Big Data - Ethical Data Use Kimberlin Cranford

Ethical Use in the Era of Big Data  Landscape has Changed  Attitudes about Big Data  PII, Anonymous, De-identified  Sensitive Data Evolving  Governance of Big Data  Privacy by Design (Privacy Engineering)

Attitudes About Big Data Examples of Big Data individuals can understand… Search is Big Data for consumers. Digital Advertising is Big Data for consumers.

Big Data Benefits Corporate uses Fulfill a transaction Improve operational efficiency Develop new products/services Market and advertise products/services Satisfy a legal obligation Societal uses Research Free Speech

Risks of Big Data Traditional Harms Financial Physical New Harms Emotional Intrusion Reputation

Big Data Types Device Identifiable Information Anonymous Choice X De-Identified Information X Personally Identifiable Information Aggregate Information Pseudo - anonymous / / Personal Pseudo- anonymous PIIDII AGI De-ID SANI ANI PIISANI Covered Information Ease of Technical Re-identification 100% 0%

Sensitive Data Evolving Historically Sensitive Commercial Data  Identification  Financial  Medical  Children New Categories of Sensitive Commercial Data  Precise geo-location  At-risk populations (children & elderly)  Teens - raise the age for COPPA from under 13 to 18  Elderly over 60  Social network information (public & non-public)  Biometrics & Facial recognition  Modeled Data Finances Identification Medical Social Networks Biometrics At Risk Populations Facial Recognition Location

Governance for Big Data Federal Laws and Regulations General (FTC Title V) Sector Specific (GLBA, FCRA, HIPAA) Use Specific (CAN SPAM, TCPA, DNC) Data Specific (DPPA, COPPA, CPNI) State Laws and Regulations Consumer Protection Laws Do-Not-Call Laws Data Breach and Security Laws Website Disclosure Laws

Industry Groups and Self-Regulatory Groups w/ Codes of Conduct  International Association of Privacy Professionals (IAPP — a worldwide organization)  Direct Marketing Association  Digital Advertising Alliance  Interactive Advertising Bureau  Network Advertisers Initiative  Sender and Provider Coalition  Coalition for Sensible Public Record Access  Policy and Economic Research Council  National Business Coalition for Ecommerce & Privacy  US Chamber of Commerce  State Chambers of Commerce  Conference of Western Attorneys General  Mobile Marketing Association  Information Accountability Foundation

Privacy By Design / Privacy Engineering  Should be part of organizational strategy  Privacy and data protection: should be embedded throughout the enterprise and the life cycle of products and services  Google’s Red Team  Yahoo’s Paranoid Team  Apple’s App Review Team  MIT program, Harvard program  (computer) Code is Conduct “All of Acxiom’s products and services have been created based upon these key principles.”

Information Governance = Accountability & Measurement  Line of business accountability  Leadership required to be accountable for the operational compliance of their products, solutions, services  Client Credentialing: Legitimate entity, legitimate use  on-site inspection possible  Vendor Screening and Accountability Program  You are your vendor’s keeper  Privacy by Design/Privacy Impact Assessment  Understanding and applying the rules to business processes is complex – yet critical  Computer Code is the Conduct  Individual employee accountability & training  Achieve excellence - each employee accountable for applying rules, issue spot, report problems  Assurance Reviews  Internal audits on data products  Functional Area/Line of Business Audits 11

 First ever Consumer Access Portal – launched 9/4/13  Clear and public articulation of Acxiom’s ethical data use position  Internationalization: country by country approach to globalize ATD  In the works:  Adding more core data to the portal  Increase value for those participating AboutTheData

Launched 9/4/13  # of visitors: 630K  % returning users: 17%  % opt out: 2%  % creating accounts: 37%  % editing:11%

Big Data and Ethical Promise Media Policy Makers/ Regulators Consumers TRUST Expertise and Leadership Compliance and Leadership Hyper-Transparency Clients

Thank you!