In June 2019, the ICO issued a scathing report describing the use of interest-based advertising (IBA) in Adtech and Real-Time Bidding (RTB) as “disproportionate, intrusive and unfair”.(1) It gave the Adtech industry six months to get its digital house in order. Updated cookie guidance swiftly followed, confirming the need for opt-in, GDPR-level consent before dropping cookies or using other online tracking techniques, and hinting at cookie sweeps.(2)

The time for a privacy-first, digital marketing strategy, it seemed, had arrived. Brands would need to take a user-centric approach, respecting end-user privacy and ensuring a fair value exchange while pursuing their objectives. They would need to build Privacy and Data Protection by Design (DPbD) into their digital marketing activities.