Why should I?

In keeping with the Web 2.0 approach of going where the people are, the use of online advertising on popular commercial websites is being considered and pursued by agencies.

Government advertisements (ads) on commercial websites are being used to:

• promote government services
• deliver government information
• deliver messages to specific segments of the Australian population, by  advertising on websites relevant to and popular with target audiences.

Some agencies are already placing online ads on web-based mediums such as:

• search engines
• social networks
• news websites
• popular blogs and
• content selling and sharing websites (including sites that host music, movies, videos, photos and software).

What should I do?

All Australian Government online information and web content, including online advertising, must meet the mandatory requirements of the Web Guide, including:

• Branding
• Accessibility
• Privacy
• Risk assessment

Meeting these requirements will help ensure compliance with current policies, legislation and guidelines.

The Central Advertising System (CAS)

All Australian Government departments and agencies subject to the Financial Management and Accountability Act 1997 (FMA Act) are required to place their advertising (including online advertising) through the Central Advertising System (CAS). The Communications Advice Branch (CAB), Department of Finance and Deregulation administers the CAS, which consolidates government advertising expenditure to secure optimal media discounts on Commonwealth-wide media rates.

In addition, agencies subject to the FMA Act undertaking any government information and advertising campaigns must comply with the Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies (March 2010).

australia.gov.au

The CAS requires government advertising campaigns to use australia.gov.au followed by the campaign name, as the web address for the campaign, for example, www.australia.gov.au/campaignname.  The campaign name should easily identify the individual campaign and may be its ‘call to action’, for example, measureup.

Ads using australia.gov.au must be branded to feature the website address: www.australia.gov.au/campaignname. Further information is provided at Advertising campaigns and australia.gov.au.

How do I?

Types of online advertising

Types and formats of web-based ads include:

Banner ads

• static banner ads
• animated banner ads
• sidebar/skyscraper banner ads (static or animated)
• pop-up/pop-under banner ads (static or animated)
• pull-down banner ads (static or animated)
• floating  banner ads (static or animated).

Search engine advertising

This works by serving ads, which are related to the user’s search terms, on search engine pages. These ads are known as sponsored links. There are variations on this type, but the general approach is typified by the Google AdWords product.

Internet video advertising

These include ads in videos on video sharing sites, such as YouTube, as well as streaming video in banner ads.

Branding

Online advertising should comply with the Australian Government Branding requirements where possible. However, due to the size of typical online ad, it is not always possible or practical to include the Australian Government Design (the Design). Agencies should consider the checklist below.

Branding checklist

• When applied, the Design must always comply with the size, colour and positioning requirements.
• Agencies should use the Design where possible, but may not if the size or format of the ad does not allow for the correct application of the Design. One benefit of including the Design is that it ensures the ad is quickly and easily recognised as Australian Government content. Agencies should consider this when deciding whether to include the Design.
• If agencies choose not to include the Design in an online ad, they must include the Uniform Resource Locator (URL) of the Australian Government web page the ad links to (preferably a gov.au URL). This is intended to help users distinguish between ‘real’ government content and fraudulent or misleading content.

Accessibility

Agencies must also comply with the mandatory Accessibility requirements of the Web Guide. In particular, agencies must comply with the following checklist.

Accessibility checklist

• Use meaningfully named links that describe the purpose or destination of a link. For example, using the name of the linked website , for example ‘visit the Swine Flu Outbreak website for more information’ presents more meaning than a link that reads ‘more information’.  Do not use ‘click here’.
• Ensure content will not cause seizures. Imagery should not flash or blink more than three times per second, or five times in total without a way to pause or stop. Red flashes or blinks should not be used at all.
• Ensure strong colour contrast is used to help identify foreground from background. Logotypes and text above 18pt is not included, but all other elements should have a minimum contrast of 4.5:1.
• Don’t use sensory elements as references (e.g. colour, size or shape).
• Make sure content is legible (minimum font size suggested at 8pt).
• Especially for static images: Use alternative text that presents the same or equivalent important information. Preferably achieved through the ‘alt’ attribute in HTML, otherwise provided on the linked (destination) webpage.
• Especially for dynamic images and/or animations: Provide a redundant text link to the webpage for when applets or scripts are turned off or cannot be interpreted by assistive technologies. The webpage must host the same information as in the multimedia content, in an accessible format (such as text description).

Privacy

The interactivity of web advertising and its ability to track users makes it intrinsically intrusive. Agencies must comply with the Privacy Act in respect to their use of the web. The Privacy Commissioner’s Guidelines for Federal and ACT Government Websites are also a mandatory requirement of the Web Guide. These Guidelines require agencies to incorporate appropriate privacy statements on their websites advising what information is collected, how this information is used and if and to whom it may be disclosed.

This information includes clickstream data and information collected by cookies. These requirements also apply to information collected by agency ads hosted on other websites.

While click stream data and information collected by cookies may not, on its own, constitute personal information within the meaning of s.6(1) of the Privacy Act,  in some circumstances, this information may be able to be combined with other information to become personal information. To deal with this uncertainty, the Privacy Commissioner’s Guidelines require that notice of the collection of click stream data and information collected by cookies be included in the website privacy statement.

If space permits, the agency may wish to provide a privacy statement in the layered notice format on the third party hosted ad.  Alternatively, the agency may wish to provide a link in the ad to the privacy statement on the agency website.

If the agency ad, hosted on the third party website, directly collects personal information from individuals then Information Privacy Principle 2 (IPP 2) requires that a notice be given by the agency, covering the following matters:

• the purpose for which the information is collected
• specify any law which authorises or requires the collection
• specify the person, body or agency to whom the agency usually discloses the information
• if known to the agency, to whom the recipient usually discloses the information.

It may not always be apparent whether a particular online ad actually collects personal information, or other information that is combined to form personal information. Where this is unclear agencies should conduct a Privacy Impact Assessment (PIA) to determine whether or not this is the case.

An agency IPP 2 notice can be incorporated in the condensed or layered privacy statement with careful drafting.

If a commercial organisation (such as an ad network) collects personal information on behalf of an agency, then that organisation must comply with the National Privacy Principles (NPPs) in the Privacy Act, particularly the notice provision in NPP 1.3.

Technical approaches to tracking

There are several technical approaches employed to tracking consumer response to web advertising. These include:

• cookies
• web bugs
• JavaScript
• databases of user interactions
• Ad networks that serve ads to multiple websites and employ complex algorithms to infer relevance to the interests and preferences of web users.

These technical approaches generally allow advertisers to record and analyse patterns of user behaviour and interaction with web ads. They also allow the identification of repeat users. While this may not involve the identification of a user by name it does permit advertisers to identify the same user returning to a website and to differentiate users from each other. Ads on social networks such as Facebook and MySpace may record the name of the user on whose home page ads are served. This information is recorded and analysed in sophisticated online databases.

Unlike print and broadcast media advertising, online advertising tracks user behaviour in real time. As a result, internet advertising is more targeted than print and broadcast advertising. Tracking may deliver relevant advertising to users but it also monitors and measures the behaviour of users for the benefit of advertisers and their clients. The effectiveness of online advertising can also be assessed through campaign tracking research and analysis of call centre data.

Privacy checklist

• Establish whether the proposed online advertising collects personal information as defined in the Privacy Act. This may be done by tracing the information flows as part of a PIA.
• If personal information is collected include an IPP 2 statement in the agency’s website Privacy Statement addressing the collection of this personal information.
• If personal information is not collected include advice in the agency’s website of what information is collected by online ads.

Risk assessment

As well as Privacy Impact Assessments, more general risk assessments should be conducted by agencies considering the use of internet advertising. Some non-privacy related risks are discussed below.

Consumer Issues

Most browsers allow users to block pop-up ads and cookies and some will block other forms of online ads. Other applications and browser plug-ins such as Readability and Ad-blocker allow consumers to view web pages free of ads. This may mean that the use of web ads (or certain forms of them) may be ineffective because users may block them and their cookies.

Inappropriate association

In the Online video guidance in the Web Guide the risk of inappropriate association is discussed.  The relevant text is quoted below.

Users have no control over the trailer videos advertised on the site. This can lead to your video being linked to inappropriate content, or content which contradicts the message your video conveys. For example a video about binge-drinking may be followed by a spoof video promoting drunkenness. Trailer videos are suggested to users on the basis of similar keyword tags used to describe the video. The experiences so far from other government agencies indicate this is sometimes not helpful and can result in contrary messages or unrelated content on the same page.

Similar risks in respect to government ads on commercial websites may occur where the ads are co-located on a web page with products or messages which are inconsistent with the message being promoted.

Security risks

The widespread use of government ads on commercial websites may invite the spoofing of such ads as part of phishing and other exploits. There are many documented scams and other security risks associated with the internet advertising industry and online ads can also deliver malware.

Risk assessment checkpoint

When considering the use of online advertising agencies should conduct a risk assessment and consider risks related to consumer issues, reputation and security risks.

Subjects:

• Advertising
• Commercial websites