PageFair writes to all EU Member States about the ePrivacy Regulation

Dr Johnny Ryan GDPR

This week PageFair wrote to the permanent representatives of all Member States of the European Union in support for the proposed ePrivacy Regulation. Our remarks were tightly bounded by our expertise in online advertising technology. We do not have an opinion on how the proposed Regulation will impact other areas. The letter addresses four issues: PageFair supports the ePrivacy Regulation as a positive contribution to online advertising, provided a minor amendment is made to paragraph 1 of Article 8. We propose an amendment to Article 8 to allow privacy-by-design advertising. This is because the current drafting of Article 8 will prevent websites from displaying privacy-by-design advertising. We particularly support the Parliament’s 96th and 99th amendments. These are essential to enable standard Internet Protocol connections to be made in many useful contexts that do not impact of privacy.…

GDPR’s non-tracking cookie banners

Dr Johnny Ryan GDPR

This note outlines how an anomaly in European law will impact cookie storage and presents wireframes of permission requests for non-tracking cookies.  Online media will soon find itself in an anomalous position. It will be necessary to apply the GDPR’s consent requirements to cookies that reveal no personal data, even though the GDPR was not intended to be applied in this way.[1] Recital 26 of the GDPR says that “the principles of data protection should … not apply to anonymous information, namely information which does not relate to an identified or identifiable natural person…”.[2] Even so, a hiccup in the choreography of European Law making is creating an unexpected situation in which the GDPR’s conditions will apply to cookies that reveal or contain no personal data.…

How to audit your adtech vendors’ GDPR readiness (and a call to adtech vendors to get whitelisted as Trusted Partners)

Dr Johnny Ryan GDPR

This note describes how publishers can audit their adtech vendors’ readiness for the GDPR, and opens with a call for adtech vendors to collaborate with PageFair so that they can be whitelisted as Trusted Partners by PageFair Perimeter.  How adtech and media will work under the GDPR We anticipate that the GDPR will indeed be enforced, whether by national regulators or by NGOs or individuals in the courts. We also realise that consent is the only applicable legal basis for online behavioural advertising (See analysis). Personal data can not be processed for OBA in the absence of consent. However, consent dialogues for adtech need a “next” button -or a very long scroll bar- because online behavioural advertising requires many different opt-ins to accommodate many distinct personal data processing purposes.  …

Supporting new European data regulation

Dr Johnny Ryan GDPR

Unusually for an ad-tech company, PageFair supports the proposed ePrivacy Regulation. Here is why.
Additional note (11 May 2017): our position concerns the proposal’s impact on online behavioural advertising (OBA). Though there are kinks to work out, as we note in our recent statement to Parliament representatives, we strongly endorse the proposal’s broad approach to OBA.  The European Commission has proposed new rules for ePrivacy, which will supplement the GDPR.[1] Unlike colleagues in other digital advertising companies, PageFair commends the proposed privacy protections for online advertising.
Access the GDPR/ePR repositoryA repository of GDPR and ePrivacy Regulation explainers, official docs, and current status.Access Now PageFair has taken this position for two reasons. First, personal data are not required for online advertising.  The online advertising system can deliver relevant ads without the need to use personal data, or third party cookies that collect personal data.…