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Developing Mobile Trust In Today's E-Privacy Landscape
1.
DEVELOPING MOBILE TRUST IN
TODAY'S E-PRIVACY LANDSCAPE November 19th 2015 PRESENTERS: Todd Ruback Esq., CIPP-US/E, CIPT Chief Privacy Officer & V.P. Legal Affairs Jon Sheppard Director of Product Management, Privacy
2.
2 Agenda • Introductions • Update
on Privacy Legal and Regulatory Landscape • ePrivacy Directive • Getting in Compliance & The Ghostery App Notice Solution • Q&A Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
3.
3 Introductions Private & Confidential
| © 2015 Ghostery, Inc. All Rights Reserved Jon Sheppard Director of Product Management, Privacy Todd Ruback Chief Privacy Officer & VP of Legal Affairs
4.
AT&T June 2015 Update on
Privacy Legal and Regulatory Landscape Todd Ruback Esq., CIPP-US/E, CIPT Chief Privacy Officer & V.P. Legal Affairs
5.
5 US Self-Regulatory Program
for Online Behavioral Advertising (OBA) • Mobile enforcement began September 1, 2015 – Accountability agents are actively monitoring and expect robust enforcement • Extends DAA’s Principles to mobile websites and apps • Let’s Break It Down: Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved Ads If based upon OBA data, then deploy AdChoices Icon, when opened goes to DAA’s AppChoices, the industry opt-out solution, listing third parties in ad with consumer choice Apps Shared obligation with third parties to provide notice of OBA activity and give control to consumer
6.
6 Canada & EU
Self-Regulatory Programs Canada DAAC; enforcement spike by ASC in recent months • Added complexity of national privacy law, PIPEDA, that also applies to OBA • OPC Report – encouraged that Canada websites deploy AdChoices notice, but expect more. • ASC fully supports PIPEDA; no daylight between the two. EU EDAA; Will soon announce mobile enforcement date Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
7.
7 What do the
Self-Regulatory Programs Apply to? Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved • 3 different types of data that might be collected: • Cross App Data (CAD) – OK, unless user opts-out • Precision Location Data (PLD) – need affirmative consent • Personal Directory Data (PDD)- need affirmative consent • Control: • Settings upon download • Ghostery’s App Notice • DAA’s AppChoices
8.
8 US State Specific
Transparency Laws States currently affected: • California (CalOPPA) • Delaware (DelOPPA) • New York proposed legislation Legislation Overview Requires websites, and Apps, to have comprehensive understanding of invisible digital activity and disclose it. Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
9.
9 EU – Safe
Harbor / Cross Border Data Transfers • ECJ invalidated US Safe Harbor Program • Sky is not falling, although over 4,000 US companies rely on this legal mechanism to transfer EU personal data to the US • Chances of Safe Harbor 2.0 – 50/50 • Not clear what it may look like but third party Seal Program is at risk, and we can expect robust monitoring and enforcement. • WP29 has given companies until Jan 31, 2016 to put Plan B in place • Many recommend Standard Contractual Clauses as short term solution Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
10.
10 EU – General
Data Protection Regulation Last mile of negotiations • Will have new rights for individuals and obligations by companies • Will require companies to have demonstrable knowledge of digital activity –annual audits of sites and apps Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
11.
11 EU ePrivacy Directive
– No Longer Just the Cookie Law • Applies to websites (and Apps and connected devices) • Often confused with Self-Regulatory Programs for OBA • Will be reviewed in 2016 after GDPR is completed • Requirements – Notice & Consent • Enforcement – regulators have been signaled it applies equally to Apps and IoT but have waited for market solution • Priority – for children’s Apps; sweeps have already happened • Solution – Ghostery’s App Notice Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved
12.
AT&T June 2015 Getting in
Compliance & The Ghostery App Notice Solution Jon Sheppard, Director of Product Management, Privacy
13.
13 Why is there
a need for a different solution for Mobile Apps? Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved • Unlike the web: • Mobile Apps are installed and run locally on the users device. • Changes to Apps can only be made by updating the Apps code and releasing a new version to the App Store. • Apps aren’t cookie based. • Like the web: • Mobile Apps contain trackers reporting, OBA, CAD, PLD and PDD • The list of available App trackers is growing quickly.
14.
14 Steps to Get
into Compliance Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved 1. Identify your companies mobile apps 2. Work with your mobile developer to identify the ad tech used by your apps, and data it collects 3. Implement Ghostery App Notice UPDATE • We can help you here if you’re lost!
15.
AT&T June 2015App Notice
Demo
16.
16 The Ghostery App
Notice Solution Overview Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved • Worked closely with privacy leaders to design and build. • Provided by a Software Development Kit (SDK) • Available in 2 versions depending on your App type: • Android 4.1 and up • iOS 7 and up • Both Explicit and Implied notice formats supported • Over 50 notice customizable options available to match your apps requirements, including notice color and text and size etc.
17.
17 What is an
SDK? Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved • A mobile Software Development Kit (SDK) is a packet of code that allows developers to easily add new functionality to their apps. • SDK’s are often used as shortcuts so that developers don’t have to write everything from scratch • SDK’s frequently include sample code and supporting technical notes or documentation Lorem ipsum dolor sit amet, consectetur adipiscing elit. Fusce hendrerit pellentesque tellus ut lacinia. Curabitur sed consectetur lorem, eu tincidunt urna. Ut lacinia ultrices porttitor. Phasellus vehicula blandit accumsan. Pellentesque
18.
18 Installing your SDK Private
& Confidential | © 2015 Ghostery, Inc. All Rights Reserved 1. App Developers passed the SDK code via Github GITHUB 2. SDK is installed in App by Developer: • Installation & Companion Guides are provided as well as sample code. YOUR APP 3. Customize the color and text of your Notice in your Site Notice Account. 4. Submit your updated App to the store for your users to download. UPDATE
19.
19 Ghostery is the
Privacy Compliance Leader Private & Confidential | © 2015 Ghostery, Inc. All Rights Reserved • Ghostery globally is the Ad Choices Program leader • Dominant market share: Preferred Partner of every major Ad Agency Holding • Integrated with all key buy and sell-side platforms • Close relationships with the entire privacy ecosystem • Technology vendor to DAA SOME OF OUR INTERGRATION PARTNERS • Over 290+ clients across desktop, mobile and video • Over 3 billion AdChoices icons served daily • Over 100 million site consent notices served daily • 40 languages supported GHOSTERY BY THE NUMBERS
20.
20 Thank you Private &
Confidential | © 2015 Ghostery, Inc. All Rights Reserved Jon Sheppard Director of Product Management, Privacy Todd Ruback Chief Privacy Officer & VP of Legal Affairs Todd@Ghostery.com JSheppard@Ghostery.com EU SALES +44 020 7031 8232 NORTH AMERICA SALES 917-791-5550 Sales@Ghostery.com EUSales@Ghostery.com
21.
AT&T June 2015 Q&A
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