Last week Mozilla announced the availability of a Do-Not-Track setting in the mobile version of Firefox. Although not yet honored by more than a few companies, seeing this implementation reminds me of how the mobile paradigm may require a very different approach to tracking control. It’s worth asking: Will the ad-industry’s tracking choice framework — built around an ad-based icon that leads to cookie-based choices — be relevant in the mobile world? I see at least two reasons to doubt it.
1. The icon offers a poor experience on mobile web pages.
On mobile devices, most web pages are either zoomed out, making the icon practically invisible and un-tappable, or zoomed in on the content rather than the ads. Certainly more and more publishers will design web pages specifically for smaller screens, and this will mean a new paradigm for ads. But it won’t help with the essential trade-off: Less space overall means less space for a disclosure icon and a notice-and-choice experience. It will also be difficult on mobile pages to present notice-and-choice overlays that don’t destroy the user flow; opening up choices in a new mobile browser window or tab will be awfully cumbersome.
2. Mobile applications will have a different choice framework.
Since mobile apps need to be individually installed by users, they have a built-in opportunity to obtain user consent for tracking activities in the app. This might take the form of an additional consent screen or checkbox; or at the very least, tracking activities will be disclosed in the app-store description of the program. For some ad-supported apps, accepting targeting may be a condition to using the app; for others, behavioral tracking might be something that can be turned off separately in the installation process, still allowing non-behavioral ads.
Do-Not-Track on Mobile Firefox
The broader point is that users have come to expect mobile settings to be simple and universal, like the mobile Firefox Do-Not-Track switch. Piecemeal disclosure and choice within mobile apps, tracker-by-tracker, would fall too far short of user expectations to be taken seriously by consumers (or regulators) in the long run.
It also matters that the method of storing tracking preferences in apps will need to be different, since ads in apps don’t tend to use cookies like browsers do. Instead apps identify the device through locally stored files or by using the device’s unique identifier. This means that the cookie-based opt-out framework can’t easily be bolted on to mobile ads in apps.
It’s surprising that, despite the raging debate about how best to implement tracking choice on traditional computers, there has been little discussion about how things should work on mobile devices. When a framework does develop, the form factor and user expectations on mobile probably mean that the “power-i” approach is not a good fit. As a result, mobile requirements may move the entire choice framework, across all computers and devices, in the direction of Do-Not-Track switches.