Online Behavioural Advertising The UK experience

Transcription

1 Online Behavioural Advertising The UK experience

2 Contents 01 Set up of dedicated Working Group 02 Extension of SRO remit 03 Compliance and enforcement 04 Resourcing and training

3 Working Groups- getting the industry green light Working group assembled by the UK Advertising Association comprising of the whole OBA value chain: (a) the SRO (b) advertisers (c) agencies (d) media owners (e) ad networks/exchanges and relevant third parties (f) relevant trade bodies

4 Working Groups- getting the industry green light Clear messaging: Aim to deliver a self-regulatory solution which maintains consumer and civil society trust and confidence by providing transparency and choice over the collection and use of information to deliver OBA by third parties

5 Working Groups The group discussed: The role of the ASA in dealing with OBA-related complaints The rules which should be incorporated into the advertising Code How rules were likely to be interpreted If ad networks needed additional guidance Relevant sanctions available for the ASA (and industry) to use How complaints and sanctions procedures can be adopted into the way the ASA operates

6 Working Groups Key challenge: How will the system fit with existing SRO structures? mandatory vs membership based SROs We have had to make some adjustment to the wording of rules whilst trying to maintain as much of the original intent of the BPR as possible

7 Extending remit Once we had the green light from the industry to incorporate OBA into our Code we asked our industry committee (the body which writes the UK Advertising Code) for their approval. The ASA Council will consider the proposal on the 9 th November which is the final step in the process. We aim to make an announcement by the end of November and start to regulate OBA in February 2013.

8 Extending remit in practice Think about the practical implementation. We have: Thought about the types of complaints we are likely to receive Looked at the way the US deal with complainants, what type of information they provide and letters do they send to complainants. Incorporated the EASA complaints handling principles into our own internal procedures Considered how our computer systems, complaint forms may need to operate Incorporated the EASA Sanctions flow chart into our Compliance processes

9 Extending remit in practice Types of complaint: I want to opt-out of all advertising The opt-out provided did not work I saw an OBA ad but it did not have an icon or other notice around it I keep receiving retargeted ads I/my child keeps seeing ads which I think are targeted at children under 12

10 Extending remit in practice We will: Put a Q&A on our website answering key questions about how OBA works and what the rules can deliver Work to educate consumers through the information we provide Produce a guidance note for third parties on the new rules Offer Copy Advice to third parties as and when they require it

11 Extending remit in practice Training for ASA staff: Given an initial basic training session on what OBA is to all staff. Plan to give a detailed overview of our complaints process nearer towards the implementation date Have had presentations from ad networks in the past 18 months

12 Compliance and Enforcement Making the EASA Sanctions flowchart work in practice: - Publish our rulings on the ASA website. These often get picked up by the press - Use the ad alert system for OBA to have the greatest effect - We are considering how we can persuade third parties to become compliant after investigations - Consider how and when the removal of the icon and seal might work - How we communicate these sanctions to demonstrate our effectiveness

13 Compliance and Enforcement Consider how information from certified providers can be used to ensure compliance across the OBA market, including nonsignatories. Consider how the work of our compliance team can bolster overall confidence in the system.

14 Resources and training Factors we considered when calculating our estimated costs: IAB UK experience with youronlinechoices.uk and the typical complaints and consumer feedback they receive Data from the US (BBB and NAI) Information from the BBB and NAI on how their compliance function works and interacts with certified providers The impact of country of origin (we re likely to have a number of large OBA providers in our jurisdiction) Existing resources and budget

15 Resources and training We anticipate our costs for year 1, subject to agreement and consideration of the function of certified providers, to be 51,000. This includes the cost of one extra member of staff to deal with complaints; Costs for alterations to our websites and other systems and materials Excludes OBA s share of overheads. Out of a total budget of 8 million- we think we re able to deliver this extension of remit at a very low cost.

16 Thank you Hayley Fletcher Code Policy Executive Advertising Standards Authority Mid City Place, 71 High Holborn London WC1V 6QT Telephone Direct line