14 Macklin Street 020 7050 6969 London WC2B 5NF IAB Affiliate Marketing Council Consumer Transparency Framework: A Guide for Publishers / Affiliates ePrivacy guidance across the affiliate marketing industry V 1.2 | May 2013 | Produced by the IAB Affiliate Marketing Council Produced by the IAB Affiliate Marketing Council
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IAB Affiliate Marketing Council Consumer … Affiliate Marketing Council | Consumer Transparency Framework V1.2 page 2 A Guide for Publishers / Affiliates | May 2013 Introduction The
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14 Macklin Street
020 7050 6969 London WC2B 5NF
IAB Affiliate Marketing Council Consumer Transparency Framework: A Guide for Publishers / Affiliates
ePrivacy guidance across the affiliate marketing industry
V 1.2 | May 2013 | Produced by the IAB Affiliate Marketing Council
For further Information about cookies you can also visit www.
aboutcookies.org
Controlling Cookies
Describe how you can you can prevent, delete and control cookies on your
computer by using the relevant settings within your browser options etc.
Explain how this may affect the overall experience with the website.
What are our responsibilities?
Describe the need to provide transparency to consumers and sign-post to the
revised law.
What is our policy as a business?
Explain to consumers what your approach is to providing transparency and
protecting privacy.
How do we use cookies on our website?
Describe first and third party cookie usage within your advertising, analytics
activities etc.
Describe the affiliate marketing model briefly, being clear about advertising and
sales revenues. It is important to keep this information easy-to-understand for
the average internet user.
Information about the cookies used
There are many examples available on the internet to provide assistance on
how this can best be formatted. You might use a simple table providing clear
information. Something like:
Cookie Name Purpose, characteristics and privacy
How to delete and prevent
XYZ-adv This is a first party cookie which is used to ensure that we are able to provide users with / track advertising etc… The information stored does not include any personal data. It includes anonymous identifiers.
Describe how the cookie can be deleted, blocked and provide any opt out functionality (e.g. links)
1. Conduct a comprehensive audit of cookies (and other technologies) and how they are used. How this is carried out depends on your organisation. The aim is to establish a
clear assessment of where you may have issues. We have highlighted a set of
useful questions for audit – see below.
While many of the cookies are linked to the advertising displayed on your site, they
will NOT be in your control. These are controlled by the ad servers like Microsoft /
Atlas, Goolge / Doubleclick, Valueclick / Mediaplex, etc. It‟s strongly advised you
understand how these work so they can be incorporated into your audit. The
networks and agencies you work with will be able to direct you to relevant
information regarding these third-party providers.
2. Assess intrusiveness As part of the audit, the ICO advices businesses to make an assessment on how intrusive cookie (or other technology) use is. The ICO recognises that many cookie uses – such as for functional or analytical purposes - do not have an impact upon user privacy.
3. Where you need consent Decide what solution to obtain consent will be best in your circumstances. The
ICO has stated that “implied consent” is a valid form of consent. Regarding
assessing privacy intrusiveness the ICO has said:
“It might be useful to think of this in terms of a sliding scale, with privacy neutral
cookies at one end of the scale and more intrusive uses of the technology at the
other. You can then focus your efforts on achieving compliance appropriately
providing more information and offering more detailed choices at the intrusive end
DCMS open letter www.dcms.gov.uk/images/publications/cookies_open_letter.pdf Emphasising the pragmatic, flexible and business friendly approach supported by
Affirming the need to take measures to achieve compliance but also recognising the complexities involved especially with third-party cookies.
ICO Half Term Report , December 2011 http://www.ico.gov.uk/news/latest_news/2011/~/media/documents/library/Privacy_and_electronic/Practical_application/guidance_on_the_new_cookies_regulations.ashx
Indications are provided regarding the regulator‟s attitude towards enforcement
(“…the Regulatory Action Strategy makes clear that any formal action must be a
proportionate response to the issue it seeks to address”). Whilst enforcement is
not precluded, the level of intrusiveness and risk of harm to individuals appears
likely to be a relevant factor. Likewise, the measures taken to inform users
regarding the use of cookies and their associated choices also appears to be an
important factor in determining whether compliance has been adequately
addressed.
ICO blog: Updated Advice and guidance on changes to the EU Cookie Law (May 2012) http://www.ico.org.uk/news/blog/2012/updated-ico-advice-guidance-e-privacy-directive-eu-cookie-law.aspx
A video and blog within information on “implied consent” and answering questions including:
1. How can UK organisations comply with the new cookies changes? 2. Is the ICO concerned that many websites aren‟t yet compliant? 3. What approach will the ICO be adopting to enforcing the amended cookies laws? 4. What are the benefits of complying with the new cookies regulations? 5. What should members of the public do if they are concerned about cookies being placed
on their device? 6. How is the ICO working with web browsers and third party advertisers to ensure they