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A couple weeks ago I submitted submitted public feedback on the IAB Tech Lab’s proposed ID-Level Data Transparency Standards. IAB’s Taxonomy sets forth new metadata standards for online advertising being deployed later this year. In other words, the Taxonomy is poised to define how advertisers identify and define audiences.

These new audience standards are a game-changer – a new kind of standardization for online ads that aims to change the way audiences are organized on a global scale.

This standardized way to describe groups of people and audiences is being deployed by all the major advertising companies and hundreds of smaller advertising networks. Essentially the global supply chain of advertising is adopting a standardized way to target and auction ads to groups of people.

So the list of ways to describe people is very important… and very powerful.

If an interest group is not recognized (i.e., excluded from) the final ID-Level Data Standards, there won’t be an easy way for that group to target advertising to each other. Advertisers will need to use audience amalgamators and other techniques that increase externalities and costs to reach them, if at all — essentially an “excluded data property tax” that, in fact, serves no real benefit.

Imagine the impact of being excluded from online organizing if you were a member of a persecuted minority religion, or a political party with only a few seats at the national level of your government, or part of a non-traditional family. The list is endless. If online advertising were able to describe someone as being without a permanent home, it would be easier for organizations to provide services to those individuals and improve support and product marketing to their clients.

It’s clear there could be a significant impact on communities through their inclusion in audience segments – and there are also opportunities to better serve larger communities by looking to existing schema, and apps and websites that have already described people and the products they love in unique and helpful ways.

With the principles of inclusion, visibility, and market efficiency in mind, I submitted the below proposal to the IAB during their public comment period on the Taxonomy which ended July 16th, 2018. My high-level feedback outlined emphasizes the need and importance of creating guidelines for why properties are included, and suggests using Wikipedia or other public schema as guidelines for inclusion.

Public Comment to the IAB (Previously Submitted) for the ID-Level Data Transparency Standards

Feedback on the proposed IAB ID-Level Data Transparency Standards.


This message summarizes my proposed metadata, which is also listed in the Google Sheet available via this link. The Spreadsheet consists of three tabs: (1) my suggested additions (with some notes); (2) a complete list of the initial “Standardized Audience Taxonomy” from IAB, including my suggested additions, highlighted in green; and (3) the Wikipedia URLs for “Political Parties by Country,” which I believe are consistent with emerging legal trends in Europe that seek to extend anti-discrimination laws beyond the employment sector, see Part III below.

In total, I have suggested between 200-300 additions for the taxonomy. If you include only the non-political party categories, it is approximately 100 additional metadata properties.

Beyond the particular line-item schema I have suggested adding to the Taxonomy, I also believe IAB should publish governing protocols and/or bylaws that explicitly address the procedures for amending the Taxonomy and providing notice to companies who utilize the Taxonomy in processing metadata. As discussed in more detail in Part II, these protocols and/or bylaws will be critical to ensuring IAB’s transparency, inclusiveness and relevance, and most importantly to companies implementing the standards, the known-process would help to provide time for companies to comment if proposed future changes conflict with applicable anti-discrimination policies. 

I make these suggestions based on my decade-plus experience as a digital strategist in both the public and private sectors. My experience includes over 15 months on President Obama’s digital and new media campaigns in 2007, research on behalf of former New York Mayor Michael Bloomberg’s reelection campaign and directing digital strategy for Houston Mayor Bill White’s 2010 Gubernatorial campaign. Through my consultancy, Victory Medium, I help to optimize private sector marketing and advertising campaigns and provide services to a variety of businesses, spanning a wide range of industries including technology, health and medicine, literature and art, and food products.


The fundamental principles of inclusion and representation guide my suggested additional categories for the Taxonomy. IAB’s Taxonomy has the power to render categories of people visible (or invisible), to reinforce (or subvert) existing institutions, discourses, and power structure. Thus, on a philosophical level, I have drafted suggestions to promote maximum representation and inclusion, in a transparent and open way. 

I applaud and support IAB’s public comment process, which invites self-reflection on internal and implicit biases through an open and public dialog. This is no doubt a critical step in reducing the impacts of implicit biases on the final Taxonomy. This process is also consistent with the proposed EU Directives that promote equal treatment and dignity of persons within and beyond the employment sector and provides a new platform for a dialog to discuss the existing patchwork-quilt regulations around the world for individual rights and exposure for infringement. 

In addition to the specific line items I have proposed, I also believe the IAB Taxonomy would benefit from clearly written protocols or bylaws that govern how and when amendments to the Taxonomy can be added or amended, and how they will be communicated to companies who rely upon the IAB Taxonomy and have potential exposure for the implementation of those standards. Clear governing protocols that drive toward the principles of both inclusion and transparency also comport with EU policy goals (and current pending proposals in EU) (and existing laws in other countries) in support of equal treatment and dignity of individuals.


Since 2008, the EU has considered various drafts of a Proposal for Directive on Equal Treatment (the “Proposal“), which, if implemented, would impose a broad range of anti-discrimination and pro-equality obligations beyond employment. The EU Proposal in its current form would mandate the equal treatment of persons irrespective of “of religion or belief, disability, age or sexual orientation outside the labour market.Several of the proposed categories of IAB metadata include the protected classes under the current Proposal, and indirectly implicate many more, depending upon how broadly the anti-discrimination classes are construed.

Given the EU’s stated commitment to promoting equal justice and dignity, social inclusion, and ending discrimination and the EU’s increasingly progressive position on regulatory policy, it would be a prescient decision to bake inclusion and representation principles into the IAB ID-level data segment taxonomy so that we harmonize taxonomy goals with emerging EU policy. 

Furthermore, as detailed by an extensive 2013 report from the World Bank, anti-discrimination and equality protections creating different protected classes of individuals are already enshrined in many constitutions, with national and international law both trending toward more pro-inclusion directives. In Kenya, their modern Constitution states, “Discrimination is prohibited on the grounds of race, sex, pregnancy, marital status, health status, ethnic or social origin, color, age, disability, religion, conscience, belief, culture, dress, language or birth.” 

The report from the World Bank also highlights numerous efforts in the EU to protect minorities that could potentially create exposure even if the 2008 Proposal isn’t implemented, concluding, “Also of importance is the EU Charter of Fundamental Rights, particularly Article 21 which prohibits any discrimination based on any ground such as sex, race, color, ethnic or social origin, genetic features, language, religion or belief, political or any other opinion, membership of a national minority, property, birth, disability, age or sexual orientation.”

One way to help insure IAB is building upon inclusionary principles would be to create an “Equal Treatment Metadata Working Group” — a dedicated body committed to reviewing potential biases in the Taxonomy, recruiting new voices for participation in IAB standards, and providing a feedback loop for any updates to the taxonomy that could impact businesses who have already deployed the standardized taxonomy in their supply chains.

Currently, the IAB taxonomy has artificially limited properties for minority political parties, social beliefs and minority religions. In the current proposed Taxonomy, metadata properties for “Demographic: Political: XXX” consist of only five political groups, “Liberal, Moderate, Conservitive, Independant, Green.” This is patently inadequate.  First, the Taxonomy appears to blend political ideology with political party. Second, even if limited to political ideology, the five existing categories leave massive gaps and fail to apply across different countries. Third, as presently drafted, the current categories have different meanings in different countries and different contexts. I suggest dramatically expanding this taxonomy to separately account for a political party as separate and distinct from political beliefs (or ideological/social beliefs). 

For political parties, I propose that the IAB creates a new rule that provides that political parties will be added to global metadata Taxonomy for every country in the world as soon as that party controls one federal or parliamentary seat of any kind within that government, and as documented and maintained by Wikipedia on their list of political parties by country resource page.” A similar policy could also be considered for organized religions and social groups, although some may present difficulty with articulating an objective standard for the threshold for representation in the Taxonomy. 


Gender | Non-binary/ third gender | 

Gender | Prefer not to say |

  • HRC and other organizations have written extensively about Gender options, and the choice “Prefer not to say” is considered just as valid as “Male” or “Female” or other choices. The word “Other” should also be potentially supplemented with “Non-Binary” and/or “Third Gender” as it is the preferred choice for some individuals. 

Household Data | Property Type | Working Farm | 

Household Data | Property Type | Mobile Home | 

Household Data | Ownership | Homeless | 

  • Inclusion of non-traditional and non-urban household types is essential for their visibility and inclusion in services. In most major urban areas, there are “Homeless counts” and other services provided to the homeless, and the vast majority of homeless people still own a modern cell phone. To reduce the stigma of this “Homeless” metadata property, it could be described as, “Not Currently Housed at Permanent Address.”
  • The inclusion of these three new types of households could have untold impacts on the services provided to certain individuals that could potentially be protected under various laws. Also, the lack of a classification for a family operating a Working Farm impacts banking and agriculture services and the types of financing opportunities available in most jurisdictions.

Household Data | Median Home Value (USD) | $0-$24,999 | 

Household Data | Median Home Value (USD) | $25,000-99,999 | 

  • Homes in India and many high-tech developing countries cost significantly less than Europe and the United States. In order to properly reflect the global price of houses and the differences in middle class home values in other countries, two or more new Taxonomy categories could be considered.

Political | Vote In Last 2 Elections | 

Political | Vote In Last 3 Elections | 

Political | Vote In Last 4+ Elections |

  • All modern political campaigns segment their voters with turnout propensity scores, and it significantly impacts the advertising costs. In the United States, and provide core voter data for the majority of Democratic and Republican campaigns, and many partners working in their ecosystem provide propensity scores that include multiple elections to ensure that “guaranteed voters” aren’t over-targeted. Individuals who have voted in 3+ and 4+ of the last elections are typically removed from targets or targeted in very unique ways. The larger advertising ecosystem should also adopt these data standards to provide advertisers the data needed to save costs on political advertising.

Books and Literature | Religion & Spirituality |

  • This is a significant genre in the industry of books and literature and reflects sectarian/spiritual interests that have both significant marketing/audience implications, as well as religious/social inclusion implications. 

Business and Finance | Business | Business Banking & Finance | Blockchain & Cryptocurrency |

Technology & Computing | Computing | Blockchain and Crypto |

  • I suspect other folks suggested similar metadata, blockchain & crypto, but these are major emerging markets and should be reflected. 

Business and Finance | Industries | Non-Profit Organizations | Electoral Politics & Politicians |

  • Non-profit organizations don’t have the same disclaimer requirements as non-profit organizations working in electoral politics and the interest in nonprofits doesn’t correlate to an interest in politics. These should be segmented in some way, particularly with Facebook’s new rules for political advertisements that don’t impact a non-political nonprofit.

Education | Education Policy | 

Education | Homeschooling |

  • Two minor additions, with the “Homeschooling” addition included due to the fact that in some jurisdictions the right to homeschool a child has been enshrined as a protected belief (usually under protections for religion).

Family and Relationships | Divorce and Separation |

  • Minor addition that provides an important targeting criteria for services.

Food & Drink | Food Delivery Services | 

Food & Drink | Food Entertainment and Television | 

Food & Drink | Food Entertainment and Television | Anthony Bourdain |

  • Two minor additions, and then a suggestion for one taxonomy, “Anthony Bourdain” to help explain to publishers and the larger public the concept of taxonomy ID-standardization, and how they could take every article they wrote about Bourdain, and using the standards, append data to every user who views that article a special tag showing their interest in Bourdain. I chose Bourdain because of the amount of articles written in a multitude of languages, and the global search volume for his name, and because he did a great job at connecting people over common interests – very similar to the goals of this taxonomy standardization from the IAB.

Healthy Living | Health Coach | 

Healthy Living | Wearables and Health Tech |

  • Two minor additions that are popular advertising targeting criteria.

Hobbies & Interests | Vaping and Electronic Cigarettes | 

  • Vaping is an industry growing much faster than Cigars and some of the other included interests. 

Movies | Music and Musical Movies | 

Movies | Sports Movies | 

Movies | Critics Picks Movies | 

Movies | Faith and Spirituality Movies | 

Movies | Classic Movies |

  • Several movie categories used by Netflix not included in the initial metadata.

Music and Audio | Talk Radio | Podcast |

  • Distinguishing online talk radio through a new “Podcast” format. 

News and Politics | Online News and Blogs | 

News and Politics | Politics | Immigration | 

News and Politics | Politics | Tax and Revenue Issues | 

News and Politics | Politics | Healthcare and Insurance | 

News and Politics | Politics | Technology and Data Issues | 

News and Politics | Politics | Healthcare and Insurance | 

News and Politics | Politics | Criminal Justice Issues | 

News and Politics | Politics | Workplace Policies | 

News and Politics | Politics | Election Issues | 

News and Politics | Politics | Housing Issues | 

News and Politics | Politics | Food and Agriculture Issues |

  • An inclusion of new political/policy issues to ensure that any protected classes and interests are not ignored. It’s possible this list also needs to be expanded and considered a potential legal exposure for companies implementing the standards.

Pets | Ferrets, Rabbits and Small Animals |

  • In the U.S., ferrets are the 3rd most popular pet in some areas, and small mammals should potentially be given a unique property due to the unique products associated with the animals. 

Religion & Spirituality | Islam | Shiite | 

Religion & Spirituality | Islam | Sunni |

  • The inclusion of a unique “Shiite” and “Sunni” sub-category for “Islam” is an extremely important distinction that further raised issues with the proposed Religion & Spirituality inclusions. This is almost like merging Christianity and Judaism into some larger “Jesus-based religions” – it doesn’t provide the correct information and would cause problems at scale.

Video Gaming | Video Game Genres | Retro Games | 

Video Gaming | Video Game Genres | Voice Control Games | 

Video Gaming | Video Game Genres | Turn-Based Games | 

Video Gaming | Video Game Genres | Female Protagonist Games | 

  • These four video game categories were modeled off video game categories. The inclusion of “Voice Control Games” is important for differently-abled gamers, and both “Retro” and “Turn-Based” games have grown in the last few years significantly. The inclusion of “Female Protagonist Games” is important to many members of the gaming community, and those categories in apps like Steam should be modeled by IAB.

Consumer Packaged Goods | Food and Beverages | Vegetarian Foods | 

Consumer Packaged Goods | Food and Beverages | Vegan Foods | 

Consumer Packaged Goods | Food and Beverages | Meal Replacements and Shakes |

  • It’s essential to respect the ethical decisions of Vegetarians and Vegans, and potentially even provide Kosher and other religious-food-preferences.
  • The inclusion of Meal Replacements and Shakes is a long-needed targeting criterion for people with disabilities who cannot eat solid foods, sometimes as a matter of diet (e.g., bariatric surgery candidates and patients) or sometimes as a matter of physical disability.

Consumer Packaged Goods | Back to School Supplies | Clothes | 

Consumer Packaged Goods | Back to School Supplies | School Supplies | 

  • Minor distinction to segment “Back to School Supplies” – technology purchases could also be potentially segmented here to further provide a clear difference in shopping behaviors. 

Finance and Insurance | Insurance | Agriculture Insurance | 

Finance and Insurance | Insurance | Flood Insurance | 

Finance and Insurance | Insurance | Liability Insurance | 

Finance and Insurance | Insurance | Travel Insurance | 

Finance and Insurance | Insurance | Workers Compensation Insurance |

  • There were several large-categories of insurance not included in the initial proposed taxonomy – a much larger list with dozens of additional types can be found on Wikipedia. In some jurisdictions, access to health insurance and other types of insurance creates protected classes of individuals – it’s my opinion that Insurance taxonomy should be potentially expanded to over-cover all types of insurance. 

Health and Medical Services | Digital Addiction |

  • The big 4 tech companies are developing products for Digital Addiction and many mental health professionals already provide supportive services for digital addiction, while the DSM-V has identified “Internet Addiction” as a “Condition for Further Study,” which also may raise potential disability and inclusion issues in the future

Legal Services | Legal Aid and Civil Liberty Services | 

  • Access to free legal services, and legal protections for the poor is oftentimes a protected status — the “Legal Services” taxonomy should potentially be expanded to address these distinctions.

Life Events | Adoption |

  • Adoption is protected as a triggering event in many different sectors and different countries, from insurance to family leave, and should be reflected to ensure that adoptive/non-nuclear families are adequately represented by the Taxonomy. 

Sporting Goods | Outdoor Recreation Equipment | Scooter Rental |

Travel and Tourism | Homeshare and Short Term Rentals | 

Travel and Tourism | Scooters and Personal Transportation Rentals |

  • Scooter rentals and home sharing are billion-dollar industries – metadata standards should reflect that in some way.


What else is missing from the proposed IAB ID-Level Data Standards? What have other schemas done to reduce bias or should be done with the IAB standards?

Remember…the end goal is always trying to prevent the worst version of the internet…

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