Storage is not cleared via Tools -> Options -> Advanced -> Network -> Offline data -> Clear Now

(2) Included in the “Cookies and Website Data” setting.

I have to admit, this was a fairly intensive exercise, requiring some effort to discover and understand these different controls across the different browsers.  Most users only use one browser, but it is quite difficult to offer specific general guidance to consumers as it varies so widely by browser.

However, the general behavior of the web storage objects is trending towards that of cookies. It is expected that user agents will ultimately treat them the same way to ensure the willing and motivated consumer can feel that their expectations were met when turning on cookie controls or similar settings.

Generally, Chrome offers the best set of features in terms of clarity and advanced features.


Usefulness of Storage.  In some ways, Web storage provides a better long term solution to cookies, as the amount of information that can be stored allows for more uses.  One area this can be helpful is around storing multiple preferences across multiple third parties for privacy.  Another would be to store preferences a user has provided with intent and permission to be shared.  For example, “I allow my favorite brand, Burton Snowboards, to present me with their new snowboard advertising as I am in the market for a new board next season.  Also, they can share my info with different providers of boots and bindings as I would want to look at those also.”

Performance.  The usual trade-off of (1) unique client-side identifiers that point to server-side data vs. (2) heavier client side data plays an interesting role in performance optimization, especially in dynamic exchanges and other real-time operations.  Having a better option for richer client side data can help present additonal options for client-side optimization.

Privacy.  There are still some gaps from a consumer’s perspective depending on the browser used, as illustrated above.  But, generally, web storage objects are non-permanent so they can be deleted just like cookies and thus are as “safe” as cookies.  But, some degree of standardization is needed in terms of either merging controls with cookies or educating users that these also behave like cookies and need appropriate controls.  This is all trending towards happening in the coming short-to-medium time frame, so generally, the threat level is low around web storage objects in the medium term.

For the immediate term for those that want to use Web Storage, the high road should be taken on transparency of their use and providing an opt-out system similar to the industry transparency programs (e.g., AdChoices).  TRUSTe has already developed such system for those already using this approach in the mobile world, but it also applies for desktop users.  Clearly, a DNT-like approach can work once that spec reaches a landing point.

Finally, websites should regularly monitor their sites for the use of these technologies similarly to cookies and other tracking technologies.




More Resources:


Do Not Track and Preference Management

By Travis Pinnick
User Experience Designer | TRUSTe

The current industry standard of providing user preferences around ad-related tracking makes use of a script-based in-ad icon as specified by the DAA which links to a preference management tool. Newer browsers are also supporting the Do Not Track (DNT) header request as an alternate method of indicating user preferences.

With the proliferation of DNT it is becoming more obvious that future systems need to be technology-agnostic in their approach to preference management. Until the industry fully adopts DNT, a temporary solution could be to integrate DNT recognition mechanisms into existing cookie-based systems.

DNT vs Cookie-based preferences

DNT is a browser feature that appends a header to http requests expressing a user’s preference not to be tracked (currently implemented in newer versions of Firefox, IE, and soon to be implemented in Chrome).

A strong advantage of DNT is that it makes it easy for consumers state a clear preference regarding tracking. Unfortunately other than an acknowledgement response that the signal was detected, DNT lacks a technical method of enforcement and relies on trackers to honor the request.

Cookie-based opt-out tools are used to indicate that a user wishes to be opted-out of behavioral advertising. This places the burden of control on the user to deal with large numbers of tracking domains, and deleting cookies (a common consumer approach for controlling privacy) also deletes the opt-out preferences.

DNT Exception Handling

DNT in its current incarnation is a global preference associated with the browser, whereas cookie-based opt-out allows for granular tracker-specific preferences.

While DNT only applies to third party trackers, it’s still possible that a user may want to grant exceptions for third parties on a site they trust for the purposes of enabling desired functionality. For this purpose future browser implementations of DNT may accommodate exception handling – allowing the user to set browser-based DNT exceptions for specific domains.

view demo »

Mozilla was an early champion of DNT and specifically chose the term to avoid the ambiguity of interpretation that plagued cookie-based opt-out mechanisms. Microsoft’s surprising move to make DNT the default in IE10 will force the industry to decide how to interpret this signal. For companies who plan to honor DNT, this will be an opportunity for a new kind of consumer engagement and education by way of a DNT exception request, in which the publisher can request on behalf of the ad providers that the user allow tracking for a trusted site.

Complications of an Integrated Solution

One of the difficulties of integrating DNT and cookie-based preferences is that these two preference mechanisms, while similar in their representation of user intent, are functionally very different. DNT is a global setting in the browser and is communicated along with all http requests, while cookie-based preferences are maintained in the browser cookie storage and can only be accessed by the individual domains who set them.

Any preference mechanism which attempts to recognize both types of preferences will have to deal with collisions – what happens if the user has set a global DNT preference in their browser, but has an opt-in tracking cookie? Collision logic will be necessary to determine which preference is the most accurate signal of user intent. This will be complicated even further if browsers implement domain-based DNT exceptions, wherein users may have a global DNT preference, a domain-based DNT exception, and a cookie-based preference, any of which may conflict.

DNT and Automatic Cookie-based Opt-out

Since a user who has stated a DNT preference most likely does not wanted to be targeted, existing cookie-based systems could also be implemented to respond to DNT detection. TRUSTe has developed a DNT-integrated ad tag solution capable of acknowledging a user’s DNT preference and reflecting it via the transparency afforded by the in-ad icon, using the ad tag script to automatically record the user’s preference by triggering opt-outs for all tracking entities associated with the ad tag.
More on this »

A less invasive approach is for this option to be presented to the user in the ad interstitital messaging, or at the point of interaction with the preference manager (rather than being invoked by the script serving the ad tag). While functionally similar, this approach gives the user control over the execution of the opt-out, rather than letting the system do this automatically.

view demo »

The future of DNT is still uncertain, as the industry struggles to reach an agreement regarding how it should be honored, which its inclusion as a default in IE10 will only reinforce. A parallel approach to this is to find ways to integrate DNT recognition mechanisms into existing preference systems in ways that are both meaningful and graceful, without forgetting its original intent.


Technical Analysis of the IOS6 Tracking Identifiers and Privacy System

The new release for IOS6 contains several improvements in the tracking and privacy systems for advertisers and consumers. The release features are definitely just a starting point in what appears to be a long term strategy to embed privacy controls into the platform.  Below is an analysis of what is included within the system along with some insights from TRUSTe based upon on our learnings from launching the industry’s first comprehensive mobile ad privacy system earlier this year.

From a high level, there are two major components to this system:

  1. A new system for identifying users based upon two identifiers.
  2. A new privacy control system for users to signal privacy preferences.

New IO6 Identifiers

The two identifiers are as follows:

  1. advertisingIdentifier(aI)
    • Per the documentation, this is a read-only, alphanumeric string unique to each device, used for advertising only.
    • The value is constant for all third parties, but the ID can be deleted “if the user erases the device.”
  2. identiferForVendor (idV)
    • Per the documentation, this is a read-only, alphanumeric string that uniquely identifies a device to the app developer.
    • The value is the same for apps that come from the same app developer running on the same device.


  • These IDs are an improvement over UDID and MAC Address usage, as the ID’s are non-permanent, can be deleted and have two different systems that can be used for Advertising and Analytics.
  • Offering a separate developer-only version also provides some origin control around access to the ID.  But, the aI is available to any third party so profiles can be built across different apps.
  • In order to delete these ID’s, users will have to erase their device to remove the ID which is a pretty extreme analog to clearing your cookies from your browser.
  • Cookies also offer the added benefit of including expiration dates so they only be used for short finite periods, whereby these IDs offer no such controls.

New Tracking Controls

There is a new “Limit Ad Tracking” function that allows phone users to control the use of their aI by advertisers.

  1. There is a user-controlled setting under “About” in the Setting menu where a user can turn this on or off.  It is defaulted OFF.
  2. Apple Provided text to consumer:
    1. iOS 6 introduces the Advertising Identifier, a non-permanent, non-personal, device identifier, that advertising networks will use to give you more control over advertisers’ ability to use tracking methods.
    2. If you choose to limit ad tracking, advertising networks using the Advertising Identifier may no longer gather information to serve you targeted ads.
    3. In the future all advertising networks will be required to use the Advertising Identifier.
    4. However, until advertising networks transition to using the Advertising Identifier you may still receive targeted ads from other networks.

How exactly does this work?

There are two new functions:

  1. NSUUID *adid = [[ASIdentifierManager sharedManager] advertisingIdentifier];
  2. BOOL tracking = [ASIdentifierManager sharedManager].advertisingTrackingEnabled;

The first function is to get the aI , and the second one requests the state to check if tracking is enabled (it is ON by default), which is sort of a “DNT” flag concept:

  1. When a user keeps the Limit function in its default OFF position, the aI gets sent to third parties and “TrackingEnabled” returns “YES.”
  2. When a user turn on Limit Ad Tracking, the aI still gets sent and “TrackingEnabled” returns “NO”.


  1. This is definitely an expert function for the most privacy-sensitive users, which TRUSTe applauds Apple for making these controls available as a baseline.  General consumers will not know this function exists without additional education.  As such there is still need for a transparency system by app developers and the ad industry to let users know when their data (identifiers) is being used by third parties.
  2. There is only one option to Limit Ad Tracking and this is a global setting. There needs to a more granular system to allow users to provide exceptions beyond the global option, as some [free] apps are predicated on the fact that they can be ad supported.
  3. This system has some structural similarities to the DNT header feature that is rolling out in most browsers, but with some important gaps like Exception management and some definitions around what behaviors are expected by third parties once the user has set the flag.
  4. It is unclear how this system will work in conjunction with the browser-side DNT deployment that also is rolling out in IO6.
  5. It appears that restricting access to UDID and MAC address will occur at the app approval process vs. platform level, as access to the UDID is still possible when the Limit flag is set.  There are no official positions stated by Apple around MAC address, but one would have to assume this will be eventually limited like the UDID was.


This is an interesting first step for Apple to bring some improvements to its platform, to help advertisers offer targeted advertising in a more privacy-safe manner.  But, there are still some pretty important gaps around user transparency, user education and more granular choices that reflect those users that want free apps from trusted brands.

TRUSTe has been working hard for over a year on its TRUSTed Mobile Ads product with leading app developers and third party ad and data providers to provide users with transparency around their data use and flexible choice options on how they want their information shared with third parties.  This information includes their device ID’s but also other parameters that are used by advertisers.

TRUSTe’s solution offers a very robust set of choice options that include permissions for brands, ad networks and global preference options.  The solution also binds these preferences across both sides of the mobile device to give the user comprehensive control.  Finally, it is a general permission framework which goes beyond just those users that wish to opt-out, but also provides capabilities for user to tell advertisers what they are interested in, which is what a full-featured interest and privacy system should accomodate.

TRUSTe looks forward to evolving its solution alongside this new IOS solution in addition to the DNT program on the browser side.  TRUSTe’s solution is ID-agnostic, so it will automatically work with the new IDs.  The TRUSTe solution will also be compatible with any user-invoked settings via the Limit Ad Tracking settings.


San Francisco Privacy Engineering Meetup – Kickoff

The San Francisco Privacy Engineering group held its first meetup in late August at the TRUSTe’s office in Union Square. Eleven attended keeping it perfectly sized for an intimate discussion around Travis Wellman describing “Spaciousness”, a new model, based on Content Addressing and graphs, for users to store their information in the web. The new model differs from the walled garden approach prevalent in today’s web in how data is addressed and queried. There are Photos of the meetup and Travis has provided slides here to check out.

SF Privacy Engineering brings together those interested in learning about and discussing technical issues surrounding data privacy issues on the web and mobile devices. Specifically, developers who develop or spec out systems/applications to discover personal data transfers, inform first parties of data transfers and manage permissions and preferences for personal data transfers. What is personal data? That is a good subject for an upcoming meetup.

Please keep an eye out for the next meetup on our SF Privacy Engineering home page. We are planning to meet monthly and are now scheduling speakers for the next couple of meetings.

If you would like to present at a meetup, please let us know by submitting suggestions on the meetup home page, or by emailing the organizers (Joseph Green or Jenny).

We look forward to meeting you at the next meetup!

Joe Green
Director, Engineering



Mobile Privacy Consumer App

By Travis Pinnick
User Experience Designer | TRUSTe

TRUSTe is in the process of designing a consumer app that addresses mobile privacy issues. The current app design consists of 3 sections:

  • App Permissions (reflects the current permissions of apps on the user’s device)
  • App Activity (allows the user to see what data calls their apps are making and to whom)
  • Ad Preferences (a mobile version of our Trusted Ads Preference Manager)

The app will probably initially be Android only, as iOS doesn’t allow access to the permission and data transmission information.

Interactive Demo »

Initial Design and Testing

We conducted a small user test of the initial design to assess overall messaging and usability, as well as the perceived usefulness of the app content. Overall users liked the app, and no one had any trouble with the overall purpose or usability of the app.

App Permissions

Most of the users initially deemed the App Permissions section the most valuable (though a couple ended up preferring the App Activity section once they understood its function). Because the App Permissions section shows information that can already be accessed in Android OS settings (though in a different format), I was surprised by it’s perceived value. Maybe this is because consumers like to have similar related functionality in a single app.

App Activity

Users seemed to have the most confusion with the App Activity section (called ‘App History’ during the user test – other names considered were “Data History” and “Data Access”). None of the users was able to articulate what they expected this section to do until after they had seen it, so finding a title that conveys the appropriate meaning to users will be very important. Users were split on their perceived value of this section; more technical users were interested in who their apps were contacting from a privacy perspective, while less technical users were interested in the frequency with which their apps were using data from a resource conservation perspective.

Ad Preferences

As with similar tests of our desktop preference manager, most users had confusion around what it means to set an ad preference. This is probably to be expected, since ‘opting-out’ in the desktop world generally means opting-out of targeting only, and the mobile equivalent has yet to be defined (TRUSTe’s mobile preference management system currently stores a user’s preference for an ad provider to access, but the industry is still debating how the preference will be interpreted).


The purpose of creating a consumer app should be consumer engagement, and it seems evident from the testing that consumers are responding well to this “all in one” multi-component privacy app idea. This design is still a work in progress, and feedback is welcome.


Designing Effective Policies

By Travis Pinnick
User Experience Designer | TRUSTe

Policy policies as initially conceived were meant to afford consumers protection from poor data practices, but have since evolved to serve more as legal protection for the companies collecting the data. As such they are often needlessly complex and intentionally vague.

Therefore there is strong interest, especially among regulators and consumer advocates, to move beyond policies into easily digestible privacy short notices that can be represented in the browser.

Attempts to Summarize Policy Data

An early approach for simplifying the consumption of privacy policies was the Platform for Privacy Preferences (P3P) developed by Lorrie Cranor (Carnegie Mellon CyLab), which enables sites to express their privacy practices in a standard format that can be interpreted by machine-readable user agents. A short notice style of P3P agent which gained attention was the Privacy Nutrition Label by Patrick Gage Kelley (Carnegie Mellon CyLab), which was able to display P3P policies in a graphical matrix which compares the types of data collected to the uses of that data. A similar icon-based approach to visualizing privacy policies called KnowPrivacy was attempted by UC Berkeley graduate students Soltani, Gomez, & Pinnick. Both designs display policy data for a wide number of categories in a grid format.

(left: Kelley’s Nutrition Label; right: KnowPrivacy’s icon policy summary)

In 2010 Mozilla hosted a workshop about the use of privacy icons to communicate only the most important information practices to consumers. Workshop feedback suggested that privacy icons should ONLY be used when the user does NOT have a reasonable expectation regarding how data is used, and that the icons needed to represent a small number of categories in order to be useful in a consumer-based short notice.

The revised versions of the Mozilla icons (started by Aza Raskin and finalized by Alex Fowler and Ben Moskovitz with icon design by Disconnect.me) consisted of four categories: Third Party Use, Sharing with Ad Networks, Sharing with Law Enforcement, and Data Retention. Similar to other attempts at icon designs, each category (except for retention) used 2 icons per category to represent binary states.

What policy summaries mean to users

TRUSTe also conducted a user test of both the Mozilla policy summary icons and a similar set proposed by TRUSTe. Both were well received, but testing suggested the following conclusions:

  • Users don’t seem to have preconceived notions of what categories make the most sense regarding privacy. Every user tested was unable to articulate what categories they expected to see, but also every user agreed that the first categories they were shown met their expectations
  • Icons aren’t important, it’s presentation and finding the appropriate method (and timing) of delivery that’s important. The actual icon used seemed to be of minimal importance compared to user concerns over presentation of the short notice categories. No user was able to articulate clearly what icons they associated with the categories other than the ones shown, and several commented that icons work as long as they make reasonable sense in context

There is clearly a need for policy summary data, but consumers are looking to privacy and policy experts to find the appropriate method of delivery.

New applications for policy summaries

TRUSTe has also been encoding short notice data for client re-use.  We’ve built the capabilty to read this short notice data into our layered privacy policies, adding an extra summary layer to the full policy information.

We’ve also built the capabilty to read this short notice data into a couple of our products where it makes sense for a user to need this information (like at a decision making point regarding a site, app, etc). One example is our Tracker Protection browser client, a tracker blocker plug-in which can also read our policy summary data for a given site, the other is our EU Cookie Consent Manager offering.

Policy data and mobile

Mobile presents more challenges in delivering policy information. Most mobile apps and web apps have just as complicated data collection practices as their desktop counterparts, but with even less screen real estate available to convey this information.

Shown here is our mobile-optimized privacy policy we provide our mobile certification customers. TRUSTe and Privacy Choice also offer free mobile privacy policy generators for app developers.

Mobile also provides another opportunity for the delivery of policy summary data. Unlike normal web browsing, the nature of app usage provides an ideal time in the user experience to provide summary information – at the point of installation.

Shown here is an early version of our policy short notice integrated into our mobile-optimized privacy policy. Also shown is the treatment of android’s permission summary screen, which is an analogous example of delivering summary data at a highly relevant decision-making point in the mobile user experience.

(left: possible TRUSTe mobile short notice; right: Android permission consent)


An effective policy summary should:

  • Provide only the information that is most relevant, like the data collection practices which are invisible to users
  • Support a user’s ability to assess a site or app’s privacy practices at an appropriate time (like a decision making moment such as app download)
  • Support a method of delivery that is informative without being overwhelming or intrusive to the user experience

For all the talk about icons, what really matters is the delivery of easily consumable summary data at the appropriate time when it is most relevant and least intrusive.

For more on this topic see my talk at the PII 2012 creating effective policies panel with Casey Oppenheim (Disconnect.me) and Jim Brock (PrivacyChoice).

Follow me on twitter at @xtratrav.


Transitioning ‘Ad Choices’ to Mobile Apps

By Travis Pinnick
User Experience Designer | TRUSTe

TRUSTe is preparing to launch an ad preferences offering for mobile apps, which essentially takes the foundation of our Trusted Ads tracker database and applies it to the mobile ecosystem. Unlike the Trusted Ads offering, which uses an ad tag that displays the ‘ad choices’ notice and directs users to the Preference Manager, the mobile offering requires an SDK to be embedded by the app publisher. The SDK can be created by either an app publisher, ad network, or ad network aggregator, and functions by storing a user preference which is associated with a revokable device ID, an app ID, and one or more ad network IDs.

View demo of the various implementation options »

Publisher Implementation

The publisher version of the SDK has a number of options regarding how the preference manager mechanism is invoked. The publisher can include an option to set preferences in the app settings, in a first time user alert, or anywhere else the publisher deems appropriate.

Ad Network Implementation

The ‘ad choices’ in-ad tag approach is the only preference manager invocation option for ad network SDKs, since the ad network only has access to in-ad content. Unfortunately the ‘ad choices’ ad tag doesn’t translate well to mobile ads, as it’s about 15 x 15px (the smallest recommended clickable icon size for mobile is 40 x 40px), but anything bigger will dwarf the ad content in an already limited ad unit space.

A potential solution is having the ad tag be a static part of the ad content, and moving the actual invocation mechanism to the frame of the full page ad the user sees after clicking the ad and being taken to an in-app web view. It requires the user to actually open the ad to access the preference manager, but it’s still a viable solution for ad network SDKs, especially considering the lack of alternate locations.

Follow me on twitter at @xtratrav.

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