Project:Adtech
Reactions to other talks
Observation on OpenWPM
OpenWPM has split up into a testbed for mass crawling, and a web extension which is separate (currently used in a second project, for mass reporting to Mozilla).
Interesting queries
- What is the impact of a Q839 on a data management platform (Q495)(all)?
- Is this helpful for understanding cross-device tracking (Q519)? probabilistic fingerprinting (Q520)?
- More specifically a SAR on an identity resolution service (Q559)(all)? Is it different than for a data broker (Q522)(all)?
- What is the legal situation of Adobe Marketing co-op (Q399), successor to Demdex (Q398)?
- What traces are left by real-time bidding (Q523)? Which are accessible through Q839?
- Which adtech company (Q110)(all) or adtech product (Q834)(all) set the marketing segment (Q838)(all)?
- When are they shared?
- Is deciding the marketing segment (Q838) enough to make an entity a data controller (Q96)(all)? What about if you decide how they can be shared?
- Turn Inc (Q546) for instance facilitated the selling of an audience (Q496) by Weather Channel (Q840) of people more "likely to be constipated". This was determined (?) through the use of geolocation data (Q539).
- An example request, generated directly from Guardian adtech investigation (Q855).
Tag management
- What is the impact of an indirect SAR on a tag manager (Q504)(all)
- Can a SAR tell you for whom an advertising tag (Q503)(all) fired?
- Is the legal situation different for a SAR on Google Tag Manager (Q70)?
Bidding process
- What is the impact of a(n indirect) SAR on a ad exchange (Q498)(all)?
- Can you know whether ad impression (Q497)(all) was triggered?
- What was the value of the transaction?
Top-down, bottom-up, maximizing utility
The goal of SARs could be to maximize utility in understanding the ecosystem.
Hence the goal of litigation should be around expanding the reach of SARs, in order to "flatten" the ecosystem.
This has two advantages: better competition, more transparency.
In particular, for every role, there is a possibility of picking a small player with this role, a huge one, or one with dual roles. Each of those situations will lead to different outcomes for the SAR, all valuable.
Scaling effects
Indirect SARs sound complicated and unhelpful. I am not sure: you get a lot of allies in putting pressure on the service providers, who sometimes masquerade as GDPR data processor (Q841). The costs and effects have a completely different scaling factor, and also an impact on the choice of jurisdiction.
- All boils down to: what is provided by the data subject?
- Why do this? Because then we can transfer more easily to researchers to understand better the ecosystem.
GDPR Article 26 (Q842) gives the right to information about the "essence of the contract" in joint-controller situations. What does this cover?
- Can we learn more about anonymization (Q848) or pseudonymization (Q847) through this?
- Can we know how unique identifier (Q127) hashing (Q849) is done? Is a hashing salt (Q850) used? This has direct impact on identifiability (to whom?)
- Can we learn more about the structure of each agreement involved in real-time bidding (Q523)?
Adtech experiments
- data rights service (Q188) helps get feedback quicker
- IAB Consent Framework (Q858) defines a IAB vendors list (Q94)
- There are problems with the "purposes" defined in the consent framework.
- Through cookie manipulations you can consent very flexibly. A/B test on the entire IAB, agree to A on odd day, B on even day.
Facebook's Replacement IDs
Consents
Consents are interesting data points, that should be within the scope of Access and (it seems) Portability.
Privacy Shield
Tremendous tool for choosing jurisdiction, at no cost.
Involves Europeans, but also Americans, whose data goes abroad. Drives a wedge between Facebook Ireland and Facebook Inc, etc.
Links to competition
Privacy is a dead-end for enforcement. It will always boil down to consent and design, and always be abused in unaccountable ways, in order to get the first users. And then it will expand progressively to everyone (cf. Facebook's experiments to get my consent in order to use facial recognition).
On the other hand, tracing data flows -- which is possible thanks to data protection law -- helps define exactly the assets that are being shared. It's not just about raw (personal) data, it's also about the consents associated to this data, as well as its identifiability. Once all this is taken into account, we will have a better understanding of the personal data market, and will be better able to assess dominance of some players over that market. This might open the door to a more reasoned antitrust action.
Relevant items
- advertising technology (Q107)
- adtech company (Q110)
- adtech ecosystem buy side (Q517)
- adtech ecosystem sell side (Q518)
- adtech ecosystem (Q370)
- adtech company (Q110)
- data management platform (Q495)
- identity resolution service (Q559)