Notice of Consultation and Call for Submissions
Understanding Online Tracking, Profiling and Targeting
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The Office of the Privacy Commissioner of Canada (OPC) invites your views on the privacy implications of the online collection of personal information by commercial entities for the purpose of tracking, profiling and targeting individuals in both the home computing and mobile device environments.
The aim of this consumer consultation is to learn more about such industry practices, explore their privacy implications, and find out what privacy protections Canadians expect with respect to these practices. The consultation is also intended to promote debate about the impact of these technological developments on privacy, and to inform the next review process for the Personal Information Protection and Electronic Documents Act (PIPEDA).
The consultation will begin with an open period for the submission of comments or papers by interested parties. The deadline for submissions is March 15, 2010. This will be followed by focused panel discussions in Toronto in April and Montreal in May. The Office welcomes applications for panel participation from a broad range of participants. Some audience seating will be available, and the events will also be webcast.
A second consultation on privacy issues emerging from the trend toward cloud computing will be announced shortly.
Advancements in technology have drastically reduced the cost of collecting and storing data, while radically increasing processing efficiency. This, in turn, has spawned industry practices that pose new challenges for the protection of personal information.
It has become common for enterprises to track the online activities of consumers, in order to deliver ads targeted to their inferred interests. The practice is referred to as behavioural advertising.
Information about people’s online behaviour is used to maximize their engagement with products and services. A related phenomenon uses information from cellular networks, Wi-Fi access points, satellite links and global positioning systems to deliver services to mobile devices. There are, for example, location-based services that recommend nearby restaurants or keep tabs on the whereabouts of friends.
Proponents say behavioural marketing and location-based tracking support free online content, allow people to receive more relevant advertising and discount offers, and promote the development of useful services.
Critics, however, warn that people may be unaware that their personal information is being collected, and do not understand how and why it is used. They also argue that, even when the information is considered anonymous, it can sometimes be combined with other information to identify individuals.
As stated above, the aim of the consumer consultation is to learn more about such industry practices, explore their privacy implications, and find out what privacy protections Canadians expect with respect to these practices. The consultation is also intended to promote debate about the impact of these technological developments on privacy, and to inform the next PIPEDA review process.
In advance of the panel discussions, we welcome written submissions of a maximum of 15 pages on the privacy implications of online tracking, profiling and targeting. We are especially interested in the following issues:
THE DIGITAL ENVIRONMENT
- Current industry practices and business models:
- Some current technologies:
- Consumer awareness:
- Citizens’ attitudes:
- Individual practices:
- Benefits consumers expect from data profiling
- Risks consumers take with their personal information
PRINCIPLES FOR INFORMATION GOVERNANCE
- Accountability (obtaining consent, individual access, accuracy, correction, redress)
- Transparency (public notice, privacy policies, corporate compliance)
- Consent (opt-in, opt-out, express, implied)
- Security (encryption, de-personalization, anonymity)
- Oversight (review, audits, impact assessments)
- Safeguards (retention, disposal, destruction)
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