Association of Canadian Advertisers

10 December, 2010

Office of the Privacy Commissioner of Canada
112 Kent Street
Ottawa, Ontario K1A 1H3

Re: Draft Report on the 2010 Office of the Privacy Commissioner of Canada's Consultations on Online Tracking, Profiling and Targeting and Cloud Computing

We are pleased to provide you with feedback regarding your Draft Report. As an association of advertisers, the ACA's comments are directed exclusively to the portions of the Draft Report dealing with online tracking, profiling and targeting, also referred to as interest-based, or behavioural, advertising.

The ACA is supportive of the broad policy directions indicated in the Draft Report. As noted in our March 2010 submission, we have endorsed the World Federation of Advertisers' Global Principles for Self-Regulation of Online Behavioural Advertising, which incorporate policy themes identified in the report including education of consumers and businesses, transparency, and consumer control.

The Draft Report identifies a number of areas in which the OPC seeks to work with stakeholders in developing specific policy initiatives, including the public/private divide, standards for children's personal information, and procedures to obtain meaningful consent. The ACA is very interested in working with the OPC in developing policies for these and other aspects of online interest-based advertising. As the OPC moves forward in this initiative, the ACA welcomes opportunities to provide concrete policy input and to provide an industry/stakeholder sounding board for the OPC.

Thank you again for the opportunity to participate in this important discussion.

Yours truly,

Robert Reaume

Vice President, Policy & Research
Association of Canadian Advertisers

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