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On November 1 and 2, 2007, the Federal Trade Commission will host a Town Hall entitled "Ehavioral Advertising: Tracking, Targeting, and Technology." The event will bring together consumer advocates, industry representatives, technology experts, and academics to address consumer protection issues raised by the practice of tracking consumers' activities online to target advertising - or "behavioral advertising." The Town Hall is a follow-on to a dialogue on behavioral advertising that emerged at a November 2006 FTC forum, "Tech-Ade," which examined the key technological and business developments that will shape consumers' core experiences in the coming ten years. In addition, several consumer privacy advocates, as well as the State of New York, recently sent letters to the FTC asking it to examine the effects of behavioral advertising on consumer privacy. The Town Hall will explore how the online advertising market, and specifically behavioral advertising, has changed in recent years, and what changes are anticipated over the next five years. Among other things, it will examine what types of consumer data are collected, how such data are used, what protections are provided for that data, and the costs and benefits of behavioral advertising to consumers. The Town Hall will also address what companies are disclosing to consumers and what consumers understand about the online collection of their information for use in advertising. In addition, the Town Hall will look at what regulatory and self-regulatory measures currently govern the practices related to online behavioral advertising, as well as anticipated changes in the behavioral advertising space in the future. The Commission invites interested parties to submit requests to be panelists and to recommend other topics for discussion. The requests should be submitted electronically to behavioraladvertising_requests@ftc.gov by September 14, 2007. The Commission asks interested parties to include a stat

If you've been advertising online for a long time, you may have gone through stages: sticking with banner ads at first, and then going with search engine advertising, and maybe putting your ads on a publisher network belonging to a search engine or an advertising company. Most of the time you probably tried to put your ad in a matching context. That might be the wrong approach. I've written before about behavioral advertising, also known as behavioral targeting. You can read my first article about it here. If the topic of behavioral targeting intrigues you, you might also want to read about behavioral retargeting. Before I plunge into the content and focus of this article, though, let me give you a quick definition. Behavioral advertising is a form of online advertising that follows the user around. For example, a web surfer who has just priced some flights on an airline's website might be shown a travel-related ad when he surfs to the next website in which he's interested, which might be for the local pizza joint. The theory behind behavioral advertising is, in a sense, pretty simple. Most people are bombarded with ads most of the time, especially when web surfing. As a result, we tune them out. Because of the usual advertising practices, we might be better at tuning out ads that are in the same context as the content we're reading. In other words, someone reading content on a web site about where the best ski slopes are just might have completely ignored an ad for your lovely Aspen getaway. To rise above this clamor, it's necessary to hit web surfers with a surprise, something that doesn't fit the normal context. Think about it: aren't you more likely to stare at someone talking into a banana than a cell phone? That's the theory, but it's new enough that researchers and marketers are still doing surveys to prove or disprove it. The most recent one was conducted by BL Labs and released by ad network BlueLithium. You'd probably expect it to

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Federal Trade Commission staff today issued a report describing its ongoing examination of online behavioral advertising and setting forth revisions to proposed principles to govern self-regulatory efforts in this area. The key issue concerns how online advertisers can best protect consumers' privacy while collecting information about their online activities. Over the last decade, the FTC has periodically examined the consumer privacy issues raised by online behavioral advertising - which is the practice of tracking an individual's online activities in order to deliver advertising tailored to his or her interests. The FTC examined this practice most recently at its November 2007 "Behavioral Advertising" Town Hall. The following month, in response to public discussion about the need to address privacy concerns in this area, FTC staff issued a set of proposed principles to encourage and guide industry self-regulation for public comment. Today's report, titled "Self-Regulatory Principles for Online Behavioral Advertising," summarizes and responds to the main issues raised by more than 60 comments received. It also sets forth revised principles. The report discusses the potential benefits of behavioral advertising to consumers, including the free online content that advertising generally supports and personalization that many consumers appear to value. It also discusses the privacy concerns that the practice raises, including the invisibility of the data collection to consumers and the risk that the information collected - including sensitive information regarding health, finances, or children - could fall into the wrong hands or be used for unanticipated purposes. Consistent with the FTC's overall approach to consumer privacy, the report seeks to balance the potential benefits of behavioral advertising against the privacy concerns it raises, and to encourage privacy protections while maintaining a competitive marketplace. The report points ou

Last month, the digital advertising industry's use of behaviorally targeted advertising gained a reprieve of sorts when the Federal Trade Commission issued a final report confirming its earlier support of self-regulation. But some commission members remained concerned about ads that are shown to Web users based on their previous online activities, and in particular the possibility of violations of online privacy. Some form of legal restrictions may be imposed on the industry, the FTC indicated, if the online ad industry isn't up to the task of regulating itself. "Privacy is definitely the biggest concern today," said Joe Apprendi, CEO of Collective Media, an online advertising network based in New York. "There has been the concern that through such approaches as deep-packet technology, companies can leverage information through subscriber-based providers to marry anonymous behavioral segment data and identify real people. "The fact is, online advertising is subject to a higher standard that offline direct marketing tactics," Apprendi said. The FTC report, "Self-Regulatory Principles for Online Behavioral Advertising," continues to advocate voluntary industry self-regulation, in keeping with its principles governing online behavioral advertising issued at the end of 2007, despite the urgings of consumer advocacy groups that it impose rules regulating online advertising. The commission's new guidelines are based on four principles: * Transparency and consumer control. The commission advises that Web sites that collect data for behavioral advertising provide "a clear, concise, consumer-friendly and prominent statement" that the data are being collected to provide ads tailored to the user's interests and that the user has an easy and obvious way to choose whether to allow this. * Security for data retention. Companies that collect data for behavioral advertising should provide "reasonable" protection of that information and reta

To address important consumer privacy concerns associated with online behavioral advertising, the staff of the Federal Trade Commission today released a set of proposed principles to guide the development of self-regulation in this evolving area. Behavioral advertising is the tracking of a consumer's activities online - including the searches the consumer has conducted, the Web pages visited, and the content viewed - in order to deliver advertising targeted to the individual consumer"s interests. For more than a decade, the FTC has engaged in investigation, law enforcement, studies, and other privacy developments to protect consumers' privacy online. Concepts used to develop the principles emerged from the agency's longstanding privacy program and, more recently, from two conferences hosted by the FTC. In the fall of 2006, a three-day public hearing, "Protecting Consumers in the Next Tech-ade," examined technology developments that could raise consumer protection policy issues, including privacy, over the next decade. This past November, building on the Tech-ade hearings, the FTC hosted a Town Hall entitled "Ehavioral Advertising: Tracking, Targeting, and Technology," to focus in on privacy issues raised by behavioral advertising. "The purpose of this proposal is to encourage more meaningful and enforceable self-regulation to address the privacy concerns raised with respect to behavioral advertising. In developing the principles, FTC staff was mindful of the need to maintain vigorous competition in online advertising as well as the importance of accommodating the wide variety of business models that exist in this area," according to its proposal "Behavioral Advertising: Moving the Discussion Forward to Possible Self-Regulatory Principles." The proposal states that behavioral advertising provides benefits to consumers in the form of free content and personalized advertising but notes that this practice is largely invisible and unknown to consumers. To address the

Now that behavioral targeting has become more pervasive (and more effective), it is being talked about not only by publishers and advertisers, but also by privacy advocates -- organizations like the NAI and IAB and, in Washington, the FTC. At issue is if BT players are doing enough to disclosure to consumers how BT works and offering them the opportunity to opt out of being tracked by BT vendors and publishers. There has been much discussion about how to regulate behavioral marketers; but no solution that satisfies everyone. The BT industry so far has contended that website privacy policies are sufficient disclosure since many of them contain links to opts out opportunities like the NAI site. Google and Bluekai have announced 'preference pages' or registries that allow Web users to say what type of BT they are interested in receiving. But, the other, more common option is to put that information in the Privacy Policy of the site. But the problem with that is that no matter where disclosures are placed on the service provider's site, most people won't ever see them. How will a customer visiting Retail SiteX know that Company Y is going to use their browsing behavior to later display relevant ads to them as they surf the Web on Network Z? The average customer won't. The only way a customer will know what forms of BT advertisers are using is if the advertisers themselves tell them. I think that it's time for advertisers to step up in this privacy debate. Thus far the pressure for disclosure has been placed on networks, behavioral marketing providers and publishers. The key players in those industries have done a good job of becoming more transparent (though there is still work ahead of us), while advertisers haven't been asked to do anything. Advertisers are clearly benefiting from behavioral marketing, and its time they disclosed what type of behavioral marketing they participate in, and allow customers to opt-out. How they do this is open for discussion: Tag each

Big Brother may be at it again. Behavioral advertising -- the tracking of consumer's Internet surfing activity to create tailored ads -- has triggered an intense legal controversy that has law firms scrambling to stay on top of a burgeoning practice. Attorneys say that behavioral advertising is raising privacy, litigation and regulation fears among consumer advocates, the electronic commerce and advertising industries and legislators. Law firms are busy helping companies come up with a transparent way of letting consumers know that their online activities are being tracked and possibly shared. "Lawmakers and companies are having a tough time keeping up with this new frontier of Internet privacy issues, and there is growing consumer unrest about behavioral advertising, leading in some cases to consumer rebellion," said Lisa Sotto, a partner and head of the privacy and security data group in the New York office of Richmond, Va.-based Hunton & Williams. "Consumers find this type of tracking intrusive, and businesses are starting to take the consumer reaction seriously," she said. The buzz over behavioral advertising has been building since congressional hearings that were held last year, during which Congress called on Internet service providers (ISPs) to testify about a highly controversial advertising practice known as "deep-packet inspection." The practice gives companies the ability to track every Web site consumers visit and provides a detailed look at everything they're doing, such as where they're going on vacation, who is going, how much they spent on the trip and what credit card was used. But then came the first class action targeting behavioral advertising, filed against Foster City, Calif.-based NebuAd Inc., an online advertising company accused of spying on consumers from several states and allegedly violating their privacy and computer security rights. The lawsuit specifically alleges that NebuAd engaged in deep-packet inspection. Valentine v. Ne

As online shopping becomes a greater force each year, the behavior of online shoppers becomes more and more scrutinized. Ad net AudienceScience, a key scrutinizer, announced today the findings of a commissioned study conducted on its behalf by JupiterResearch designed to measure the receptiveness of online shoppers to behavioral targeting. And the survey says: They like it -- at least that they are more responsive to ads that are behaviorally targeted than those that are contextually targeted. And they were pretty clear about it, with 65 % responding that they are more receptive to BT, and only 35% saying they paid more attention to contextual ads. "Since its inception, behavioral targeting has been an evolution of contextual advertising, and these findings are testament to its power to more effectively engage with consumers on their own level," said Marla R. Schimke, VP of Marketing, AudienceScience. "If we conduct the same study in a year, five years, ten years, I believe we'll see this already substantial gap between the two continue to widen as more and more brands and marketers realize that they can use behavioral targeting to specifically target their ideal customer."

Big Brother may be at it again. Behavioral advertising - the tracking of consumer's Internet surfing activity to create tailored ads - has triggered an intense legal controversy that has law firms scrambling to stay on top of a burgeoning practice. Attorneys say that behavioral advertising is raising privacy, litigation and regulation fears among consumer advocates, the electronic commerce and advertising industries and legislators. Law firms are busy helping companies come up with a transparent way of letting consumers know that their online activities are being tracked and possibly shared. "Lawmakers and companies are having a tough time keeping up with this new frontier of Internet privacy issues, and there is growing consumer unrest about behavioral advertising, leading in some cases to consumer rebellion," said Lisa Sotto, a partner and head of the privacy and security data group in the New York office of Richmond, Va.-based Hunton & Williams. "Consumers find this type of tracking intrusive, and businesses are starting to take the consumer reaction seriously," she said. The buzz over behavioral advertising has been building since congressional hearings that were held last year, during which Congress called on Internet service providers (ISPs) to testify about a highly controversial advertising practice known as "deep-packet inspection." The practice gives companies the ability to track every Web site consumers visit and provides a detailed look at everything they're doing, such as where they're going on vacation, who is going, how much they spent on the trip and what credit card was used. But then came the first class action targeting behavioral advertising, filed against Foster City, Calif.-based NebuAd Inc., an online advertising company accused of spying on consumers from several states and allegedly violating their privacy and computer security rights. The lawsuit specifically alleges that NebuAd engaged in deep-packet inspection. Valentine v. Ne

As arguments swirl over online privacy, a new survey indicates the issue is a dominant concern for Americans. More than 90 percent of respondents called online privacy a "really" or "somewhat" important issue, according to the survey of more than 1,000 Americans conducted by TRUSTe, an organization that monitors the privacy practices of Web sites of companies like I.B.M., Yahoo and WebMD for a fee. When asked if they were comfortable with behavioral targeting - when advertisers use a person's browsing history or search history to decide which ad to show them - only 28 percent said they were. More than half said they were not. And more than 75 percent of respondents agreed with the statement, "The Internet is not well regulated, and naïve users can easily be taken advantage of." The survey arrives at a fractious time. Debate over behavioral advertising has intensified, with industry groups trying to avoid government intervention by creating their own regulatory standards. Still, some Congressional representatives and the Federal Trade Commission are questioning whether there are enough safeguards around the practice. Last month, the F.T.C. revised its suggestions for behavioral advertising rules for the industry, proposing, among other measures, that sites disclose when they are participating in behavioral advertising and obtain consumers' permission to do so. One F.T.C. commissioner, Jon Leibowitz, warned that if the industry did not respond, intervention would be next. "Put simply, this could be the last clear chance to show that self-regulation can - and will - effectively protect consumers' privacy," Mr. Leibowitz said, or else "it will certainly invite legislation by Congress and a more regulatory approach by our commission." Some technology companies are making changes on their own. Yahoo recently shortened the amount of time it keeps data derived from searches. It is also including a link in some ads that explains how

"Consumers are often oblivious to the fact that some businesses share a great deal of their personal information with other businesses who deliver targeted behavioral advertising, says Anzen analysts Megan Brister and Jordan Prokopy. In an e-mail interview with IT Business Edge editor Lora Bentley, Brister and Prokopy say most consumers are just not aware of the business practices of companies that use personal information for profit. The Federal Trade Commission recently held meetings with consumer and privacy advocates, business and government leaders to discuss privacy, regulatory, and business issues of online behavioral advertising. It plans plan to ramp up efforts to protect consumers and possibly push for tougher legislation to protect consumers. One issue, Brister and Prokopy say, is the lack of transparency by companies that engage in behavioral advertising. These companies have been slow to adopt clear data-management policies and even when they do have policies, they are often written in language that is difficult to understand. Fortunately for consumers, some type of regulation appears to be on the way. The FTC appears eager to penalize businesses who lack transparency regardless of whether the consumer actually experienced any real negative effects as a result, Brister and Prokopy say."

As the impact of digital advertising on consumer privacy comes under scrutiny, AT&T is taking a stance in support of stricter standards. Rep. Rick Boucher (D., Va.), chairman of the subcommittee, said in an interview Wednesday that a statute is needed to regulate how companies collect, share and use data on consumers' behavior in targeting online advertising. While ad targeting on the Web has been at the forefront of privacy advocates' concerns, worries are growing about other media, ranging from mobile phones to emerging TV technologies. To sell marketers targeted ads, technology and media companies collect data about customers, ranging from the Web sites they visit to the neighborhoods they live in to the TV shows they watch. Marketers often will pay a premium for this form of advertising because it allows them to show their ads to consumers who are likelier to buy their products or services. "Pitfalls arise because behavioral advertising in its current forms is largely invisible to consumers," says Dorothy Attwood, AT&T's senior vice president of public policy and chief privacy officer, in prepared testimony she is expected to deliver at the hearing of the House Subcommittee on Communications, Technology and the Internet. Her statement says consumers don't fully understand that their online activity is used to create detailed profiles of them. Internet and other media companies say the data they use to target ads are anonymous and can't be traced to individual consumers. AT&T plans to argue that consumers should have "full and complete" notice of what information is collected about them and how it is used and protected, and should have tools that let them determine whether their Web activities are being tracked. The company says it won't use consumer information for online behavioral advertising unless it first obtains consent from the consumers involved. AT&T's stance contrasts with the position taken by most big Internet companies and industry trade grou

More consumers are growing comfortable with online behavioral targeting, perhaps as a result of an increase in familiarity, but the majority remain uneasy with the practice. That's according to a new study conducted by TNS on behalf of the privacy group Truste. For the study, consumers were asked whether they agreed or disagreed with the statement: "I am comfortable with advertisers using my browsing history to serve me relevant ads, as long as that information cannot be tied to my name or any other personal information." Twenty-eight percent of respondents agreed, up from 24% who agreed when the same study was conducted last year. At the same time, 51% said they disagreed that they were comfortable with anonymous behavioral targeting. While that figure represents a slim majority, it's down from last year, when 57% of respondents said they disagreed. At the same time, more respondents than in the past now say they delete cookies. Almost half--48% of survey respondents--said they erase cookies at least weekly, up from 42% last year. It's not clear how much overlap there is between the respondents that regularly delete cookies and those who say they're uncomfortable with behavioral targeting. Colin O'Malley, vice president of strategic business at Truste, attributed the increase in the proportion of consumers who said they were comfortable with behavioral targeting to increased publicity over the issue. He said the recent attention to the issue in the mainstream media has helped to increase transparency. He added that the increased cookie erasures showed that consumers want to be able to manage their experience. "Cookie deletion is just one more indication that consumers are seeking tools to increase their level of control," he said.

If behavioral targeting is the key to providing Web users with advertising that's better tailored to their particular needs and interests--instead of banner ads that they ignore--then what's the harm to consumers? That was a central question tackled by a panel of privacy and online marketing experts Thursday at the OMMA Behavioral conference in New York. Whether online user tracking--even when anonymous--represents a growing threat to privacy has become a hotly debated issue in the last year, with FTC, Congress and state governments considering increased regulation of behavioral targeting. For Jules Polonetsky, co-chair and director of the AT&T-funded think tank Future of Privacy Forum, that debate has become almost superfluous. Whatever side one takes, he emphasized that there is now a widespread perception among consumers and regulators that online tracking is creepy at the very least. The key to diffusing the controversy is for publishers and marketers to give Web users notice that their behavior is being tracked in order to provide them with more relevant content, recommendations and marketing offers.

Google will unveil new privacy measures today that will give consumers more control over behavioral targeting. Now, when Google serves banner ads on outside publishers' sites, the ads will include links that provide more information explaining why they were served. Clicking through will lead to details about the company's behavioral advertising program, which categorizes consumers as interested in particular types of goods or services based on the sites they visited. The program is only in beta for now, but once Google signs up publishers, consumers will be able to view the categories they have been placed in--such as "interested in travel"--and also tell Google to remove them from whatever buckets they wish. Consumers also will be able to opt out of the program permanently via a browser plug-in. Or, if people want to receive ads for certain types of products, they can edit their profiles to reflect that--in effect, opting in to particular types of ads. Google's new measures come at a time when online behavioral targeting is facing increased scrutiny. Last month, two Federal Trade Commissioners warned that the online advertising industry could face new laws if it didn't take steps to self-regulate on privacy issues. Recently, Google rival Yahoo announced enhancements to its privacy policies. Among other changes, Yahoo said it would allow consumers to opt out of behavioral targeting on its own site. Google's move drew praise from the Interactive Advertising Bureau's Mike Zaneis, vice president for public policy. "It's really a consumer empowerment tool, which is great," he said. "It's one more example of how industry is competing on the privacy issue, to the benefit of consumers--and also to the benefit of businesses."

"Faced with increasing pressure from Washington, the Interactive Advertising Bureau launched a public service campaign on Thursday aimed at educating consumers about behavioral targeting. The online campaign, created pro bono by WPP's Schematic, features rich media banner ads with copy like "Advertising is creepy" and "Hey, this banner can tell where you live. Mind if we come over and sell you stuff?" More than one dozen publishers -- including Microsoft, Google's YouTube, and AOL -- have committed to donate a combined 500 million impressions for the initiative. The campaign comes as policymakers are questioning whether data collection by marketers violates consumers' privacy. Rep. Rick Boucher (D-Va.) has said he plans to introduce a bill that could require Web companies to notify users about online ad targeting, and in some circumstances, obtain their explicit consent. In addition, the Federal Trade Commission has criticized the industry for using dense privacy policies to inform people about behavioral targeting, or tracking people online and sending them ads based on sites visited. In a meeting with reporters Thursday morning, IAB President and CEO Randall Rothenberg said one goal of the campaign is to address regulators' concerns that consumers don't understand behavioral advertising. "

On Monday, U.K.-based digital rights organization Open Rights Group submitted an open letter to major online media players, urging them to prevent ISP-level behavioral targeting firm Phorm from tracking user interactions on their Web sites. The letter, sent to Google, AOL, Microsoft, Facebook, Yahoo, Amazon and Ebay, said, "[ORG] believes that it is clearly in your company's interest, it is in the interests of all of your customers, and it will serve to protect your brand's reputation, if you insist that the Phorm/Webwise system does not process any data that passes to or from your website." "We have received the letter and are giving it careful consideration from privacy and business perspectives," a spokesperson for AOL and its social network Bebo told ClickZ News. Similarly, in reference to the ORG correspondence, a Google spokesperson told ClickZ, "We've received the ORG's letter, but we're still considering the points they raised, so we don't have a response to make at this time." According to information published on the British Telecom Web site (one of Phorm's ISP-partners,) site owners can specifically request that their properties are not "scanned" by Phorm's technology, by contacting the firm directly. Phorm announced deals with three major U.K. ISPs over a year ago, but its technology is still yet to be fully deployed. BT has, however, carried out live trials of the platform with some of its customers. Phorm's CEO, Kent Ertugrul, claims that BT will implement his company's technology by the end of the year, but BT itself remains less committed to that timeline. Both AOL and Google have vested interests in the behavioral targeting space, although not in the controversial area of deep packet inspection (DPI), in which Phorm's technology lies. AOL-owned Tacoda targets ads based on users' activity across a range of partner sites, but does not directly intercept ISP-data. Google also announced this month that it will begin testing similar behavioral targe

Three out of four Americans believe that individuals are responsible for protecting their own privacy online. That's the bottom line of a new survey conducted by TRUSTe, a company that certifies the compliance of websites with privacy standards and statements. Nonetheless, The New York Times reports that the Federal Trade Commission is trying to put more responsibility on website operators: Last month, the F.T.C. revised its suggestions for behavioral advertising rules for the industry, proposing, among other measures, that sites disclose when they are participating in behavioral advertising and obtain consumers' permission to do so. One F.T.C. commissioner, Jon Leibowitz, warned that if the industry did not respond, intervention would be next. "Put simply, this could be the last clear chance to show that self-regulation can -- and will -- effectively protect consumers' privacy," [FTC commissioner Jon] Leibowitz said, or else "it will certainly invite legislation by Congress and a more regulatory approach by our commission." Behavioral advertising, which records individual users' Web usage by inserting cookies into their browsers and keeping a log of where they go and what they do, is the most high-profile privacy issue today. Google-owned DoubleClick is tracks Web users across many sites, combining them into one profile at DoubleClick's end to be used for ad targeting. Some survey respondents use cookie-deleting browsers and anonymizing software to thwart tracking systems. Privacy advocates, TRUSTe, and the FTC all strongly encourage companies to post meticulous privacy statements for online visitors, and to follow them to the letter. Still, only 15 percent of TRUSTe's survey respondents said they actually read privacy statements.

Emily Riley of Forrester Research presented a lot of data during her keynote presentation at today's OMMA Behavioral Conference but one point she made seemed rather salient to me: many of those marketers and data firms involved in behavioral targeting seem to skip over social media as a source of information. They might look at the data surrounding the usage of those sites but they seem to rarely do any actually monitoring, let alone interacting there. It reminded me of an experience I had with my wife. We once lived in a building where we didn't have much interaction with our neighbors, very little beyond an occasional wave in the hallway. We could, however see their mail mixed with ours and our landlord's. My wife began to notice that the landlord and our neighbor were starting to get similar envelopes from law firms. I, being the incurious mail sorter I am, didn't really think much of it. She, on the other hand, was convinced that one of them must be suing the other and was able to spin out some fairly detailed scenarios based on other clues from the hallway, the presence of exterminators one day, the thickness of paint on the front door etc. One day I encountered our neighbor in the hallway and did my customary wave. "Oh by the way," He said, "We're moving out next week." Oh really? He then regaled me with the entire story which involved a variety of things including an exterminator, paint thickness, and law firms. My wife and I were both able to glean essentially the same information. However if I had approached him and said, without any warning, "I bet you and our landlord are having one heckuva legal squabble," he probably would have punched me in the nose. I also believe that the ease with which I was able to get the whole story out of him suggests that had we interacted more it would have been I scooping my wife and not the other way around. These two approaches to gathering information are akin to the difference between following

I have an open question for the people who complain about the potential of advertising networks to track your behavior on the Internet: What is a better way? Some might say that all behavioral targeting should simply be banned. But if you don't think that showing Chevy ads to people looking for cars is equivalent to poisoning the peanut butter, we need a middle ground that explains to people what's going on and lets them decide what is acceptable. This is much harder than it sounds: Any one Web page you visit can have a dozen advertisements and invisible bits of code that each send information about you to different companies, each with different ways of using that data. The privacy policy of the site you are looking at - not that anyone reads privacy policies - can't even try to explain this to you, because the site owner doesn't even know what all of its advertisers are doing. I'm coming to the conclusion that each advertisement on a page has to speak for itself. That's implicit in the approach Google is taking for its new behavioral targeting system. It puts the phrase "Ads by Google" on all its advertisements. Click that link and you'll get some limited information about Google's targeting system and an ability to adjust some of the interests that Google is tracking. But Google's approach is presented in a way that glosses over what they are doing and discourages people from reading the disclosure and exercising control, says Joseph Turow, a marketing professor at the Annenberg School for Communication of the University of Pennsylvania. Mr. Turow has developed a plan that is simpler and more comprehensive: Put an icon on each ad that signifies that the ad collects or uses information about users. If you click the icon, you will go to what he calls a "privacy dashboard" that will let you understand exactly what information was used to choose that ad for you. And you'll have the opportunity to edit the information or opt out o