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“Data is a precious thing that will last longer than the systems themselves.”
Australian businesses seeking to curate an audience for digital ads have long understood the importance of customer intelligence. The data they use to identify targets must be accurate and relevant; otherwise, the entire endeavor is doomed to fail.
This is as true today as ever, but lately another marker of data quality has become a commensurate priority: the state of its privacy hygiene.
Data Providers and Refining of Data
Typically, targeted ad campaigns rely on data gathered, cleaned, refined, and made available by companies like Azira. Originally sourced from consumer devices, the data may include, for example, a smartphone’s precise geolocation from time-to-time, which serves as a proxy for the owner’s location.
If permitted by the phone owner, the app that collected the data may provide it to a data aggregator. The aggregator, in turn, will group it with similar data gleaned from other apps, and sell the resulting sets of raw location data to a data intelligence provider like Azira.
Responsible data intelligence providers take steps to ensure the good state of privacy hygiene required by law, including by confirming that:
- Consumers consented to the use of their personal
- The data was only used as permitted by the consumer
- Consumers are and have been afforded their privacy rights throughout
Generally, data providers draw inferences from the data to create consumer profiles, which can be tailored to suit an advertiser’s needs. For instance, if a consumer accesses the internet from within an airport, the provider might tag them as a “traveller.”
Furthermore, providers combine the attributes they infer about individuals to create “enriched” profiles, e.g. a luxury traveller versus an adventure traveler.
To serve the needs of advertisers, while also respecting the privacy of consumers, responsible data providers routinely scrub consumer profiles of data that directly identifies the individual. For example, a provider may encrypt a smartphone’s unique advertising identification code (known as a MAID) before passing it along to a client. In this way, the client receives the info it needs for targeting and attribution, without data points that might readily expose the owner.
Privacy Law in Australia
Australia’s Federal Privacy Act of 1988 (the “Privacy Act”) is one of the oldest around. Over the years, several Australian states and territories have developed their own, additional locally-applicable privacy laws.
The Privacy Act serves as the foundation for data collection and management policies, establishing standards for safeguarding personal data, promoting transparency, and ensuring accountability. Nevertheless, it is broadly considered inadequate to effectively manage today’s complexities, notwithstanding amendments made in 2022.
Let’s take a look at some of the proposed reforms to Australia’s privacy laws which could have an impact on data providers:
- Expanded Definition of Personal Information: data that relates to individuals is to be included; currently, only information that directly identifies a user is in scope.
- Stronger Notice and Consent Requirements: Consent must be voluntary, informed, specific, and easily withdrawn.
- Right to Erasure: a.k.a., the right to be forgotten, is to be made available under certain circumstances.
- Mandatory Privacy Impact Assessments: to be required for activities considered high-risk.
- Stricter Direct Marketing Regulations: rights to opt-out of certain direct marketing practices will be implemented.
- Enhanced Regulatory Powers: to be conferred on the Office of the Australian Information Commissioner (OAIC).
- New Statutory Tort for Privacy Invasions: serious invasions of privacy may give rise to claims of damages by consumers.
Common Challenges Faced by Data Providers
- Navigation through complex laws.
Regulations can vary widely across jurisdictions. The diversity complicates compliance strategies.
Azira’s market ranges across the US, EU and APAC (including Australia). From its inception in 2024, Azira has prioritized compliance with privacy laws by implementing multiple initiatives, including becoming a member of Interactive Advertising Bureau and the Network Advertising Initiative. Beyond simply meeting regulatory requirements, Azira has implemented a Global Privacy Protocol designed to actively monitor, detect, and prevent the misuse of consumer personal data across the evolving landscape.
- Consumer Rights
Regulations increasingly focus on providing individuals with opt-out options, access to their data, and the ability to request deletion. Robust operational solutions are required. Azira ensures that consumers are able to exercise these rights at any time, through tools accessible on its website.
- Transparency Requirements
Transparency requirements pose a unique challenge for data providers, which typically lack a direct relationship with the consumer. Accordingly, responsible data providers like Azira actively monitor their supply-chains of personal data, to ensure that the “right to know” is honored throughout.
Azira’s Global Privacy Protocol
The Azira Global Privacy Protocol features a comprehensive suite of measures to ensure robust compliance with all applicable requirements, including:
- An up-to-date privacy policy that establishes a clear and lawful purpose for collecting, storing and processing data.
- GDPR-compliant data processing addendums and transfer mechanisms.
- Registration with all required state data provider regulations.
- Enhanced audit questionnaires for data supplier and vendor assessments to ensure consent.
- An enhanced data supplier assessment program to ensure a compliant supply chain.
- Active monitoring and review of all client projects to ensure compliance with privacy norms.
Azira stands ready to work with advertisers to implement a privacy-first, responsible approach to achieve your marketing objectives and grow your business. Please feel free to reach out to James Kuan or Nathan Newman at: privacy@azira.com.
Disclaimer: The information provided in this article is for general informational purposes only and does not constitute legal advice. For advice regarding your specific situation, please consult with a qualified attorney.
