How Privacy By Design Will Impact the Outdoor Advertising Industry

Image by Hands off my tags! Michael Gaida from Pixabay

Like most industries these days, the advertising industry makes use of data collection and analytics. We collect information on our clients and their target demographics. And those of us that use targeted advertising as part of our business strategy (whether it is geotargeting or retargeting) often collect sensitive information regarding the people walking by our advertisements on the street. This can include information like Wi-Fi signals, smartphone IDs, and demographics to name a few. Protecting this data, making sure we are only collecting what is needed, and that it is being used for the appropriate reasons, among other concerns, are issues that all of us should be aware of.

For the last few decades, governments have been playing catch up with advancing technology. There were no laws on the books on how data should be stored, what kind of personal data could be tracked, or sold. Recently, both the European Union and the state of California have enacted privacy protection laws to ensure that individual’s right to be forgotten is protected. Laws that protect an individual’s right to find out how companies are collecting the data, and what it is being used for, and the ability to opt out of data collection. With more regulations likely on the horizon, outdoor advertisers would benefit from taking a proactive approach to these challenges.

Since 2011, new guidelines with more specific information as to how privacy protocols can/should be implemented have continued to come out. From the NIST Privacy Framework to ISO 27701, some are nation-specific, while others can be adapted to help organizations comply with privacy regulations such as the European Union’s General Data Protection Regulation (GDPR) or the UK’s Data Privacy Act. The penalty for violating the GRPR, for example, is a fine of up to 4% total global turnover of the preceding fiscal year or 20 million euros. Other penalties may also apply.

While outdoor advertising may not seem to carry such as sensitive data as, say, social media sites, banking sites or apps, or other more highly personal sectors, there is a responsibility to ensure what data we do collect, and use is protected and used ethically. To understand this issue and how it impacts our industry, let us start by looking at what is privacy by design, what it’s meant to do, and what steps outdoor advertisers can take.

Image by Gerd Altmann from Pixabay

Designed With The Best Intentions

Privacy by design, as a concept, was first floated around in 1995 by Dr. Anna Cavoukian. Hailed as “preventative approach to data privacy protection”, its purpose was to creates a model for data privacy that went beyond privacy enhancing technologies and regulatory compliance to create a holistic approach to data privacy that guarantees an individual’s full data privacy. In 2009, this concept was released to the public at large in a formal document, the core of which were seven principles that were to be adopted. These principles were not a framework per se but a holistic approach that companies could embrace to form their own individual policies and guidelines and using them as a basis for building your privacy policies can benefit any outdoor advertiser.

These principles are:

Proactivity not reactivity- The journey of a thousand miles begins with a single step. Similarly, when approaching privacy by design, it is important to incorporate privacy protections at the beginning. When developing new data collection technology, designing behavioral algorithms, or drafting a privacy policy, outdoor advertisers can start by anticipating potential risks and taking steps to ensure that privacy breaches are not able to occur. This can include adopting data storage practices that keep sensitive client data off of the cloud, restricting access to this data, and regularly reviewing and updating privacy practices.
Privacy as a default- Privacy should be a pillar of business operations. Instead of additional steps, or overly complicated processes, making privacy the starting point makes data breaches less likely to happen, and encourages a proactive mindset.
Embed privacy in design- For privacy to be the default, it cannot be an “add on.” IT systems, and business practices must include privacy as an “essential component of the core functionality.” If your business model incorporates collecting device identifiers or demographic data so target audiences can be retargeted after viewing a mobile truck ad, a good first step is only collecting information that is necessary or aggregating the data in a way that does not violate an individual’s privacy.
Uncompromised functionality- Privacy does not have to be a zero-sum game. We can recognize that privacy vs. security, or for outdoor advertisers, audience reach vs. privacy are false dichotomies. It does not have to be either/or. There is a balance that can be reached where both individual rights and business interests can benefit.
End-to-end lifecycle security- from the day systems or practices are designed, through to data collection and then disposal, Privacy By Design recognizes the need for strong security measures. Data must be stored securely and by the end, disposed of in a timely manner. In the outdoor advertising industry, this might mean storing campaign related data for a set period of time, and then destroying it when the campaign ends.
Transparency and Visibility- For outdoor advertisers, this means being open about how we collect data and why. That we explain our practices and are clear on the technology used. Privacy policies must be written in clear, plain language that is easy to understand. This goes for our customers and private individuals alike. All stakeholders must feel reassured in our privacy practices.
Respect for User Privacy- For outdoor advertising, our users are our clients, and for those of use who engage in targeted advertising, we have the public. The “rights and best interests” of our clients and those whose data we collect in campaigns should be prioritized. It means regularly evaluating what data we collect, and why, as well as what risks may come of it.

The OOH industry is one of the oldest in the advertising world. We have gone through many changes throughout the years and will continue to go strong as long as we keep doing what we do best—growing. Through wars, pandemics, economic downturns, and regulatory challenges, we have adapted and thrived. Privacy By Design is one of the newest challenges that we face as an industry but whether it’s DOOH, mobile truck advertising, or billboard advertising, by taking the appropriate steps and building our privacy infrastructure the best we can, our ability to be ethical and responsive business partners will only increase over time.

Image by Gerd Altmann from Pixabay