The moving target of permissible PII

New rules for collecting and using personally identifiable information are emerging, shifting the balance in favor of the consumer.



Online advertising is becoming more personalized. Audience-specific ad experiences are driven by data, supplied both knowingly and gleaned from our online activity. All this serves as the fountainhead turning customer insights into personalized marketing, telling marketers: 



  • What to advertise to us and when.
  • And even what language and imagery are used based on deep insights from past purchase data, website and app visitation, time-on-site, and even our personality types. 

Often, all this hyper-focused personalization requires the use of personally identifiable information (PII). 


What constitutes personally identifiable information (PII)?


If you’re unfamiliar with what constitutes PII, it can be broken down into two categories. 


The first is usually referred to as “linked information,” which is any information that can be used to identify a person or household. Examples of this type of data are rather obvious, including:



  • Full name.
  • Address.
  • Email.
  • Phone number.
  • Login details. 

Another kind of data is “linkage data” which, when used alone, cannot be used to identify a person. However, when multiple types of linkage data are stitched together, they can be used to glean some PII. Some examples of this data could be first or last name combined with the resting location of your mobile device that can be geo-framed back to a terrestrial address. 


It’s important to note that some linkage data is not considered PII as the identifiers captured cannot be used to identify an individual or customer. This non-PII data includes signals like cookies and device IDs that can be used to create anonymized audiences that, while still targeted, cannot be matched back to any individual or household. 


The gray area


Marketers frequently build propensity models and audiences using anonymized data to serve ads for boosting engagement and driving more conversions. 


Most marketers and big adtech platforms are familiar with anonymized data, including cookies and device IDs, which have been reasonably easy to collect when someone visits websites or downloads an app on their mobile device. 


An ever-changing gray area has emerged between:



  • What constitutes anonymous data.
  • What data can be combined to derive some form of PII.
  • And how much of that data is permissible for advertising. 

The new rules for PII data collection and usage



The new rules for collecting and using PII data hinge on the notion that peoples’ data belongs to them, not big tech. Of these new rules, the first and quite obviously the most important is around consent. Consumers now have to agree to the collection and use of their information


While these guidelines are clearing out the bad players, it’s also creating an opening for marketers who get consent more power based on a newly fostered trust. 


Adapt to privacy changes through identity resolution


Beyond collection, there is a shift in handling and sharing PII data. The result is vendors now providing clean rooms, consent management platforms and safe havens. 


In the past, audiences were built, and programmatic engines served ads in near real-time. While this still happens, these new players act as gatekeepers, cleansing data and ensuring campaigns only use data in the way consumers have consented to.


Along with this is a nascent new identity ecosystem waiting to emerge if and when we get more iOS restrictions and Google deprecates third-party cookies in Chrome. These changes will add another layer of complexity to an already moving target around the permissible use of data for advertising. 


The new era of data usage is here


While there is plenty of speculation on how much PII data will be permissible for advertising in the U.S., we can be sure that the free-wheeling days of data collection and brokerage are ending. 


This new data usage era will be anchored in consumer consent and ultimately be decided in a consumer’s ability to trust brands they engage with to make purchases, stream content or socialize online. 


This forecast bodes well for marketers and platforms who have invested heavily in their brands, building and fostering trust with their customers. 


Trust, combined with a material value exchange for access to our data, will be the two main driving forces in the next generation of digital advertising.


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About The Author






Ken Zachmann




A leader in the data-driven AdTech space that spans 20 years across both the US and the EU. Ken Zachmann’s worked on the ground floor of a data start-up that yielded an eight-figure exit and served as VP and SVP for two leading digital data firms and saw them through to acquisition in 2017. In 2018 Ken launched his first consulting firm focused on identity-based solutions and helping companies navigate a cookie-less future. Ken’s background in data and identity resolution, paired with his experience of living and working in both the US and Germany, has afforded him a unique understanding of the complexities of sourcing and building data, identity and measurement solutions.

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