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"Lora Bentley spoke with Anzen analysts Megan Brister and Jordan Prokopy via e-mail regarding behavioral advertising - what companies are doing, what regulators want to do and what we, as advertising consumers, need to know. With their coworker Miyo Yamashita, the analysts recently wrote a guest opinion for IT Business Edge. Bentley: Why are so many concerned about privacy when it comes to behavioral advertising? What is it about the Internet that convinces consumers that information they share there is not being used? Brister and Prokopy: Most concerns stem from the lack of transparency around data disclosure practices. While consumers may value a Web site's product and service offerings, they are generally unaware that businesses share their information with an extensive group of other businesses in order to deliver targeted advertising. This group includes news Web sites, advertising networks, profiling services, and Web analytics providers, to name a few. As Pamela Jones Harbour, a Commissioner at the Federal Trade Commission (FTC), discussed at the FTC Roundtable earlier this week, there is an asymmetry between consumer perceptions and business realities. Once consumers are informed of businesses' data handling practices, they will want to have more control over how businesses manage their information. As we discuss in our article, some businesses engaged in online behavioral advertising have been slow to adopt transparent consumer data management policies. This is a concern particularly for vulnerable groups, such as minors or non-English speaking consumers, because they may not understand legally written policies. Consumer advocacy groups argue that without knowledge and control over the collection, use, and disclosure of data, Web sites may misuse or expose sensitive data about consumers' health, lifestyles and finances."

You're watching Jon Stewart's "The Daily Show," when suddenly you see a commercial for the Mustang convertible you've been eyeing - with a special promotion from Ford, which knows you just ended your car lease. A button pops up on the screen. You click it with the remote and are asked whether you want more information about the car. You respond "yes." Days later, an information packet arrives at your home, the address on file with your cable company. This is the future of cable TV advertising: personal and targeted. Cable TV operators are taking a page from online advertising behemoths like Google Inc. to bring these so-called "addressable" ads onto the television. "It hasn't really been done on TV before," said Mike Eason, chief data officer of Canoe Ventures, a group formed by the nation's six largest cable operators to launch targeted and interactive ads on a national platform starting this summer. They're betting they can even one-up online ads because they also offer a full-screen experience - a car commercial plays much better on your TV than on your PC. As such, they hope to charge advertisers more. The stakes are high: Cable companies get only a small portion of the $182 billion North American advertising market. Eason said the cable operators, which sell local ads on networks like Comedy Central, get roughly 10 percent of the commercial time on those channels. With targeting, they are hoping to expand that. But they have to tread carefully. Privacy advocates worry the practice opens the door to unwanted tracking of viewing habits so ads can target consumers' likes or dislikes. They also fear it could lead to discrimination, such as poorer households getting ads for the worst auto-financing deals because they are deemed credit risks. "You've got to tell people you're doing it and you've got to give people a way to say no," said Pam Dixon, executive director of World Privacy Forum in Carlsbad, Calif. "Otherwise, it's just not fair."

The Nature of the Problem Identity theft has been referred to by some as the crime of the new millennium. It can be accomplished anonymously, easily, with a variety of means, and the impact upon the victim can be devastating. Identity theft is simply the theft of identity information such as a name, date of birth, Social Security number (SSN), or a credit card number. The mundane activities of a typical consumer during the course of a regular day may provide tremendous opportunities for an identity thief: purchasing gasoline, meals, clothes, or tickets to an athletic event; renting a car, a video, or home-improvement tools; purchasing gifts or trading stock on-line; receiving mail; or taking out the garbage or recycling. Any activity in which identity information is shared or made available to others creates an opportunity for identity theft. It is estimated that identity theft has become the fastest-growing financial crime in America and perhaps the fastest-growing crime of any kind in our society. Identity Theft: Is There Another You?: Joint hearing before the House Subcomms. on Telecommunications, Trade and Consumer Protection, and on Finance and Hazardous Materials, of the Comm. on Commerce, 106th Cong. 16 (1999) (testimony of Rep. John B. Shadegg). The illegal use of identity information has increased exponentially in recent years. In fiscal year 1999 alone, the Social Security Administration (SSA) Office of Inspector General (OIG) Fraud Hotline received approximately 62,000 allegations involving SSN misuse. The widespread use of SSNs as identifiers has reduced their security and increased the likelihood that they will be the object of identity theft. The expansion and popularity of the Internet to effect commercial transactions has increased the opportunities to commit crimes involving identity theft. The expansion and popularity of the Internet to post official information for the benefit of citizens and customers has also increased opportunities to obtain

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Banks and cellphone companies have a long way to go to persuade U.S. consumers to use their cellphones for banking, as many worry about security and extra fees and others are not even aware they can. In a survey of about 500 U.S. consumers, accounting firm KPMG found that only about 9 percent had tried mobile banking. In comparison, about 76 percent "consistently use" online banking services on computers. As many as 95 percent said they were so uncomfortable with conducting financial transactions on their phones that they've never used them to make a purchase on a retailer's Web site. About 48 percent of respondents cited security and privacy worries as their reason for not banking on their cellphones, according to KPMG. While many respondents said they believe mobile banking is important, according to the accounting firm, they do not think it is important enough to pay extra for it. Roughly 19 percent of respondents said they are "somewhat likely" to a use a mobile device for online banking in the next 12 months but only seven percent said are willing to pay a nominal fee for cellphone banking, according to the survey. And even though most of the major U.S. banks offer a mobile banking service, about 68 percent of the survey respondents said their bank does not offer the service. "The fact that the majority of U.S. consumers are not aware that their current banks offer mobile banking is clearly more perception than reality," said Carl Carande, a principal in KPMG LLP's Advisory and Banking and Finance practices. Banks offering mobile services include Citigroup Bank of America and Wells Fargo.

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

1:53:26 - Jun 29, 2007 Recorded at the 8th www.ToorCon.org Information Security Conference, Sept 30th and Aug 1st, 2006 in San Diego, California. Content produced by www.MediaArchives.com --- PRIVACY IS DEAD - GET OVER IT, with Steven Rambam. This talk will include numerous examples of actual data and investigative online resources and databases, and will include an in-depth demonstration of an actual online investigation done on a volunteer subject. (The subject is Rick Dakan, a noted author, who will be present.) (From CNN: "...Rambam was scheduled to discuss how he dug up -- in just over four hours of searching private and public databases -- more than 500 pages worth of data on Rick Dakan, who was attending the conference and had agreed to participate in the project. "All I had given him was my e-mail and name," Dakan said. "He knew everywhere I'd lived, every car I had driven, and even someone else in Alabama who was using my Social Security number since 1983.Emphasis will be placed on discussing the "digital footprints" that we all leave in our daily lives, and how it is now possible for an investigator (or government Agent) to determine a person's likes and dislikes, religion, political beliefs, sexual orientation, habits, hobbies, friends, family, finances, health and even the person's actual physical whereabouts at any given moment, solely by the use of online data and related activity

DESPITE SIGNIFICANT IMPROVEMENTS since the U.S. Sarbanes-Oxley Act of 2002 became effective, the continuing cost of compliance with the act's Section 404 requirements remains a concern for board members and management. A periodic operational audit of the Section 404 program can provide valuable information to executive management and the audit committee, and potentially identify areas where significant costsavings can be realized. Whether the Section 404 program is managed by the finance department, internal auditing, or another organization, it's an excellent candidate for this type of review, particularly if the focus remains on program efficiency. Several questions, based on The IIA's publication Sarbanes-Oxley Section 404: A Guide for Management by Internal Control Practitioners, can be used as the basis for the audit. The questions cover issues ranging from ensuring that operating management takes ownership of its processes, to achieving fewer and more effective key controls, to determining whether the external auditor's reliance on management testing has been optimized.

You have an unlisted phone number, you guard your personal information, you shred your financial papers- so everything is private and safe, right? Would you be alarmed to know that even when you think things are private, a perfect stranger can look you up online, see your address, birth date, past addresses, and even see a photo of your home, down to the detail of your child's play set out in the back yard? Alarmed yet? You should be. Take a look at this website: www.zabasearch.com. Simply plug your name in, and you are likely to be surprised, and probably a bit distressed to see all the information that is readily available online. How could this happen? Easy. Virtually every major change in your life is recorded somewhere in a government document. When you are born, a birth certificate is issued. When you obtain a driver's license, get married, buy a house, file a lawsuit ' all of these events are recorded in public documents easily available to you and to others. Government records are intentionally public in order to enable citizens to monitor the government and to ensure accountability in our society. The challenge is to balance the public's right to information with the individual's right to privacy.

In my last post, Behavioral Targeting, I mentioned that I used a home-grown form of customer tracking when I worked on Wall Street. I explain a bit more about that in this post. I will describe more about the process in a second part to this post.
Early Adopters
The competition in the financial se

The discipline known as governance, risk, and compliance (GRC) management has come a long way in a short time. Results from Business Finance's 2009 GRC Maturity Study suggest that the majority of companies with formal GRC programs are beginning to derive strategic benefits from their efforts: Two-thirds of survey respondents say that the primary benefit of the GRC programs extends beyond mere compliance to "strategic risk management and decision-making insights" (55 percent) and "superior resilience and long-term shareholder value" (11 percent). Additionally, 81 percent of survey respondents describe their company's GRC capabilities as "strong" (15 percent) or "acceptable" (66 percent); only 18 percent of respondents say that their programs are "in need of improvement." What's more, a remarkable 83 percent of survey respondents (see the "Methodology" side bar) say that their corporate GRC programs were somewhat to very helpful in enabling their organizations to anticipate and respond to the current economic downturn. At many companies, GRC is about much more than compliance these days.

Difficult economic times can be the breeding ground for increased fraudulent activities. In July 2009, the Financial Crimes Enforcement Network (www.fincen.gov) published its 12th edition of The SAR Activity Review - By the Numbers. SARs (Suspicious Activity Reports) are one key aspect of FinCEN's efforts related to its responsibility for regulatory administration of the Bank Secrecy Act of 1970. Many different financial industries such as banks, credit unions, insurance companies, check-cashing services, broker/dealers, and casinos are required to complete and file SARs. According to FinCEN's press release on the SAR Activity Review, "The report reveals that of the 20 different violation types tracked, seven of the categories relate specifically to fraud and all seven showed an increase in SAR filings during the year. While these categories represent one-third of the possible violation types, they accounted for nearly half of the increase in total SAR filings from 2007 to 2008, with all of the fraud categories seeing double-digit increases in percentage of filings in 2008. These categories are: check fraud, mortgage loan fraud, consumer loan fraud, wire transfer fraud, commercial loan fraud, credit card fraud, and debit card fraud." Could any of this apply to you? Are your control and monitoring processes able to identify these examples of common patterns of suspicious activity that FinCEN has identified?

Has your management team asked the following four questions about your organization's internal controls? 1) Have we identified the meaningful risks to our objectives? 2) Which controls are "key controls" that will best support a conclusion regarding the effectiveness of internal control in a particular process? 3) What information will be persuasive in assessing whether the controls are continuing to operate effectively? 4) Are we presently performing effective monitoring that is not unnecessary and costly testing? These questions appear in a white paper, "Effective Internal Control Systems for Rapidly Changing Markets: A New Opportunity," packed with answers for GRC professionals wondering if there is a better way to operate. The paper, authored by the GRC experts at advisory firm SMART Group, clearly lays out how controls monitoring processes can and should align with the "Guidance on Monitoring" COSO published earlier this year to help organizations strengthen the effectiveness and efficiency of their internal controls frameworks. Among other useful how-to information, the 12-page paper includes a five-step "Implementation Guide" for creating a better controls-monitoring program.

As I mentioned two weeks ago, a recent survey indicates that more than half of large companies have limited knowledge of which systems or applications their employees have access to. This marks a system access problem, and a growing risk during a period of frequent and large layoffs. If a company needs to turn off access manually (which is often the case), it may miss several user accounts that they don't realize exist. This leaves the door open for past employees, and others, to access important data, including financial information and customer information. To learn more about these open-door system risks, I asked Courion vice president Kurt Johnson about his firm's research.

To find out more about the survey, I asked Deloitte LLP chairman of the board Sharon Allen to provide some additional context. Given that my only risk-management concern early this week relates to thunderstorms off the coast of South Padre Island, I asked Sharon to step in as a guest blogger today. Here's what she sent me: When I was a high school student growing up in the small farming community of Kimberly, Idaho, little did I know that a song from that time could serve as an anthem for something happening in the workplace today. The Beatles' 1967 classic "Hello Goodbye" is a study in contrasts, as are the current attitudes about social media. Social media has arrived - and with it, employers and employees are singing very different songs about what constitutes appropriate social networking both on and off the job. Recently, I commissioned the third annual Deloitte LLP "Ethics & Workplace" survey. We polled 500 executives and 2,000 employees outside Deloitte. Our survey found that 60 percent of business executives believe they have a right to know how employees portray themselves and their organizations in online social networks. Perhaps because nearly three-fourths of the employees in our poll agreed that the use of social networks makes it easier to damage a company's reputation. However, more than half of employees polled say their social networking pages are not an employer's concern. That belief is especially true among younger workers, with nearly two-thirds of 18- to 34-year-old respondents stating that employers have no business monitoring their online activity.

The same Facebook that unites far-flung grandparents with newborn grandchildren and helps liberate the oppressed can also shatter lives and destroy careers with the click of a Send button. The same Twitter that is indispensible to the young can be utterly extraneous to their elders.