UK Cookie Law Compliance: Implications & Answers

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The ePrivacy Directive (UK Cookie Law) went into force on the 26th May. What if a single line of code could make you compliant?

Hear from the ICO, KPMG, Field Fisher & Waterhouse, and Ensighten to learn about the legal, marketing and business implications of the ePrivacy Directive. Find out how UK businesses are preparing and discover a new and very simple route to immediate and future compliance.

The ePrivacy Directive: Legal Implications
Stewart Room, Partner at Field Fisher & Waterhouse

Analysis: How UK Businesses Are Preparing
George Thompson, Director, KPMG

The New Regulations: Practical Steps.
David Evans, Group Manager, ICO

A Single Line Of Code: Solving The Compliance Challenge.
Des Cahill, VP Marketing at Ensighten

Panel discussion: Can cookie law compliance compliment digital marketing best practice?
Mike Weston, Managing Director, Profusion
Stewart Room, Partner at Field Fisher & Waterhouse
George Thompson, Director, KPMG
Des Cahill, VP Marketing at Ensighten

Conclusions & Next Steps
Adrian James, Managing Director, EMEA, Ensighten


Learn how the legislation could even be used to improve digital marketing practice and business performance rather than hinder it.

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  • Click to edit Master text stylesSecond levelThird levelFourth levelFifth level
  • make this look nicer
  • Want to make this have more graphically interesting. Maybe icons for the main bullet points. Or make icons for fast deployment, Tag detection, tag control, tag monitoring……..
  • Make the section headers (1, 2, 3 and copy) look nicerNeed a graphic for 3. maybe a map of world showing nodes (circles) on it representing our network colo locations. connect the colos with lines to show that it’s a global network. See Slide 3 (which you created) for an idea – I need a smaller version of that map. Or another creative way to show a global network infrastructure.
  • If you are one of 100 TagMan customers AND are among the 10% with all tags in TagMan TMS and you put all new tags in there and you are also an Evidon customer….you have a partial privacy solution at a cost of about $125k-$250k.
  • Click to edit Master text stylesSecond levelThird levelFourth levelFifth level
  • UK Cookie Law Compliance: Implications & Answers

    1. 1. Enterprise Tag Management UK Cookie Law Compliance: Implications & Answers 23rd May 2012 - The Hospital Club, London #PrivacyEU
    2. 2. Ensighten Overview  Enterprise Tag Management solutions  Customers use Ensighten to manage 3rd party tags (ad networks, social sharing, analytics, etc.) on their websites – accelerate website page load – manage website consumer data collection – site privacy and compliance (partner with PrivacyChoice)  Founded in 2009 – Cupertino, CA; London UK  Solutions for web, mobile apps, flash  40+ F1000 customers2 | Ensighten, LLC. - Confidential, All Rights Reserved.
    3. 3. Ensighten technology powers these sites
    4. 4. Agenda 16:20 The ePrivacy Directive: Legal Implications Stewart Room, Partner, Field Fisher Waterhouse 16:45 ePrivacy: How to face the Cookie Monster George Thompson, Director, KPMG 17:05 Cookies: View from the ICO David Evans, Group Manager – Business and Industry, ICO 17:25 A Single Line Of Code: Solving The Compliance Challenge Des Cahill, VP Marketing at Ensighten 17:35 Panel discussion: What impact will the UK Cookie Law have on digital marketing strategy? Mike Weston, Managing Director, Profusion Stewart Room, Partner, Field Fisher Waterhouse George Thompson, Director, KPMG David Evans, Group Manager – Business and Industry, ICO Des Cahill, VP Marketing at Ensighten 17:55 Conclusions & Next Steps Adrian James, Managing Director, EMEA, Ensighten 18:00 Drinks Reception4 | Ensighten, LLC. - Confidential, All Rights Reserved.
    5. 5. Cookie consentStewart Room, PartnerStewart.Room@ffw.com
    6. 6. • No dropping of cookies without consent (storing in terminal equipment, accessing information in terminal equipment)• Specific, informed, freely given and prior?• Express and implied• Subscribers and user and people under a disability• The consent journey – information but activity• Terms and conditions and information society services
    7. 7. • Twitter @StewartRoom• www.stewartroom.com• www.ffw.com• http://privacylawblog.ffw.com/
    8. 8. e-PrivacyHow to face thecookie monsterGeorge Thompson23rd May 2012
    9. 9. © 2012 KPMG SA, a Swiss corporation, is a subsidiary of KPMG Holding SA, a Swiss corporation, which is a subsidiary of KPMG Europe LLP and a member of the KPMG network of independent firms affiliated with KPMG International Cooperative 9(KPMG International), a Swiss legal entity. All rights reserved. The KPMG name, logo and „cutting through complexity‟ are registered trademarks or trademarks of KPMG International
    10. 10. Agenda 1. Introduction 2. Compliance survey 3. Clients issues© 2012 KPMG SA, a Swiss corporation, is a subsidiary of KPMG Holding SA, a Swiss corporation, which is a subsidiary of KPMG Europe LLP and a member of the KPMG network of independent firms affiliated with KPMG International Cooperative 10(KPMG International), a Swiss legal entity. All rights reserved. The KPMG name, logo and „cutting through complexity‟ are registered trademarks or trademarks of KPMG International
    11. 11. KPMG surveySelected major UK organisations across a wide range of sectors – 55Website analysis Presence of Cookie, trackers etc Presence of Privacy Policy/T&Cs etc that explain cookie/tracker usage by the site Presence of consent mechanism Analysis of resultsResults 1 website compliant with consent mechanisms in place 2 websites with privacy policy stating the site would be in compliance by 26th May 2012 2 websites with no cookies/trackersNext Steps: Re-run survey post 26th May© 2012 KPMG SA, a Swiss corporation, is a subsidiary of KPMG Holding SA, a Swiss corporation, which is a subsidiary of KPMG Europe LLP and a member of the KPMG network of independent firms affiliated with KPMG International Cooperative 11(KPMG International), a Swiss legal entity. All rights reserved. The KPMG name, logo and „cutting through complexity‟ are registered trademarks or trademarks of KPMG International
    12. 12. Client requests ChallengesWhat are my peers doing? Who is responsible?What do I need to do?  Privacy Officer First party  Marketing/HR/IT Third party  Third partyWhich websites? How do I assess and manage the risks? Corporate  Compliance risks Affiliates  Technology risks HR services  Contract/Sourcing risks Marketing  Consumer Impact Third parties© 2012 KPMG SA, a Swiss corporation, is a subsidiary of KPMG Holding SA, a Swiss corporation, which is a subsidiary of KPMG Europe LLP and a member of the KPMG network of independent firms affiliated with KPMG International Cooperative 12(KPMG International), a Swiss legal entity. All rights reserved. The KPMG name, logo and „cutting through complexity‟ are registered trademarks or trademarks of KPMG International
    13. 13. Defining the scope of the issueIn scope: Other considerations:Cookies that store and track information  Intrusivenessabout your site visitors  Data passed to an organisation the First / third party individual would not expect Session or persistent  Sensitive data Flash, web beacons, gifs.  Aggravating factors (e.g., could the site‟s use of cookies be perceived as All equipment (e.g., mobile devices) disingenuous?)Not in scope: Cookies whose sole purposes is to facilitate communication over a network Strictly necessary for the provision of service requested by the user© 2012 KPMG SA, a Swiss corporation, is a subsidiary of KPMG Holding SA, a Swiss corporation, which is a subsidiary of KPMG Europe LLP and a member of the KPMG network of independent firms affiliated with KPMG International Cooperative 13(KPMG International), a Swiss legal entity. All rights reserved. The KPMG name, logo and „cutting through complexity‟ are registered trademarks or trademarks of KPMG International
    14. 14. KPMG approach I - Discovery KPMG will run a discovery phase to identify websites that contain client specific names, brands etc. This data is used to create an inventory of internet presence II - Data Gathering (asset inventory) which the organisation uses to assign A crawl, with pre-agreed limits, will be ownership/responsibility and creates the baseline for performed that gather information on all compliance reporting. cookies set for each site. This will record both persistent and session cookies as well as those issues by any third party (e.g. analytics or advertisement related). III – Compliance and Risk Assessment IV - Remediation Output from previous two phases will KPMG will advise on which cookies require be compared and any non-compliances consent as well as advise on potential reported. Further KPMG will provide an solutions. If required, KPMG can re-do inventory of all cookie data, together selective crawls to confirm adequacy of any with appropriate summaries of remediation activity. information collated.© 2012 KPMG SA, a Swiss corporation, is a subsidiary of KPMG Holding SA, a Swiss corporation, which is a subsidiary of KPMG Europe LLP and a member of the KPMG network of independent firms affiliated with KPMG International Cooperative 14(KPMG International), a Swiss legal entity. All rights reserved. The KPMG name, logo and „cutting through complexity‟ are registered trademarks or trademarks of KPMG International
    15. 15. Websites Discovery and Risk AssessmentI - Discovery Phase II - Data Gathering Phase Attributes that can be gathered from headers or basic trawling, such as: - Software version Known URL‟s - Development framework Detect Websites - Cookie details Additional information from e.g.: Gathering of site attributes for websites - Public registrars (primarily automated) - InfoChimps GeoIP data set. Reconcile Discovery - Technical characteristics of Web site results with the list of - Geo-location and provider known URLs. - Site purpose - Compliance items (Privacy policy, terms and conditions) Business value determined by the impact that Client aces through the exposure to their consumersIV – Security and Privacy Remediation III - Risk Assessment Phase For high risk websites: High Web app testing - Payment handling, - Old framework with known - Old frameworks with Technical Risk vulnerabilities Compliance assessment limited security capability - Brochureware (e.g. classic ASP) HL HH Vulnerability assessment - Site out side Client control - Gathering of PII. (sponsorship). - Modern language with Remediation - Static content, limited known secure options by Risk assessment drives the information collected. default. scope and level of assurance and LL LH the priorities for remediation. Low Business value High © 2012 KPMG SA, a Swiss corporation, is a subsidiary of KPMG Holding SA, a Swiss corporation, which is a subsidiary of KPMG Europe LLP and a member of the KPMG network of independent firms affiliated with KPMG International Cooperative 15 (KPMG International), a Swiss legal entity. All rights reserved. The KPMG name, logo and „cutting through complexity‟ are registered trademarks or trademarks of KPMG International
    16. 16. Further challenges No clear view on what kinds of consent will be meet requirements:  Browser settings – unlikely to work  Pop-ups and similar techniques?  Terms and conditions?  Settings/Feature led consent?  Functional uses?  Third party cookies? Evolving models  IAB industry icon and opt-out page© 2012 KPMG SA, a Swiss corporation, is a subsidiary of KPMG Holding SA, a Swiss corporation, which is a subsidiary of KPMG Europe LLP and a member of the KPMG network of independent firms affiliated with KPMG International Cooperative 16(KPMG International), a Swiss legal entity. All rights reserved. The KPMG name, logo and „cutting through complexity‟ are registered trademarks or trademarks of KPMG International
    17. 17. Thank yougeorge.thompson@kpmg.co.uk +44 7802 155857
    18. 18. Cookies: View fromthe ICODave EvansSpring 2012
    19. 19. Introduction and contents• Where we all are• What the ICO has seen over the past year• What we plan to do• What everyone else needs to do
    20. 20. A man walks into a bar…..• The case for tailored/targeted/personalised/more relevant service is easily made in the abstract.• But just because nobody would volunteer for off-the- shelf/scattergun/impersonal/irrelevant service doesn‟t mean they will give up everything in the search for better content.• The same people who say they want more relevant content are the same people who do not wish to be tracked online.• It is important to see the revised „cookie rule‟ as an opportunity to ensure that people are aware of and comfortable with what you are doing.
    21. 21. The revised law6. - (1) Subject to paragraph (4), a person shall not store or gain access to information stored, in the terminal equipment of a subscriber or user unless the requirements of paragraph (2) are met. (2) The requirements are that the subscriber or user of that terminal equipment - (a) is provided with clear and comprehensive information about the purposes of the storage of, or access to, that information; and (b) has given his or her consent
    22. 22. Where we are• Almost a year in – remember, the 12 month lead in related to ICO‟s regulatory approach not to the law itself.• Guidance and advice has been available from ICO since the Regulations were passed.• We are seeing lots of good work – but until it all ends up on websites there is a risk that bluster, scare tactics and burying of heads will win the day• We need to do our job in a responsible and proportionate way; for this to happen we need assurances that the good work will continue.
    23. 23. Where we are (2)• ICO guidance described as being helpful and useless; vague and clear.• There have been calls for my office to tell people exactly what to do.• Important point: it is not the regulator‟s job to tell people how to run their business.• It is far more appropriate to give guidance and advice on approaches taken and to ensure that the unwilling get their act together.• Be careful what you wish for….
    24. 24. What we have seen• We have seen progress on browser settings• Browser settings can work and will be one method of gaining consent for all the cookies which you can honestly categorise as “privacy” neutral.• Remember, the law says consent from the browser depends on the subscriber having taken some form of action• Many people, particularly those who are using old, creaking versions of browsers might never have set or amended anything; how can you show your website is not taking advantage of this?
    25. 25. A few words about analytics• They are not exempt• This is not ICO being awkward or gold plating and we definitely appreciate how important this functionality is.• BUT saying that analytics activity allowed by the setting of a cookie is within the scope of the law is not the same as saying the law requires an opt-in model.• Recent guidance from government has been interpreted to mean “don‟t bother about analytics”• ICO guidance is that you do need to bother but…..
    26. 26. Future plans (1)• We will supplement existing guidance in the following ways: – Assessment of efforts made so far – Clarification of the acceptability of implied consent – Further detail on our regulatory priorities
    27. 27. Future plans (2)• There are lots of gaps around at the moment• Like nature, regulation abhors a vacuum• We all need to fill those gaps with evidence of good practice, practical and realistic guidance and consistency across websites.• Without genuine efforts at compliance the bluster and scare tactics will fill the gap between what the law says and what you are doing.• The more users become accustomed to good practice the easier it will be to get consent and the harder it will be for the unwilling to find an excuse.
    28. 28. Next steps• Will continue to work with industry and European colleagues to address difficult areas• The updated ICO advice is available and will be amplified in the run up to May• We know there are organisations out there doing this properly and their efforts will make the „do-nothings‟ stand out.• If cookies are so important why is it that only 13% of users we confident they know what a cookie was and what it did?
    29. 29. Keep in touchSubscribe to our e-newsletter at www.ico.gov.uk or find us on… www.twitter.com/iconews
    30. 30. Enterprise Tag Management ePrivacy – Marketer‟s Perspective Des Cahill, VP Marketing Ensighten May 22, 2012
    31. 31. Marketer‟s & ePrivacy - Questions  Targeted offers vs. consumer privacy  Sell locally, comply globally – DNT for U.S., Cookie Law for U.K., what‟s next….  Who are the internal stakeholders? – Legal, Privacy, Security, Marketing, Agency  Brand and privacy – Brand attribute or hindrance?  Data collection – want vs. need31 © 2012 Ensighten - All Rights Reserved.
    32. 32. The Tag/Cookie Continuum Benefits Benefits Consumer Website Publisher Shopping Cart Analytics Ad Network Remembers items Counts the number makes inventory in a cart of pages visited available for cross- site campaigns Personalization Re-Targeting Real-Time Bidding Personalizes Shows ads to prior sells audience content such as site visitors impressions at auction welcome page32 © 2012 Ensighten - All Rights Reserved.
    33. 33. Marketer‟s & ePrivacy - Actions  What data is collected on my site(s)? – Tags – javascript for 1st party & 3rd party data collection – Cookies – in browser consumer online activities – Action: Get a site tag/cookie audit e.g., tagcert.com  Site privacy policy and TOU – What does it say? Revise. Comply – Action: Review and edit/re-publish  Enable consumer eprivacy choice – privacy page opt-out – preference center – opt-in/opt-out support (compliance) – Action: Build or buy (vendor evaluation)33 © 2012 Ensighten - All Rights Reserved.
    34. 34. From Across the Pond - Do Not Track34 © 2012 Ensighten - All Rights Reserved.
    35. 35. DoNotTrack – Nitty Gritty  FTC/Obama ask industry for DNT solution by 2013 – threat of legislation, avoid EU opt-in – dogs (tech) & cats (ad industry) lay together  Yahoo.com, Google.com, Twitter.com pledge support – recognize DNT on their sites by 2013  Safari, Chrome, IE, Opera will all support – Firefox – 9% web, 18% mobile DNT on  Ad industry wants: – DNT is default “off” – Expanded definition of “affiliate party” – Data still collected, but promise not to use for targeting35 © 2012 Ensighten - All Rights Reserved.
    36. 36. Ensighten Privacy Products • enterprise grade, customizable privacy gateway • supports any law, any standard, multi-lingual • $50k-$150k, Sony, Motorola, Verizon • fast, easy, free DNT support for any website • free, no limits on usage, announced 5/15 • fast, easy, free UK Cookie law compliance for any website • free, no limits on usage, announcing today36 © 2012 Ensighten - All Rights Reserved.
    37. 37. PrivacyEU – Announcing Today 1. UK websites can implement support ePrivacy Directive quickly with minimal effort 2. Single line of code on website pages 3. Unlimited site traffic volume, domains 4. Available for download 5/26/12 – www.ensighten.com/products/producteu 5. Free37 © 2012 Ensighten - All Rights Reserved.
    38. 38. PrivacyEU example – telegraph.co.uk38 © 2012 Ensighten - All Rights Reserved.
    39. 39. Install PrivacyEU on telegraph.co.uk <script src=“//privacy.ensighten.com/YourID/bootstrap.js”></script> <script src=“//privacy.ensighten.com/telegraph.co.uk/bootstrap.js”></script>39 © 2012 Ensighten - All Rights Reserved.
    40. 40. PrivacyEU – telegraph site tags listed40 © 2012 Ensighten - All Rights Reserved.
    41. 41. PrivacyEU – decide tags to always allow41 © 2012 Ensighten - All Rights Reserved.
    42. 42. PrivacyEU – First party tag42 © 2012 Ensighten - All Rights Reserved.
    43. 43. PrivacyEU – telegraph tags all set43 © 2012 Ensighten - All Rights Reserved.
    44. 44. PrivacyEU – “Try It”, test consumer view44 © 2012 Ensighten - All Rights Reserved.
    45. 45. PrivacyEU – testing consumer experience45 © 2012 Ensighten - All Rights Reserved.
    46. 46. Closing thoughts  Mobile - next great privacy frontier  Facebook – also next great privacy frontier  DNT – hot US media topic Q412  Long term – will DNT browser based privacy solution move to EU?  Next 6-18 months in UK will be an interesting time….46 © 2012 Ensighten - All Rights Reserved.
    47. 47. Thank you Des Cahill VP Marketing, Ensighten descahill@ensighten.com www.linkedin.com/in/descahill @descahill47 © 2012 Ensighten - All Rights Reserved.
    48. 48. Timeline & Summary • Ensighten Privacy enterprise solution • Available now • Direct sale – local implementation partners • Partner sale – Ensighten support • PrivacyDNT announced • May 15 Privacy Identity Innovation Summit, Seattle • Download mid-June • PrivacyEU announced • May 23 London launch event • Download on May 2648 © 2012 Ensighten - All Rights Reserved.
    49. 49. Ensighten Privacy Solutions Fast, easy deployment – Single line Ensighten Privacy tag placed on site webpages – Supports PC, phone, tablet and any recent browser Tag detection – Ensighten detects, lists and controls all tags on site – No need to add tags to Tag Management system Tag categorization – Ensighten allows site admin to categorize tags by privacy law – PrivacyChoice provides tag privacy data Tag gateway – Controls all tags, not just those in TMS – Detects any new tags added to site – Controls tag activation/blocking by site by visitor by applicable privacy law/standard49 © 2012 Ensighten - All Rights Reserved.
    50. 50. How Ensighten PrivacyEU Work for Publishers Ensighten Privacy 1 Tag placed on site. acmewidgets.co.uk <ensighten privacy tag> Site now recognizes PrivacyEU detects and UK visitors. Dialog box 2 lists all tags on site. 4 for Consent. Blocking of unallowed tags. acmewidgets.com UK Cookie Site administrator Law Consent 3 categorizes tags. Turns PrivacyEU on. YES NO Detailed privacy info on tags from PrivacyChoice50 © 2012 Ensighten - All Rights Reserved.
    51. 51. How Ensighten PrivacyEU Works for Consumers Ensighten Privacy Network acmewidgets.co.uk tags 1st Party Analytics 3rd Party < > < > < > < > < > < > < > < > < > < > < > < > < > < > < > Allowed < > < > < > < > < > Ensighten downloads list of Ensighten detects Ensighten displays dialog allowed tags based on 1 UK site visitor. 2 box for UK Cookie Law 3 consumer wishes. Page Page load begins. election from consumer. load complete. acmewidgets.co.uk acmewidgets.co.uk acmewidgets.co.uk <ensighten privacyEU tag> UK Cookie Law Consent YES NO Ensighten cookie is set to note consumer preferences for next site or sister domain visit.51 © 2012 Ensighten - All Rights Reserved.
    52. 52. Appendix52 © 2012 Ensighten - All Rights Reserved.
    53. 53. Other ePrivacy Offerings  Site Crawl & Tag Audit Report – nice to have report, but… – no actual control over tags, no compliance for site owner – Evidon, Truste and lots of small guys  Full TMS deployment required – cost & complexity of TMS deployment – not all tags go into TMS, can‟t be 80% compliant – new tags deployed on site not covered – TagMan, BrightTag53 © 2012 Ensighten - All Rights Reserved.
    54. 54. Ensighten Enterprise Grade Technology 1 Ensighten Tag - single line of javascript code <script src=“//privacy.ensighten.com/YourID/bootstrap.js”></script> 2 Cloud based TMS, privacy and mobile apps for site tag audit, monitor and control 3 Global Tag Server Network for fast tag serving and blocking by site by visitor Global multi-cloud network. Handled 46 Billion tag requests in Q1‟12 representing a 300% growth year over year. Powers $16B in ecommerce revenue across 13,0000 domains for customers like Staples, Microsoft, Sony, United Airlines, American Express, Symantec.54 © 2012 Ensighten - All Rights Reserved.
    55. 55. Ensighten Privacy functionality Ensighten Privacy monitors the performance and data collection behavior of 3rd party tags on your site vs. your policies55 | Ensighten, LLC. - Confidential, All Rights Reserved.
    56. 56. Ensighten Privacy vs other TMS  Tagman & BrightTag 1. Can control only tags in their TMS – Moving tags into TMS a complicated, long process – Typically not all site tags move into TMS – New tags added to site are not in TMS 2. TMS is enterprise purchase – Expensive – long sale cycle – long implementation cycle (pro services)56 © 2012 Ensighten - All Rights Reserved.
    57. 57. Ensighten Privacy compared to Evidon  Evidon 1. doesn‟t control tags on site. just sends opt-out request to ad network – not all tags honor opt-out requests (e.g., X+1) – consumer data has already been collected by tag vendor – no confirmation that ad network has complied 2. opt-out from tag vendor is global across sites – even when consumer turns off DNT, still opted out from ad networks 3. paid solution – wil not have broad publisher market penetration  Net: Evidon doesn‟t control tags on site, so can‟t block data collection. Relies on ad network opt-out process after consumer data collection has already occurred. Partner.57 © 2012 Ensighten - All Rights Reserved.
    58. 58. Ensighten Overview  Enterprise Tag Management solutions – for web, mobile apps, flash  Customers our products to manage 3rd party tags (ad networks, social sharing, analytics, etc.) on their websites – accelerate website page load – manage website consumer data collection – site privacy and compliance (partner with PrivacyChoice)  Founded in 2009 – Cupertino, CA; London UK – 40+ F1000 customers, 13,000 domains, $16B in e-commerce58 | Ensighten, LLC. - Confidential, All Rights Reserved.
    59. 59. Ensighten customers
    60. 60. Ensighten Products  Ensighten Manage – Tag Management for Enterprise Websites – Handles any tag, any use case – workflow, audit, rollback – javascript cms  Ensighten Mobile – extends TMS to compiled apps – iOS, Android  Ensighten Flash – extends TMS to rich media apps – Flash/Flex/Air  Ensighten Privacy – Single line of code deployment – Controls all tags on site, no TMS required60 | Ensighten, LLC. - Confidential, All Rights Reserved.
    61. 61. PrivacyDNT – easy publisher DNT compliance 1. Sites can implement Do Not Track for free, today and with minimal effort – Ensighten PrivacyDNT free solution launching 5/15 2. Sites dont need to wait for ad networks to implement Do Not Track – PrivacyDNT implements DNT compliance at site level 3. The solution works with and builds on the emerging DNT standards – PrivacyDNT web based solution, ongoing updates61 © 2012 Ensighten - All Rights Reserved.
    62. 62. How Ensighten PrivacyDNT Works for Publishers Ensighten Privacy 1 Tag placed on site. acmewidgets.com <ensighten privacy tag> Site now recognizes EnsightenDNT detects DNT headers. Blocks 2 and lists all site tags. 4 unallowed tags for DNT “on” visitors. acmewidgets.com Site administrator 3 categorizes tags. Turns PrivacyDNT on. DNT Detailed privacy info on tags from PrivacyChoice62 © 2012 Ensighten - All Rights Reserved.
    63. 63. How Ensighten Privacy DNT Works for Consumers Ensighten Privacy Network acmewidgets.com tags DNT NO DNT OK < > < > < > < > < > < > < > < > < > < > < > < > DNT OK < > “DNT” Consumer visits Ensighten sends browser Non-DNT tags (as defined 1 site. Ensighten detects. 2 list of “DNT allowed” tags 3 by acmewidgets.com) Page load starts. while page loads and cookies stopped. acmewidgets.com acmewidgets.com acmewidgets.com <ensighten privacyDNT tag> DNT DNT is ON Consumer privacy preference enforced63 © 2012 Ensighten - All Rights Reserved.
    64. 64. PrivacyEU – Flip it on….that‟s it64 © 2012 Ensighten - All Rights Reserved.
    65. 65. privacyDNT sign-up at ensighten.com65 © 2012 Ensighten - All Rights Reserved.
    66. 66. Confirmation Email66 © 2012 Ensighten - All Rights Reserved.
    67. 67. PrivacyDNT: Site Admin logs in67 © 2012 Ensighten - All Rights Reserved.
    68. 68. PrivacyDNT: detailed tag privacy info68 © 2012 Ensighten - All Rights Reserved.
    69. 69. PrivacyDNT: Site Admin re-categorizes tags69 © 2012 Ensighten - All Rights Reserved.
    70. 70. Access to PrivacyChoice Tag detail70 © 2012 Ensighten - All Rights Reserved.
    71. 71. Mockup of PrivacyEU dialog box71 © 2012 Ensighten - All Rights Reserved.
    72. 72. Panel DiscussionWhat impact will the UK Cookie Law have on digital marketing strategy?
    73. 73. Enterprise Tag Management UK Cookie Law Compliance: Implications & Answers Thank you!

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