Many of you have raised concerns about the legality of the system.
To make clear: Yes, our technology complies with the Data Protection Act, RIPA and other applicable UK laws.
As some background, we¹ve spent a long time developing our technology, systems and practices as regards privacy protection. We believe that most people like personalisation online. We just don¹t believe they should have to give up their personal data to get it. And that philosophy has informed the development of our entire system.
There are three main hallmarks to the system: we don¹t know who you are, we
don¹t know where you¹ve been and participation is always a choice.
We have walked several experts though our service from Ernst & Young and 80/20 Strategic Thinking to the Home Office, which is responsible for the application of RIPA. Also, you should be aware that we have spent an enormous amount of time, as have our ISP partners, verifying that all of our activities are fully compliant with all regulation. I believe that it is reasonable to suggest that if BT, Virgin and Carphone Warehouse are all participating, it is because they have fully satisfied themselves of the legality of their decision.
Unlike other online advertising products, the service doesn't store personally identifiable information, doesn't store IP addresses or retain browsing histories. So it can't know who you are or where you've browsed. The ISP will not be passing any personal information to Phorm. We do not tie into their authentication systems or use any subscriber information. Plus, users choose - they can switch the system off or on at anytime.
On the privacy front we are one of the few online companies that would welcome a decision by the Article 29 Committee to rule on IP addresses being categorised as personal data. I don't need to point out how unusual that is.