“The Emperor has No Clothes!” — FTC blog, November 2024

Okay, that’s not exactly what they said, but it captures the essence of the Federal Trade Commission’s blog post about Data Clean Rooms last week. 

If you read the blog post, you’d probably agree they take a long time to say something very simple.  If I combine data and that data can be used to make decisions that affect an individual, how is that any better than the current state of tailored advertising and content?   And, in fact, isn’t it worse because these techniques are opaque to consumers, regulators, and advocates?  At least with the oh-so-evil cookie, you can see it being written and shared with almost no effort.

I think the FTC over-simplifies this issue because they, quite justifiably, are focused on 95% of the current DCR use cases, which involve activation (in non-ad tech lingo, “targeting based on data”).

But there’s more nuance to consider.

In lieu of ‘Data Clean Rooms’ I prefer the term ‘Secure Data Collaboration’ as it better describes these technologies’ true purpose and potential. Some legitimate privacy-preserving applications exist when proper de-identification techniques are implemented with technical and procedural safeguards preventing re-identification.

For instance, multi-touch attribution, model building, overlap measurement, and optimization analytics can be conducted while enhancing privacy through encryption, non-deterministic hashing, and differential privacy approaches.

The FTC “shot across the bow” of the industry is, if anything, overdue.  But the response is to clearly communicate the intent and consent mechanisms for the activation use cases while demonstrating how SDC techniques can improve privacy protections while providing economic support for the “open web.”

What’s the pathway forward?  I think it’s three steps:

1. Clear communication about intent and consent mechanisms for activation cases

2. Demonstration of how secure data collaboration can genuinely improve privacy protection

3. Solutions that support the open web’s economic model while respecting user privacy

What do you think about the FTC’s stance on Data Clean Rooms? Join the conversation on LinkedIn and share your thoughts by clicking here.

About the Author

Daniel Jaye

Chief Executive Officer

Dan has provided strategic, tactical and technology advisory services to a wide range of marketing technology and big data companies.  Clients have included Altiscale, ShareThis, Ghostery, OwnerIQ, Netezza, Akamai, and Tremor Media. Dan was the founder and CEO of Korrelate, a leading automotive marketing attribution company, purchased by J.D. Power in 2014.  Dan is the former president of TACODA, bought by AOL in 2007, and was the founder and CTO of Permissus, an enterprise privacy compliance technology provider.  He was the Founder and CTO of Engage and served as the acting CTO of CMGI. Prior to Engage, he was the director of High Performance Computing at Fidelity Investments and worked at Epsilon and Accenture (formerly Andersen Consulting).

Dan graduated magna cum laude with a BA in Astronomy and Astrophysics and Physics from Harvard University.

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