The advertising technology industry received a shock to its system earlier this year when Apple announced it had made drastic changes with the release of its iOS 14 operating system. The tech company will not enforce the new changes until 2021, but it still leaves a lot of questions in the interim.
With iOS 14 and under Apple's App Tracking Transparency framework, developers will now be required to obtain user opt-in before their Identifier for Advertisers — the tech company's specific identifier tied to a user's device — can be shared for targeted advertising.
Each application will be required to send a one-time prompt to users asking them to either "Allow Tracking" or "Ask App Not to Track." Users will have the ability to go into their Settings and change permissions for each individual app, a distinct difference from the structure Apple had in place with previous operating systems.
"Prior to iOS 14, the IDFA was either on or off for all apps on the device," Future of Privacy Forum Director of Technology & Privacy Research Christy Harris, CIPP/US, said during an IAPP LinkedIn Live. "Now, users will be able to choose whether or not an individual app is able to receive that identifier or do tracking as opposed to a blanket on or off for the device."
Adtech will have to adjust to an opt-in model, and TripleLift General Counsel and Chief Privacy Officer Julia Shullman, CIPP/E, has already seen how her company will be affected by the paradigm shift. Shullman said TripleLift is a supply side platform that works directly with publishers, and while they do not use identifiers for targeted advertising, they can be helpful for reporting and measurement purposes.
Shullman highlighted the biggest issue adtech will face with Apple's new targeted advertising model. Users now have the ability to decide whether they want to be tracked, and the majority of them will likely say no. Since they are only going to be asked once, adtech will have a tall hill to climb.
"What I’ve been told based on studies that a number of big publishers and large players have done is that we are seeing extremely, extremely low opt-in rates associated with this binary opt-in choice," Shullman said. "I think it’s sometimes sub-15%, if not 10%. It’s going to have a large impact on the ecosystem because we will have no way of doing measurements, reporting or any of these other uses cases that others in the ecosystem have been doing today."
Harris agreed that opt-in rates are going to be low. To stop users from dismissing tracking requests at the get-go, Harris said app developers need to think outside the box to attract users' attention. She added developers can use this model as a chance to clarify what they do with identifiers and the value the user would receive by agreeing to be tracked.
"It is possible for a user to be interacting with an app and receive information that would provide an opportunity for a developer to explain why they are going to show this prompt," Harris said. "It’s an opportunity for developers to find creative ways to get consent or induce users to give consent."
The likelihood of low opt-in rates is just one area of frustration adtech has expressed since the changes were announced. Another point of contention is how Apple wants publishers to implement its framework.
Since publishers have a direct relationship with consumers, Shullman said they would want to use their own interface for each interaction. Shullman continued by saying Apple is "very specific around how this interface needs to work," which takes a level of control away from publishers.
Shullman praised Apple for its good intentions in helping explain the tracking process to consumers, but the tech company's framework preferences puts a lot of parties in a bind.
"I love that Apple is trying to simplify this from a consumer perspective. I think that all of us that are in this space are always impressed with how they try to simplify consumer dialogue and try to simplify talking about privacy," Shullman said. "The challenge is the consumer experience across a variety of internet-connected devices and technologies across the web, and whether those companies and their vendors and clients are using the same taxonomy and language to talk about the various use cases. That is the challenge with Apple not partnering with the ecosystem, with their clients and with other technology providers."
Another question around the framework surrounds compliance. Shullman said Apple could go further to ensure app developers cannot circumvent what is in place to obtain a user's identifier. While "larger players and the people who are more above board" will comply with Apple's policies, Shullman believes an that in an industry "where there’s a race to a bottom," some bad actors may find means to gather identifiers and use them for nefarious purposes.
Should such activity be seen, Harris said the U.S. Federal Trade Commission may weigh in with an opinion on potential deceptive behavior. Harris also points to Apple's terms of services for developers that wish to have an app listed on its platform as a way curb bad behavior. Apple can lean on those terms to remove any questionable offerings and also signal that it plans to take enforcement of its framework seriously.
"While Apple may not have the technical means to stop companies from using certain data, they do have the ability to stop an app existing on their platform," Harris said. "I think there’s a question about whether or not or how rigorous Apple will be in accepting reports and doing some sort of accountability and enforcement of the apps in their ecosystem. I think that remains to be seen. This is definitely an opportunity for them to take a stand and show do they have teeth in this conversation."
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