To mark World Data Privacy Day, our Chief Compliance and Data Privacy Officer Karis McLarty answers FAQs about privacy at Clear Channel.
What is your role at Clear Channel and what does your day normally involve?
I’m Chief Compliance and Data Privacy Officer, and my job is to help the business behave ethically across a broad remit, from privacy to corruption. I love that no day is the same. I could spend my morning brainstorming carbon reductions, interviewing a suspect in a forensic investigation, and then the afternoon reviewing sanctions red flags or conducting a data privacy impact assessment.
What is Clear Channel’s approach to data privacy?
We have a bold vision at Clear Channel to create the future of media. Part of achieving this means making outdoor advertising more effective, which data allows us to do, by helping our advertising clients find the best locations, timings, and content to run their campaigns on.
At the heart of Clear Channel is our commitment to behaving ethically as a company. Our work has to meet our objective of being a Platform for Brands and a Platform for Good, and our Value of Fairness.
To help us do that, we have a Data Privacy Office that has developed Fair Processing and Fair Information Security controls to ensure that appropriate privacy and security standards are maintained. The Privacy Office is supported by Data Champions and Local Compliance Officers in our markets, and our controls cover everything from understanding and recording what data we process, why, where, who has access to it, and ensuring measures are in place to make sure it is adequately protected under law. We run regular audits on our markets and training for teams that deal with personal data and have a robust due diligence process for the suppliers we work with.
What personal data does Clear Channel use to inform advertising campaigns that run on your billboards, bus shelters and street furniture and why?
This is something that has been misrepresented in the media, so it’s good to be able to explain this.
Outdoor advertising is a mass-audience medium. Brands come to Clear Channel when they want to reach hundreds of thousands of people and create brand fame, so we’re interested in insights about group behaviour and not the actions of any one person. It differs from online advertising, which might track you individually.
For example, take our campaign planning tool RADAR View. This uses aggregated, anonymized snapshots of sample groups of people that have a) agreed to share certain information about themselves with advertisers, for various reasons, including location data and then b) walked past our panels with their mobile device recently. This sample data does originate from that consensual personal data, but it is stripped of identifiers, and grouped together by a third-party data provider– they package it up for various purposes, including for advertisers.
Then, with that aggregated sample set, we can help advertisers identify the best billboards for them to roll-out their campaigns on and reach their target audience group. For example, we can tell a coffee shop that they are advertising coffee in an area where the sample people are telling us they prefer to drink tea.
Can RADAR be used to target individuals?
No! Think of it more like TV viewing figures, which are based on samples. Those samples do inform what we watch, but on a macro scale, not at each individual level.
It’s really important for me to stress here that the data that powers RADAR View does not contain any identifying information of any individual, is not collected in real time, nor does it identify individuals or provide personalized advertising. You do not have to be included in these sample sets: and can turn off the consent on your phone and app settings at any time.
My colleague Andy Stevens talks more about how the RADAR View tool works here if you’re interested in finding out more.
What about the cameras?
We very rarely use cameras, but when we do, it’s predominantly to record which adverts are displaying on billboards to report back to our customers. Some are also used for security to prevent our inventory from vandalism. In rare occasions, they can also be used for interactive ads. Wherever cameras are used, we have processes in place to ensure that any privacy risks are identified, and the relevant mitigations are in place to ensure compliance with applicable data protection legislation including GDPR.
How do you make sure you comply with GDPR when you use and collect data?
We build trust with individuals by providing transparent accessible information on how we do it, in our Privacy & Cookies Notice. We only choose suppliers and processors who meet our rigorous standards and can demonstrate compliance with applicable data protection laws and regulations in a manner that meets our requirements. We do this through due diligence processes, to understand privacy risks and mitigate against them, and then follow those with contractual terms setting out their obligations.
Can individuals find out what data Clear Channel holds about them?
Yes, individuals have a right to ask if Clear Channel is using or storing information about them. Clear Channel strive to be transparent and accountable about how we use data and assist with any requests for information made. If any individual wants to make an access request, they should contact the Privacy Office at email@example.com. Once we understand the individual’s relationship with Clear Channel, we will be able to provide information about whether data is held, how it is being used, who it is being shared with and where we got the data from.
For more information on the personal data we collect, check out our Privacy and Cookies Notice on our website.