Every Move You Make…
Advertisers are tracking your online behaviour
Behavioural Advertising
As Canadians embrace social networks and other online technologies, they are sharing increasing amounts of
personal information over the Internet. Some of this sharing is done deliberately, by posting pictures and
comments. But the mere fact of navigating the Internet also leaves behind a rich trail of information that can
reveal a great deal about a person’s location, personal preferences, computer settings and browsing patterns.
Tracking these trails is behavioural advertisers’ bread and butter. The type of information tracked and
collected can include: IP addresses, pages visited (on a single site or across sites), length of time spent on
pages, advertisements viewed, articles read, purchases made, search terms used, user preferences such as
language and web browser type, operating system and geographical location.
Behavioural advertisers can then use sophisticated algorithms to analyze the collected data, to build detailed
users’ personal profiles and to assign them to various interest categories. Interest categories are used to
present ads defined as relevant to users in those categories. Depending on the advertiser, these interest
categories can be broad or very specific.
Although it is often argued that information that can be collected about online activity is anonymous and
cannot identify individual users, recent reports have shown that, sometimes, what is assumed to be
anonymous data can be re-identified with relative ease. In addition, combining data from “anonymous” online
profiles with real-world information from other sources such as social networking sites can increase the risk of
anonymous online profiles being tied to offline identities.
The Personal Information Protection and Electronic Documents Act (PIPEDA) applies to the collection, use and
disclosure of personal information in the course of a commercial activity. 1 It requires that purposes be
“appropriate,” identified to the individual and consent obtained. Instances where consent is not required are
limited.
A 2009 survey conducted by the Public Interest Advocacy Centre found that nearly three-quarters of
respondents said they were uncomfortable with behavioural advertising, and only about half of respondents
were aware of tracking devices and techniques. However, people tended to be more comfortable with online
tracking for the purposes of improved customer service or advertising if it was done by companies with which
they had had prior dealings.
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30 Victoria Street – 1st Floor, Gatineau, QC K1A 1H3 • Toll-free: 1-800-282-1376 • Fax: (819) 994-5424 • TDD (819) 994-6591
www.priv.gc.ca • Follow us on Twitter: @privacyprivee
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The Office of the Privacy Commissioner is concerned about the potential privacy infringements presented by
such practices, particularly the lack of transparency with which they are conducted and the quality of the
consent obtained as a result of these practices. It has called on the advertising industry to better explain what
behavioural advertising involves, and how people can opt out if they wish. The industry should also ensure
that organizations obtain appropriate consent before tracking consumer.
For more information on behavioural advertising and online tracking, profiling and targeting, please see:
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The Report on the 2010 Office of the Privacy Commissioner of Canada’s Consultations on Online
Tracking, Profiling and Targeting, and Cloud Computing
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Cookies – Follow the Crumbs
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Alberta, British Columbia and Quebec has have private-sector privacy legislation that is deemed to be substantially
similar to PIPEDA.
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30 Victoria Street – 1st Floor, Gatineau, QC K1A 1H3 • Toll-free: 1-800-282-1376 • Fax: (819) 994-5424 • TDD (819) 994-6591
www.priv.gc.ca • Follow us on Twitter: @privacyprivee
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