By Isabella De Michelis di Slonghello

The European General Data Protection Regulation (GDPR), which came into force in May 2018, has imposed a whole new framework for companies using personal data. Companies, in response, have started putting in motion IT strategies that protect their businesses from regulatory risks.

Because the GDPR has put a strict requirement on consent proof for digital advertisement platforms in particular, we see the effects, like forcing companies to change their business models, Google and Facebook included. These changes impact also voice assistants like Alexa and Cortana.

But companies have not really changed their approach to data mining. Their ravenous appetites for consumer data continue to grow following the surge of Internet of Things and artificial intelligence (AI)-based platforms opportunities.

The paradox is that with strict privacy regulations coming into force, including outside Europe, inspired by GDPR’s overarching principle of “privacy as a right”, these companies can achieve their data gathering and consumption objectives at almost no cost, unless some disruption happens in the market. ErnieApp has decided to invest in a mission, which is to curb this trend!

Turning upside down the relationship between users and service providers (to give more control to users like ad-blockers do) or storing your personal data in a third-party database had always been the standard approach taken by various privacy-by-design companies to win user engagement. But it has proved not to work so well (except for ad-block solutions).

Users dislike changing their behaviours on-line if this is calling them to re-route their personal data into another party database. Despite the Cambridge Analytica scandal and several other high-profile privacy breaches, Facebook saw its ad revenues and the average time spent on its application grow. They have done so for two prominent reasons: first, people are not seeing the value of the data they share and second, people prefer to keep the data where they are, rather than relocating them.

Our approach
Differently from everybody else, we considered that only disrupting directly the business-to-business relationships between Internet companies would trigger a meaningful change. And that such disruption could only be driven by users, if actioned appropriately.

We set up a new, automatable and scalable scheme to trigger a new competition lever onto digital companies and have it homed in a mobile native app (usable also by non-digitally skilled users). We called the app ErnieApp and the service provided via the app a PKM or “Privacy Knowledge Manager”. A PKM service for end-users would come in three levels (BASE, CUSTOM and PLUS) where the PKM BASE should always be free (privacy as a service) and the two others as a freemiums (consent as a service).

With ErnieApp, if companies want to process qualified consumer personal data (meaning data for which the legal basis for processing is based on express or explicit consent), they must enter into a competitive race and bid to convince the users to maintain the adequate level of permission for as long as possible.

Key features
To facilitate user decision comprehension of the scheme and help user decision making process we combined in the app three bundled features: a proxy indicator, a privacy configurator and a game.

The proxy indicator is called the “Openness Index”. This is a meter reading in app that appears as soon as the user has added any third-party service in their dashboard. The Openness Index is a personal computed metric. It gives to an individual a proxy indicator to help them understand how generous they are with their personal data sharing toward certain applications (probably those he/she uses the most daily).

The privacy configurator, which starts functioning as soon as the user adds their first third-party account, allows the retrieval of third-party service privacy settings and their visualization in a single view. By visualizing the settings among different services, a user can compare the settings and derive which company is more privacy-friendly. User can then manage privacy settings in order to build a consistent consent policy across multiple services.

When the PKM BASE was launched, in February 2019, we launched the support for the privacy settings of Google Search, Maps and YouTube, Twitter and Facebook to begin. We then expanded the support for LinkedIn, Spotify and Netflix. We plan to add more in the near future. Users shall feel the power of controlling the privacy settings across all these popular apps and also become aware that all these apps need the users’ express consent to use their data for digital marketing purposes.

The game is rather a gamification experience than a video game for now. Users make a journey through a map; to advance they need to answer quizzes across several playgrounds (playgrounds mimic different settings where the user can identify him or herself, like outdoor or indoor). When he or she answers correctly, they accrue tokens and pass the level so that they can attain a certain status, plus they also redeem tokens in a prize draw. The game narrative is focused on the Internet and how it functions, main business models, technologies and players that coexist and compete, along with consumer rights, laws and regulations. By playing the game a user elevates his or her knowledge both as regarding privacy and how to best manage their consent as a tradable asset.

Responses, challenges and developments
We have received excellent feedback since our launch. It is interesting to note that most of our users love the game and rated it 5 star’s in market surveys; people say they learned interesting staff while having fun. People also scored high (4.5 star’s) the service novelty as the privacy configurator is very easy to use and gives them an immediate visualization of the changes when they implement them.

Not surprisingly, people expressed also discontent when they discovered that companies implement very different privacy settings on their apps and that no common taxonomy or standards exist in this space. Or that some companies do not have privacy settings at all

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. We at ErnieApp think there is a good opportunity here to build wide user consensus that privacy settings are needed and should be easy understandable. For example, we have started an online petition on Change.Org to make opt-in/opt-out features more accessible by consumers.

One of our biggest challenges when we designed our app was to identify the target “persona”. Would a PKM service be attractive for specific age segments? Gender? Geographies? Or would it have the potential to become a universal service? It’s a bit too early to give an answer to this question, but our analytics indicate there is not much difference between how the app is used in Europe and in U.S. or in other countries at the moment we speak. People like the user experience we offer, and they appreciate the increasing features approach we propose in the app.

This summer we plan to localize the app in Italian and possibly in French. We plan to add new countries where the app will be available, add additional supported third-party services privacy settings, upgrade game content and add new features which will make the user more powerful in their negotiation tactics with Internet service providers.

Isabella De Michelis di Slonghello is ErnieApp ( CEO and founder. Prior to that she founded High Pulse, a strategy consulting company focusing on advising private and public clients on broadband and digital transformation projects. She has also served as group vice president, government affairs at Qualcomm, managed European public affairs for Cisco Systems and worked for Telecom Italia, Telespazio and for Elsacom (a Finmeccanica company).

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