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Phorm, formerly known as 121Media, was a digital technology company known for its
contextual advertising Contextual advertising is a form of targeted advertising for advertisements appearing on websites or other media, such as content displayed in mobile browsers. In context targeting, advertising media are controlled on the basis of the content of a ...
software Software is a set of computer programs and associated documentation and data. This is in contrast to hardware, from which the system is built and which actually performs the work. At the lowest programming level, executable code consists ...
. Phorm was incorporated in
Delaware Delaware ( ) is a state in the Mid-Atlantic region of the United States, bordering Maryland to its south and west; Pennsylvania to its north; and New Jersey and the Atlantic Ocean to its east. The state takes its name from the adjacent Del ...
, United States, but relocated to Singapore as Phorm Corporation (Singapore) Ltd in 2012. Founded in 2002, the company originally distributed programs that were considered
spyware Spyware (a portmanteau for spying software) is software with malicious behaviour that aims to gather information about a person or organization and send it to another entity in a way that harms the user—for example, by violating their privac ...
, from which they made millions of dollars in revenue. It stopped distributing those programs after complaints from groups in the United States and Canada, and announced it was talking with several United Kingdom
Internet service provider An Internet service provider (ISP) is an organization that provides services for accessing, using, or participating in the Internet. ISPs can be organized in various forms, such as commercial, community-owned, non-profit, or otherwise private ...
s (ISPs) to deliver
targeted advertising Targeted advertising is a form of advertising, including online advertising, that is directed towards an audience with certain traits, based on the product or person the advertiser is promoting. These traits can either be demographic with a focus ...
based on the websites that users visited. Phorm partnered with ISPs Oi, Telefonica in Brazil,
Romtelecom Telekom Romania Communications (formerly known as Romtelecom) is a Romanian telecommunications company, which provides fixed voice, television and data services, for residential and business customers in Romania. As of 2020, Telekom Romania Commun ...
in Romania, and
TTNet TTNET A.Ş., operating under the Türk Telekom brand, is the largest Internet service provider in Turkey and has around 7 million subscribers. TTNET is a subsidiary of Türk Telekom Group. Currently, Mohammad Hariri is Chairman of the Board ...
in Turkey. In June 2012, Phorm made an unsuccessful attempt to raise £20 million for a 20% stake in its Chinese subsidiary. The company's proposed advertising system, called Webwise, was a
behavioral targeting Targeted advertising is a form of advertising, including online advertising, that is directed towards an audience with certain traits, based on the product or person the advertiser is promoting. These traits can either be demographic with a focus ...
service (similar to
NebuAd NebuAd was an American online advertising company based in Redwood City, California, with offices in New York and London and was funded by the investment companies Sierra Ventures and Menlo Ventures. It was one of several companies which origina ...
) that used
deep packet inspection Deep packet inspection (DPI) is a type of data processing that inspects in detail the data being sent over a computer network, and may take actions such as alerting, blocking, re-routing, or logging it accordingly. Deep packet inspection is oft ...
to examine traffic. Phorm said that the data collected would be anonymous and would not be used to identify users, and that their service would include protection against
phishing Phishing is a type of social engineering where an attacker sends a fraudulent (e.g., spoofed, fake, or otherwise deceptive) message designed to trick a person into revealing sensitive information to the attacker or to deploy malicious softwar ...
(fraudulent collection of users' personal information). Nonetheless, World Wide Web creator
Tim Berners-Lee Sir Timothy John Berners-Lee (born 8 June 1955), also known as TimBL, is an English computer scientist best known as the inventor of the World Wide Web. He is a Professorial Fellow of Computer Science at the University of Oxford and a profess ...
and others spoke out against Phorm for tracking users' browsing habits, and the ISP
BT Group BT Group plc (trading as BT and formerly British Telecom) is a British multinational telecommunications holding company headquartered in London, England. It has operations in around 180 countries and is the largest provider of fixed-line, broa ...
was criticised for running secret trials of the service. The UK
Information Commissioner's Office The Information Commissioner's Office (ICO) is a non-departmental public body which reports directly to the Parliament of the United Kingdom and is sponsored by the Department for Digital, Culture, Media and Sport (DCMS). It is the independe ...
voiced legal concerns over Webwise, and has said it would only be legal as an "opt-in" service, not an
opt-out The term opt-out refers to several methods by which individuals can avoid receiving unsolicited product or service information. This option is usually associated with direct marketing campaigns such as e-mail marketing or direct mail. A list of thos ...
system. The
European Commission The European Commission (EC) is the executive of the European Union (EU). It operates as a cabinet government, with 27 members of the Commission (informally known as "Commissioners") headed by a President. It includes an administrative body o ...
called on the UK to protect Web users' privacy, and opened an infringement proceeding against the country in regard to ISPs' use of Phorm. Some groups, including
Amazon.com Amazon.com, Inc. ( ) is an American multinational technology company focusing on e-commerce, cloud computing, online advertising, digital streaming, and artificial intelligence. It has been referred to as "one of the most influential economi ...
and the
Wikimedia Foundation The Wikimedia Foundation, Inc., or Wikimedia for short and abbreviated as WMF, is an American 501(c)(3) nonprofit organization headquartered in San Francisco, California and registered as a charitable foundation under local laws. Best kno ...
(the non-profit organization that operates collaborative
wiki A wiki ( ) is an online hypertext publication collaboratively edited and managed by its own audience, using a web browser. A typical wiki contains multiple pages for the subjects or scope of the project, and could be either open to the pu ...
projects), requested an opt-out of their websites from scans by the system. Phorm changed to an opt-in policy. According to Phorm’s website, the company would not collect any data from users who had not explicitly opted in to its services. Users had to provide separate consent for each web browsing device they used. Due to increasing issues, Phorm ceased trading on 14 April 2016.


Company history

In its previous incarnation as 121Media, the company made products that were described as
spyware Spyware (a portmanteau for spying software) is software with malicious behaviour that aims to gather information about a person or organization and send it to another entity in a way that harms the user—for example, by violating their privac ...
by The Register. 121Media distributed a program called ''PeopleOnPage'', which was classified as spyware by
F-Secure F-Secure Corporation is a global cyber security and privacy company, which has its headquarters in Helsinki, Finland. The company has offices in Denmark, Finland, France, Germany, India, Italy, Japan, Malaysia, Netherlands, Norway, Poland, Sweden, ...
. PeopleOnPage was an application built around their advertising engine, called ContextPlus. ContextPlus was also distributed as a
rootkit A rootkit is a collection of computer software, typically malicious, designed to enable access to a computer or an area of its software that is not otherwise allowed (for example, to an unauthorized user) and often masks its existence or the exis ...
called Apropos, which used tricks to prevent the user from removing the application and sent information back to central servers regarding a user's browsing habits. The
Center for Democracy and Technology Centre for Democracy & Technology (CDT) is a Washington, D.C.-based 501(c)(3) nonprofit organisation that advocates for digital rights and freedom of expression. CDT seeks to promote legislation that enables individuals to use the internet for pu ...
, a U.S.-based advocacy group, filed a complaint with the U.S.
Federal Trade Commission The Federal Trade Commission (FTC) is an independent agency of the United States government whose principal mission is the enforcement of civil (non-criminal) antitrust law and the promotion of consumer protection. The FTC shares jurisdiction ov ...
in November 2005 over distribution of what it considered spyware, including ContextPlus. They stated that they had investigated and uncovered deceptive and unfair behaviour. This complaint was filed in concert with the Canadian Internet Policy and Public Internet Center, a group that was filing a similar complaint against Integrated Search Technologies with Canadian authorities. ContextPlus shut down its operations in May 2006 and stated they were "no longer able to ensure the highest standards of quality and customer care". The shutdown came after several major lawsuits against
adware Adware, often called advertising-supported software by its developers, is software that generates revenue for its developer by automatically generating online advertisements in the user interface of the software or on a screen presented to the ...
vendors had been launched. By September 2007, 121Media had become known as Phorm, and admitted a company history in adware and stated it had closed down the multimillion-dollar revenue stream from its PeopleOnPage toolbar, citing consumers’ identification of adware with spyware as the primary cause for the decision. In early 2008 Phorm admitted to editing its article on
Wikipedia Wikipedia is a multilingual free online encyclopedia written and maintained by a community of volunteers, known as Wikipedians, through open collaboration and using a wiki-based editing system. Wikipedia is the largest and most-read refer ...
—removing a quotation from ''
The Guardian ''The Guardian'' is a British daily newspaper. It was founded in 1821 as ''The Manchester Guardian'', and changed its name in 1959. Along with its sister papers ''The Observer'' and ''The Guardian Weekly'', ''The Guardian'' is part of the Gu ...
s commercial executives describing the opposition they have towards its tracking system, and deleting a passage explaining how BT admitted misleading customers over covert Phorm trials in 2007. The changes were quickly noticed and reversed by the online encyclopedia's editors. Phorm currently resides in Mortimer Street, London, UK with staffing levels of around 35. Trading in Phorm's shares was suspended on London's AIM market on 24 February 2016, pending "clarification of the company's financial position". According to Phorm, it had been "unable to secure the requisite equity funding..." and was in "advanced discussions with certain of its shareholders and other parties regarding possible alternative financing..." and that there was "no guarantee" that such discussions would "result in any funds being raised. Pending conclusion of those discussions the Company has requested suspension of its shares from trading on AIM."


Financial losses

The company made a loss of $32.1 million in 2007, a loss of $49.8 million in 2008 and a loss of $29.7 million in 2009. 2010 was by no means better, with a net loss of $27.9 million By the end of 2010 the company had lost more than $107 million, with no perceivable revenue stream. In 2011, Phorm reported losses of $30.5 million and conducted an equity placing of £33.6 million, which paid off the company's debt.


Cessation of trading

On 14 April 2016 Phorm's Board of Directors announced to the London Stock Exchange that the company was ceasing to trade and that shareholders were unlikely to recover any of their investments. According to RNS Number : 2561Y FTSE 13 May 2016. Changes in FTSE UK Index Series FTSE AIM All-Share Index Effective From Start of Trading 18 May 2016 Phorm (UK): Constituent Deletion.


Proposed advertisement service

Phorm had worked with major U.S. and British ISPs—including
BT Group BT Group plc (trading as BT and formerly British Telecom) is a British multinational telecommunications holding company headquartered in London, England. It has operations in around 180 countries and is the largest provider of fixed-line, broa ...
(formerly British Telecom),
Virgin Media Virgin Media is a British telecommunications company which provides telephone, Cable television, television and Internet access, internet services in the United Kingdom. Its headquarters are at Green Park in Reading, Berkshire, Reading, Engla ...
, and TalkTalk (at the time owned by
The Carphone Warehouse The Carphone Warehouse Limited was a mobile phone retailer based in London, United Kingdom. In August 2014 the company became a subsidiary of Currys plc (previously named "Dixons Carphone"), which was formed by the merger of its former parent Ca ...
)—on a
behavioral targeting Targeted advertising is a form of advertising, including online advertising, that is directed towards an audience with certain traits, based on the product or person the advertiser is promoting. These traits can either be demographic with a focus ...
advertisement service to monitor browsing habits and serve relevant advertisements to the end user. Phorm say these deals would have given them access to the surfing habits of 70% of British households with broadband. The service, which uses
deep packet inspection Deep packet inspection (DPI) is a type of data processing that inspects in detail the data being sent over a computer network, and may take actions such as alerting, blocking, re-routing, or logging it accordingly. Deep packet inspection is oft ...
to check the content of requested web pages, has been compared to those of
NebuAd NebuAd was an American online advertising company based in Redwood City, California, with offices in New York and London and was funded by the investment companies Sierra Ventures and Menlo Ventures. It was one of several companies which origina ...
and Front Porch. The service, which would have been marketed to end-users as "Webwise", (in 2009 the
BBC #REDIRECT BBC #REDIRECT BBC Here i going to introduce about the best teacher of my life b BALAJI sir. He is the precious gift that I got befor 2yrs . How has helped and thought all the concept and made my success in the 10th board exam. ...
...
took legal advice over the trade mark Webwise), would work by categorising user interests and matching them with advertisers who wish to target that type of user. "As you browse we're able to categorise all of your Internet actions", said Phorm COO Virasb Vahidi. "We actually can see the entire Internet". The company said that data collected would be completely anonymous and that Phorm would never be aware of the identity of the user or what they have browsed, and adds that Phorm's advertising categories exclude sensitive terms and have been widely drawn so as not to reveal the identity of the user. By monitoring users' browsing, Phorm even says they are able to offer some protection against online fraud and
phishing Phishing is a type of social engineering where an attacker sends a fraudulent (e.g., spoofed, fake, or otherwise deceptive) message designed to trick a person into revealing sensitive information to the attacker or to deploy malicious softwar ...
. Phorm formerly maintained an opt-out policy for its services. However, according to a spokesman for Phorm, the way the opt-out works means the contents of the websites visited will still be
mirrored ''Mirrored'' is the debut studio album by American experimental rock band Battles. It was released on May 14, 2007 in the United Kingdom, and on May 22, 2007 in the United States. ''Mirrored'' marked the first album in which the band incorporated ...
to its system. All computers, all users, and all http applications used by each user of each computer will need to be configured (or supplemented with add ons) to opt out. It has since been declared by the
Information Commissioner's Office The Information Commissioner's Office (ICO) is a non-departmental public body which reports directly to the Parliament of the United Kingdom and is sponsored by the Department for Digital, Culture, Media and Sport (DCMS). It is the independe ...
that Phorm would only be legal under UK law if it were an opt-in service.


Implementation

Richard Clayton, a
Cambridge University , mottoeng = Literal: From here, light and sacred draughts. Non literal: From this place, we gain enlightenment and precious knowledge. , established = , other_name = The Chancellor, Masters and Schola ...
security researcher, attended an on-the-record meeting with Phorm, and published his account of how their advertising system is implemented. Phorm's system, like many websites, uses
HTTP cookies HTTP cookies (also called web cookies, Internet cookies, browser cookies, or simply cookies) are small blocks of data created by a web server while a user is browsing a website and placed on the user's computer or other device by the user's we ...
(small pieces of text) to store user settings. The company said that an initial web request is redirected three times (using
HTTP 307 The Hypertext Transfer Protocol (HTTP) is an application layer protocol in the Internet protocol suite model for distributed, collaborative, hypermedia information systems. HTTP is the foundation of data communication for the World Wide Web, ...
responses) within their system, so that they can inspect cookies to determine if the user has opted out. The system then sets a unique Phorm tracking identifier (UID) for the user (or collects it if it already exists), and adds a cookie that is forged to appear to come from the requested website. In an analysis titled "Stealing Phorm Cookies", Clayton wrote that Phorm's system stores a tracking cookie for each website visited on the user's PC, and that each contains an identical copy of the user's UID. Where possible, Phorm's system strips its tracking cookies from http requests before they are forwarded across the Internet to a website's server, but it cannot prevent the UID from being sent to websites using

. This would allow websites to associate the UID to any details the website collects about the visitor. Phorm Senior Vice President of Technology Marc Burgess has said that the collected information also includes a timestamp. Burgess said, "This is enough information to accurately target an ad in hefuture, but cannot be used to find out a) who you are, or b) where you have browsed".


Incentives

In 2008 Phorm considered offering an incentive, in addition to the phishing protection it originally planned, as a means to convince end-users to opt into its Webwise system. The alternate incentives, suggested in a Toluna.com market research survey carried out on behalf of Phorm, included further phishing protection, a donation to charity, a free technical support line, or one pound off opted-in users' monthly broadband subscriptions. Following the decision by
Wikimedia Foundation The Wikimedia Foundation, Inc., or Wikimedia for short and abbreviated as WMF, is an American 501(c)(3) nonprofit organization headquartered in San Francisco, California and registered as a charitable foundation under local laws. Best kno ...
and
Amazon Amazon most often refers to: * Amazons, a tribe of female warriors in Greek mythology * Amazon rainforest, a rainforest covering most of the Amazon basin * Amazon River, in South America * Amazon (company), an American multinational technology c ...
to opt their websites out of being profiled by Phorm's Webwise system, and as an incentive for websites to remain opted into the Phorm profiling system, Phorm launched Webwise Discover. The Korean launch of this web publisher incentive was announced in a press conference in
Covent Garden Covent Garden is a district in London, on the eastern fringes of the West End, between St Martin's Lane and Drury Lane. It is associated with the former fruit-and-vegetable market in the central square, now a popular shopping and tourist si ...
in London on 3 June 2009. A survey by polling firm
Populus ''Populus'' is a genus of 25–30 species of deciduous flowering plants in the family Salicaceae, native to most of the Northern Hemisphere. English names variously applied to different species include poplar (), aspen, and cottonwood. The we ...
revealed that after watching a demonstration video, 66% of the 2,075 individuals polled claimed to either like the idea or like it a lot . Website publishers are invited to upload a web widget which will provide a small frame to display recommended web links, based on the tracked interests of any Phorm-tracked website visitors (those whose ISP uses Phorm Deep Packet Inspection to intercept and profile web traffic). There would be no charge to the website, and Phorm do not stand to make any money from Webwise Discover; however, there are plans to display targeted adverts in the future.
/sup> The widget would only deliver link recommendations if the user was signed up for targeted advertising with a Phorm-affiliated ISP, the widget would be invisible to everyone else..
/sup> At the press launch Phorm spokespersons admitted that at present not a single UK ISP or website has yet signed up to Webwise Discover system,
/sup> although they emphasised it was part of the current Korea Telecom Webwise trials. Legal advice has been offered to websites considering signing up to the OIX system by Susan Singleton.
/sup>


Legality

The
Open Rights Group The Open Rights Group (ORG) is a UK-based organisation that works to preserve digital rights and freedoms by campaigning on digital rights issues and by fostering a community of grassroots activists. It campaigns on numerous issues including ma ...
(ORG) raised questions about Phorm's legality and asked for clarification of how the service would work. FIPR has argued that Phorm's online advert system is illegal in the UK. Nicholas Bohm, general counsel at FIPR, said: "The need for both parties to consent to interception in order for it to be lawful is an extremely basic principle within the legislation, and it cannot be lightly ignored or treated as a technicality." His open letter to the Information Commissioner has been published on the FIPR web site. The
Conservative Conservatism is a cultural, social, and political philosophy that seeks to promote and to preserve traditional institutions, practices, and values. The central tenets of conservatism may vary in relation to the culture and civilization i ...
peer Lord Northesk has questioned whether the UK government is taking any action on the targeted advertising service offered by Phorm in the light of the questions about its legality under the
Data Protection Information privacy is the relationship between the collection and dissemination of data, technology, the public expectation of privacy, contextual information norms, and the legal and political issues surrounding them. It is also known as data pr ...
and Regulation of Investigatory Powers Acts. On 9 April 2008, the
Information Commissioner's Office The Information Commissioner's Office (ICO) is a non-departmental public body which reports directly to the Parliament of the United Kingdom and is sponsored by the Department for Digital, Culture, Media and Sport (DCMS). It is the independe ...
ruled that Phorm would only be legal under UK law if it were an opt-in service. The Office stated it will closely monitor the testing and implementation of Phorm, in order to ensure
data protection Information privacy is the relationship between the collection and dissemination of data, technology, the public expectation of privacy, contextual information norms, and the legal and political issues surrounding them. It is also known as data pr ...
laws are observed. The UK Home Office has indicated that Phorm's proposed service is only legal if users give explicit consent. The Office itself became a subject of controversy when emails between it and Phorm were released. The emails showed that the company edited a draft legal interpretation by the Office, and that an official responded "If we agree this, and this becomes our position do you think your clients and their prospective partners will be comforted".
Liberal Democrat Several political parties from around the world have been called the Liberal Democratic Party or Liberal Democrats. These parties usually follow a liberal democratic ideology. Active parties Former parties See also *Liberal democracy *Lib ...
spokeswoman on Home Affairs, Baroness Sue Miller, considered it an act of
collusion Collusion is a deceitful agreement or secret cooperation between two or more parties to limit open competition by deceiving, misleading or defrauding others of their legal right. Collusion is not always considered illegal. It can be used to att ...
: "The fact the Home Office asks the very company they are worried is actually falling outside the laws whether the draft interpretation of the law is correct is completely bizarre." ''
The Register ''The Register'' is a British technology news website co-founded in 1994 by Mike Magee, John Lettice and Ross Alderson. The online newspaper's masthead sublogo is "''Biting the hand that feeds IT''." Their primary focus is information tec ...
'' reported in May 2008 that Phorm's logo strongly resembled that of an unrelated UK company called Phorm Design. They quoted the smaller company's owner, Simon Griffiths: "I've had solicitors look at it and they say we'd have to go to court. horm areobviously a big player with a lot of clout. I'm a small design agency in
Sheffield Sheffield is a city status in the United Kingdom, city in South Yorkshire, England, whose name derives from the River Sheaf which runs through it. The city serves as the administrative centre of the City of Sheffield. It is Historic counties o ...
that employs three people." Until 21 September 2010, Phorm's Webwise service also shared the same name as
BBC WebWise BBC WebWise is both the BBC's archived guide to the internet for computer novices as well as some videos. Created in 1998, it consisted and on the archive, consists of a series of articles and videos. It also incorporates elements of anothe ...
. Monitoring of the Phorm website using a Website change detection service alerted interested parties to changes on 21 September 2010. Phorm's website had been edited to remove references to the word 'Webwise'. Phorm's Webwise product had become 'PhormDiscover'. The
Office for Harmonization in the Internal Market The European Union Intellectual Property Office (EUIPO; french: links=no, Office de l'Union européenne pour la propriété intellectuelle), founded in 1994, is the European Union Agency responsible for the registration of the European Union trad ...
(OHIM) Trade Marks and Designs Registration Office of the European Union website CTM-Online database lists Phorm's application for use of the 'Webwise'
trade mark A trademark (also written trade mark or trade-mark) is a type of intellectual property consisting of a recognizable sign, design, or expression that identifies products or services from a particular source and distinguishes them from others. ...
name. The
British Broadcasting Corporation #REDIRECT BBC Here i going to introduce about the best teacher of my life b BALAJI sir. He is the precious gift that I got befor 2yrs . How has helped and thought all the concept and made my success in the 10th board exam. ...
is listed as an opponent on grounds of 'Likelihood of confusion'. The City of London-based legal firm Bristows wrote to the OHIM on 22 September 2010, withdrawing the BBC's opposition saying, "The British Broadcasting Corporation have instructed us to request the withdrawal of the above Opposition No. B11538985" On 28 October 2010, BT removed the Webwise pages from their company website although it was not until 12 November 2010 that all pages had finally been confirmed as removed by forum contributors at the campaign group called "NoDPI.org". ,
Virgin Media Virgin Media is a British telecommunications company which provides telephone, Cable television, television and Internet access, internet services in the United Kingdom. Its headquarters are at Green Park in Reading, Berkshire, Reading, Engla ...
had not removed their Phorm and Webwise FAQs from their customer-news section.


European Commission case against UK over Phorm

European Union The European Union (EU) is a supranational political and economic union of member states that are located primarily in Europe. The union has a total area of and an estimated total population of about 447million. The EU has often been des ...
communications commissioner
Viviane Reding Viviane Adélaïde Reding (born 27 April 1951) is a Luxembourgish politician and a former Member of the European Parliament (MEP) from Luxembourg. She is a member of the Christian Social People's Party, part of the European People's Party. She p ...
has said that the commission was concerned Phorm was breaching
consumer privacy Consumer privacy is information privacy as it relates to the consumers of products and services. A variety of social, legal and political issues arise from the interaction of the public's potential expectation of privacy and the collection and di ...
directives, and called on the UK Government to take action to protect consumers' privacy. The
European Commission The European Commission (EC) is the executive of the European Union (EU). It operates as a cabinet government, with 27 members of the Commission (informally known as "Commissioners") headed by a President. It includes an administrative body o ...
wrote to the UK government on 30 June 2008 to set out the context of the EU's interest in the controversy, and asked detailed questions ahead of possible Commission intervention. It required the UK to respond to the letter one month after it was sent. A spokeswoman for the
Department for Business, Enterprise and Regulatory Reform The Department for Business, Enterprise and Regulatory Reform (BERR) was a United Kingdom government department. The department was created on 28 June 2007 on the disbanding of the Department of Trade and Industry (DTI), and was itself disbanded ...
(BERR) admitted on 16 August that the UK had not met the deadline. On 16 September, BERR refused ''The Register'' request to release the full text of their reply to the European Commission, but released a statement to the effect that the UK authorities consider Phorm's products are capable of being operated in a lawful, appropriate and transparent fashion. Unsatisfied by the response, the European Commission wrote to the UK again on 6 October. Martin Selmayr, spokesman for Reding's Information Society and Media directorate-general said, "For us the matter is not finished. Quite the contrary." The UK government responded again in November, but the Commission sent another letter to the government in January 2009. This third letter was sent because the Commission was not satisfied with explanations about implementation of European law in the context of the Phorm case. Selmayr was quoted in ''The Register'' as saying, "The European Commission's investigation with regard to the Phorm case is still ongoing", and he went on to say that the Commission may have to proceed to formal action if the UK authorities do not provide a satisfactory response to the Commission's concerns. On 14 April, the European Commission said they had "opened an infringement proceeding against the United Kingdom" regarding ISPs' use of Phorm:Full text, titled "Telecoms: Commission launches case against UK over privacy and personal data protection", a
the European Union portal Rapid Press Releases
/ref> That day, in response to a news item by ''The Register'' regarding the European Commission's preparations to sue the UK government, Phorm said their technology "is fully compliant with UK legislation and relevant EU directives. This has been confirmed by BERR and by the UK regulatory authorities and we note that there is no suggestion to the contrary in the Commission's statement today." However, BERR denied such confirmation when they responded to a
Freedom of Information Freedom of information is freedom of a person or people to publish and consume information. Access to information is the ability for an individual to seek, receive and impart information effectively. This sometimes includes "scientific, indigeno ...
(FOI) request also made that day: In January 2012, the EU dropped its case against the UK government.


Reaction

Initial reaction to the proposed service highlighted deep concerns with regards to individual
privacy Privacy (, ) is the ability of an individual or group to seclude themselves or information about themselves, and thereby express themselves selectively. The domain of privacy partially overlaps with security, which can include the concepts of a ...
and property rights in data. Phorm has defended its technology in the face of what it called "misinformation" from
bloggers A blog (a truncation of "weblog") is a discussion or informational website published on the World Wide Web consisting of discrete, often informal diary-style text entries (posts). Posts are typically displayed in reverse chronological order ...
claiming it threatens users' privacy. Most security firms classify Phorm's targeting cookies as
adware Adware, often called advertising-supported software by its developers, is software that generates revenue for its developer by automatically generating online advertisements in the user interface of the software or on a screen presented to the ...
.
Kaspersky Lab Kaspersky Lab (; Russian: Лаборатория Касперского, tr. ''Laboratoriya Kasperskogo'') is a Russian multinational cybersecurity and anti-virus provider headquartered in Moscow, Russia, and operated by a holding company in th ...
, whose anti-virus engine is licensed to many other security vendors, said it would detect the cookie as adware.
Trend Micro is an American-Japanese multinational cyber security software company with global headquarters in Tokyo, Japan and Irving, Texas, United State.Other regional headquarters and R&D centers are located around East Asia, Southeast Asia, Europe, and ...
said there was a "very high chance" that it would add detection for the tracking cookies as adware. PC Tools echoed Trend's concerns about privacy and security, urging Phorm to apply an opt-in approach. Specialist anti-spyware firm Sunbelt Software also expressed concerns, saying Phorm's tracking cookies were candidates for detection by its anti-spyware software. Ross Anderson, professor of security engineering at
Cambridge University , mottoeng = Literal: From here, light and sacred draughts. Non literal: From this place, we gain enlightenment and precious knowledge. , established = , other_name = The Chancellor, Masters and Schola ...
, said: "The message has to be this: if you care about your privacy, do not use BT, Virgin or Talk-Talk as your internet provider." He added that, historically, anonymising technology had never worked. Even if it did, he stressed, it still posed huge privacy issues. Phorm has engaged a number of
public relations Public relations (PR) is the practice of managing and disseminating information from an individual or an organization (such as a business, government agency, or a nonprofit organization) to the public in order to influence their perception. P ...
advisers including Freuds, Citigate Dewe Rogerson and ex-
House of Commons The House of Commons is the name for the elected lower house of the bicameral parliaments of the United Kingdom and Canada. In both of these countries, the Commons holds much more legislative power than the nominally upper house of parliament. ...
media adviser John Stonborough in an attempt to save its reputation, and has engaged with audiences via moderated online webchats.Full transcripts of these interviews can be found a
''http://www.webwise.com/how-it-works/chat.html''
 The creator of the
World Wide Web The World Wide Web (WWW), commonly known as the Web, is an information system enabling documents and other web resources to be accessed over the Internet. Documents and downloadable media are made available to the network through web se ...
, Sir
Tim Berners-Lee Sir Timothy John Berners-Lee (born 8 June 1955), also known as TimBL, is an English computer scientist best known as the inventor of the World Wide Web. He is a Professorial Fellow of Computer Science at the University of Oxford and a profess ...
, has criticised the idea of tracking his browsing history saying that "It's mine - you can't have it. If you want to use it for something, then you have to negotiate with me. I have to agree, I have to understand what I'm getting in return." He also said that he would change his ISP if they introduced the Phorm system. As Director of the
World Wide Web Consortium The World Wide Web Consortium (W3C) is the main international standards organization for the World Wide Web. Founded in 1994 and led by Tim Berners-Lee, the consortium is made up of member organizations that maintain full-time staff working to ...
, Berners-Lee also published a set of personal design notes titled "No Snooping", in which he explains his views on commercial use of packet inspection and references Phorm. Simon Davies, a privacy advocate and founding member of
Privacy International Privacy International (PI) is a UK-based registered charity that defends and promotes the right to privacy across the world. First formed in 1990, registered as a non-profit company in 2002 and as a charity in 2012, PI is based in London. Its cu ...
, said "Behavioural advertising is a rather spooky concept for many people." In a separate role at 80/20 Thinking, a consultancy start-up, he was engaged by Phorm to look at the system. He said: "We were impressed with the effort that had been put into minimising the collection of personal information". He was subsequently quoted as saying " rivacy InternationalDOES NOT endorse Phorm, though we do applaud a number of developments in its process". "The system does appear to mitigate a number of core privacy problems in profiling, retention and tracking ... utwe won't as PI support any system that works on an opt-out basis." Kent Ertugrul later said he made a mistake when he suggested
Privacy International Privacy International (PI) is a UK-based registered charity that defends and promotes the right to privacy across the world. First formed in 1990, registered as a non-profit company in 2002 and as a charity in 2012, PI is based in London. Its cu ...
had endorsed Phorm: "This was my confusion I apologise. The endorsement was in fact from Simon Davies, the MD of 80 / 20 who is also a director of privacy international."


Stopphoulplay.com

Ertugrul has set up a website called "Stopphoulplay.com", in reaction to Phorm critics Alexander Hanff and
Marcus Williamson Marcus Williamson is a British writer, journalist and campaigner. As an obituarist for ''The Independent'' he has written obituaries of more than 300 subjects, including artists, poets, actors and inventors. Campaigns Phorm In 2009 the AIM-l ...
. Ertugrul called Hanff a "serial agitator" who has run campaigns against both Phorm and other companies such as
Procter & Gamble The Procter & Gamble Company (P&G) is an American multinational consumer goods corporation headquartered in Cincinnati, Ohio, founded in 1837 by William Procter and James Gamble. It specializes in a wide range of personal health/consumer hea ...
, and says Williamson is trying to disgrace Ertugrul and Phorm through "serial letter writing". Hanff believes the Stopphoulplay website's statements are "completely irrelevant" to his campaign and that they will backfire on Ertugrul, while Williamson laments that Phorm "has now stooped to personal smears". When it launched on 28 April 2009, Stopphoulplay.com discussed a petition to the UK Prime Minister on the Downing Street website. When originally launched the web page claimed, "The website managers at 10 Downing Street recognised their mistake in allowing a misleading petition to appear on their site, and have since provided assurances to Phorm that they will not permit this to happen again". That same day, the
Freedom of Information Freedom of information is freedom of a person or people to publish and consume information. Access to information is the ability for an individual to seek, receive and impart information effectively. This sometimes includes "scientific, indigeno ...
(FOI) Act was used to request confirmation of the claim by Phorm and on 29 April Phorm removed the quoted text from the website and replaced it with nothing. The Prime Minister's Office replied to the FOI request on 28 May, stating they held no information in relation to the request concerning Phorm's claim. A day after the site's launch, BBC correspondent Darren Waters wrote, "This is a battle with no sign of a ceasefire, with both sides horm and anti-Phorm campaigners/nowiki> settling down to a war of attrition, and with governments, both in the UK and the EU, drawn into the crossfire." The site was closed down in September 2009 and is now an online casino. However, the pages http://stopphoulplay.com/this-is-how-they-work/ and http://stopphoulplay.com/this-is-who-they-are/ still contain the comments against Hanff and NoDPI.


BT trials

After initial denials,
BT Group BT Group plc (trading as BT and formerly British Telecom) is a British multinational telecommunications holding company headquartered in London, England. It has operations in around 180 countries and is the largest provider of fixed-line, broa ...
confirmed they ran a small scale trial, at one exchange, of a "prototype advertising platform" in 2007. The trial involved tens of thousands of end users. BT customers will be able to
opt out The term opt-out refers to several methods by which individuals can avoid receiving unsolicited product or service information. This option is usually associated with direct marketing campaigns such as e-mail marketing or direct mail. A list of thos ...
of the trial—BT said they are developing an improved, non-
cookie A cookie is a baked or cooked snack or dessert that is typically small, flat and sweet. It usually contains flour, sugar, egg, and some type of oil, fat, or butter. It may include other ingredients such as raisins, oats, chocolate chips, n ...
based opt-out of Phorm—but no decision has been made as to their post-trial approach. ''The Register'' reported that BT ran an earlier secret trial in 2006, in which it intercepted and profiled the web browsing of 18,000 of its broadband customers. The technical report states that customers who participated in the trial were not made aware of the profiling, as one of the aims of the validation was not to affect their experience. On 4 June 2008, a copy of a 52-page report allegedly from inside BT, titled "PageSense External Technical Validation", was uploaded to
WikiLeaks WikiLeaks () is an international Nonprofit organization, non-profit organisation that published news leaks and classified media provided by anonymous Source (journalism), sources. Julian Assange, an Australian Internet activism, Internet acti ...
. The report angered many members of the public; there are questions regarding the involvement of charity ads for Oxfam, Make Trade Fair and SOS Children's Villages, and whether or not they were made aware that their ads were being used in what many feel were highly illegal technical trials. FIPR's Nicholas Bohm has said that trials of an online ad system carried out by BT involving more than 30,000 of its customers were potentially illegal. BT's third trial of Phorm's Webwise system repeatedly slipped. The trial was to last for approximately two weeks on 10,000 subscribers, and was originally due to start in March 2008, then pushed to April and again to the end of May; it has yet to occur. The company is facing legal action over trials of Phorm that were carried out without user consent. On 2 September 2008, while investigating a complaint made by anti-Phorm protestors, the City of London Police met with BT representatives to informally question them about the secret Phorm trials. On 25 September the Police announced that there will be no formal investigation of BT over its secret trials of Phorm in 2006 and 2007. According to Alex Hanff, the police said there was no criminal intent on behalf of BT and there was implied consent because the service was going to benefit customers. Bohm said of that police response: On 29 September 2008, it was announced in BT's support forum that their trial of Phorm's Webwise system would commence the following day. BT press officer Adam Liversage stated that BT is still working on a network-level opt-out, but that it will not be offered during the trial. Opted-out traffic will pass through the Webwise system but will not be mirrored or profiled. The final full roll-out of Webwise across BT's national network will not necessarily depend the completion of the work either. The
Open Rights Group The Open Rights Group (ORG) is a UK-based organisation that works to preserve digital rights and freedoms by campaigning on digital rights issues and by fostering a community of grassroots activists. It campaigns on numerous issues including ma ...
urged BT's customers not to participate in the BT Webwise trials, saying their "anti-fraud" feature is unlikely to have advantages over features already built into web browsers. Subscribers to BT forums had used the Beta forums to criticise and raise concerns about BT's implementation of Phorm, but BT responded with a statement: According to
Kent Ertugrul Kent Ertugrul was Interim Chairman of the Board and Chief Executive Officer (CEO) of Phorm Inc., a Delaware corporation. He resigned from the Phorm Corporation board on 15 July 2015. Phorm ceased trading on 14 April 2016, having burnt through £200 ...
, BT would have completed the rollout of its software by the end of 2009. The ''
Wall Street Journal ''The Wall Street Journal'' is an American business-focused, international daily newspaper based in New York City, with international editions also available in Chinese and Japanese. The ''Journal'', along with its Asian editions, is published ...
'', however, reported in July 2009 that BT had no plans to do so by then, and was concentrating on "other opportunities". Phorm's share price fell 40% on the news. On 6 July 2009 BT's former chief press officer, Adam Liversage, described his thoughts using
Twitter Twitter is an online social media and social networking service owned and operated by American company Twitter, Inc., on which users post and interact with 280-character-long messages known as "tweets". Registered users can post, like, and ...
: "A year of the most intensive, personal-reputation-destroying PR trench warfare all comes to nothing". He ended his comment with "Phantastic". In October 2009, Sergeant Mike Reed of the
City of London Police The City of London Police is the territorial police force responsible for law enforcement within the City of London, including the Middle and Inner Temples. The force responsible for law enforcement within the remainder of the London region, ou ...
answered a Freedom of Information (FOI) request. He confirmed the crime reference number as 5253/08. In his response, he stated that after originally passing case papers to the
Crown Prosecution Service The Crown Prosecution Service (CPS) is the principal public agency for conducting criminal prosecutions in England and Wales. It is headed by the Director of Public Prosecutions. The main responsibilities of the CPS are to provide legal adv ...
(CPS) in December 2008, the police were '"asked to provide further evidence, by the CPS in October 2009". Asked to "Disclose the date when that investigation was reopened", he said that it was "on instruction of the CPS in October 2009". In Sergeant Reed's response he named the officer in charge as "D/S Murray". On 25 February 2010, it was reported that the CPS continued to work on a potential criminal case against BT over its secret trials of Phorm's system. Prosecutors considered whether or not to press criminal charges against unnamed individuals under Part I of the Regulation of Investigatory Powers Act. It was not until April 2011 the CPS decided not to prosecute as it would not be in the public interest, stating that neither Phorm nor BT had acted in bad faith and any penalty imposed would be nominal. In April 2012, reports said that an officer of the City of London Police had been taken to lunch by Phorm. A police spokesperson was quoted as saying they were aware of the allegation, and that while no formal complaint had been received, "The force is reviewing the information available to it before deciding the best course of action." The spokesperson also highlighted that, "City of London Police were not involved in an investigation into BT Phorm and that the decision not to investigate was prompted by CPS advice".


Advertisers and websites

Advertisers which had initially expressed an interest about Phorm include: ''
Financial Times The ''Financial Times'' (''FT'') is a British daily newspaper printed in broadsheet and published digitally that focuses on business and economic current affairs. Based in London, England, the paper is owned by a Japanese holding company, Nik ...
'', ''
The Guardian ''The Guardian'' is a British daily newspaper. It was founded in 1821 as ''The Manchester Guardian'', and changed its name in 1959. Along with its sister papers ''The Observer'' and ''The Guardian Weekly'', ''The Guardian'' is part of the Gu ...
'',
Universal McCann Universal McCann (UM) is a global media and advertising agency. UM is a member of Interpublic Group, operating under the IPG Mediabrands branch. Some of its regional offices are known as Universal Media rather than Universal McCann but are still ...
, MySpace,
iVillage iVillage, Inc. was a mass media company that operated the ”most popular female-oriented sites” on the internet in the 1990s. In addition to ivillage.com, the company operated iVillage UK, Astrology.com, GardenWeb, and the NBC Digital Health N ...
,
MGM Metro-Goldwyn-Mayer Studios Inc., also known as Metro-Goldwyn-Mayer Pictures and abbreviated as MGM, is an American film, television production, distribution and media company owned by Amazon through MGM Holdings, founded on April 17, 1924 a ...
OMD,
Virgin Media Virgin Media is a British telecommunications company which provides telephone, Cable television, television and Internet access, internet services in the United Kingdom. Its headquarters are at Green Park in Reading, Berkshire, Reading, Engla ...
and Unanimis.
The Guardian ''The Guardian'' is a British daily newspaper. It was founded in 1821 as ''The Manchester Guardian'', and changed its name in 1959. Along with its sister papers ''The Observer'' and ''The Guardian Weekly'', ''The Guardian'' is part of the Gu ...
has withdrawn from its targeted advertising deal with Phorm; in an email to a reader, advertising manager Simon Kilby stated "It is true that we have had conversations with them hormregarding their services but we have concluded at this time that we do not want to be part of the network. Our decision was in no small part down to the conversations we had internally about how this product sits with the values of our company." In response to an article published in ''The Register'' on 26 March 2008, Phorm has stated that MySpace has not joined OIX as a Publisher. The Financial Times has decided not to participate in Phorm's impending trial. The ORG's Jim Killock said that many businesses "will think ommercialdata and relationships should simply be private until they and their customers decide," and might even believe "having their data spied upon is a form of industrial espionage". David Evans of the
British Computer Society Sir Maurice Wilkes served as the first President of BCS in 1957 BCS, The Chartered Institute for IT, known as the British Computer Society until 2009, is a professional body and a learned society that represents those working in infor ...
has questioned whether the act of publishing a website on the net is the same as giving consent for advertisers to make use of the site's content or to monitor the site's interactions with its customers. Pete John created an add on, called Dephormation, for servers and web users to opt out and remain opted-out of the system; however, John ultimately recommends that users switch from Phorm-equipped Internet providers: "Dephormation is not a solution. It is a
fig leaf The expression "fig leaf" is widely used figuratively to convey the covering up of an act or an object that is embarrassing or distasteful with something of innocuous appearance, a metaphorical reference to the Biblical Book of Genesis in which ...
for your privacy. Do not rely on Dephormation to protect your privacy and security. You need to find a new ISP." In April 2009,
Amazon.com Amazon.com, Inc. ( ) is an American multinational technology company focusing on e-commerce, cloud computing, online advertising, digital streaming, and artificial intelligence. It has been referred to as "one of the most influential economi ...
announced that it would not allow Phorm to scan any of its domains. The
Wikimedia Foundation The Wikimedia Foundation, Inc., or Wikimedia for short and abbreviated as WMF, is an American 501(c)(3) nonprofit organization headquartered in San Francisco, California and registered as a charitable foundation under local laws. Best kno ...
has also requested an opt-out from scans, and took the necessary steps to block all Wikimedia and Wikipedia domains from being processed by the Phorm system on the 16th of that month. In July 2009 the
Nationwide Building Society Nationwide Building Society is a British mutual financial institution, the seventh largest cooperative financial institution and the largest building society in the world with over 16 million members. Its headquarters are in Swindon, England. ...
confirmed that it would prevent Phorm from scanning its website, in order to protect the privacy of its customers.


Internet service providers

MetroFi MetroFi was a provider of municipal wireless network service in several cities in the western United States. History MetroFi was founded in 2002 by Chuck Haas, who helped start Covad, and Pankaj Shah, in Mountain View, California. Investors incl ...
, an American
municipal wireless network A municipal wireless network is a citywide wireless network. This usually works by providing municipal broadband via Wi-Fi to large parts or all of a municipal area by deploying a wireless mesh network. The typical deployment design uses hundreds ...
provider linked to Phorm, ceased operations in 2008. Three other ISPs linked to Phorm all changed or clarified their plans since first signing on with the company. In response to customer concerns, TalkTalk said that its implementation would have been "opt-in" only (as opposed to BT's "opt-out") and those that don't "opt in" will have their traffic split to avoid contact with a WebWise (Phorm) server. In July 2009, the company confirmed it would not implement Phorm;
Charles Dunstone Sir Charles William Dunstone (born 21 November 1964) is the British co-founder and former chairman of mobile phone retailer Carphone Warehouse, former chairman of multinational electrical and telecommunications retailer and services company Dix ...
, boss of its parent company, told the ''Times'' "We were only going to do it hormif BT did it and if the whole industry was doing it. We were not interested enough to do it on our own." Business news magazine ''
New Media Age ''New Media Age'' (''NMA'') was a weekly news magazine, covering business is use of interactive media in the UK is now ''Econsultancy''. New Media Age is owned by Centaur Media, Centaur Media plc. It was launched as a newsletter in May 1995 under ...
'' reported on 23 April that Virgin Media moved away from Phorm and was expected to sign a deal with another company named Audience Science, while BT would meet with other advertising companies to gain what the ISP calls "general market intelligence" about Phorm. ''NMA'' had called the moves "a shift in strategy by the two media companies". A day later, the magazine said both companies' relationships with Phorm actually remain unchanged. Although Virgin Media were reported to have "moved away from Phorm", in November 2010 they were the only UK-based ISP to still carry information about Phorm's Webwise system on their website. In addition, Phorm partners with international ISPs Oi, Telefónica in Brazil, TTNET-Türk Telekom in Turkey, and
Romtelecom Telekom Romania Communications (formerly known as Romtelecom) is a Romanian telecommunications company, which provides fixed voice, television and data services, for residential and business customers in Romania. As of 2020, Telekom Romania Commun ...
in
Romania Romania ( ; ro, România ) is a country located at the crossroads of Central Europe, Central, Eastern Europe, Eastern, and Southeast Europe, Southeastern Europe. It borders Bulgaria to the south, Ukraine to the north, Hungary to the west, S ...
.


Countries Post United Kingdom


South Korea

Phorm announced the beginning of a market trial in
South Korea South Korea, officially the Republic of Korea (ROK), is a country in East Asia, constituting the southern part of the Korea, Korean Peninsula and sharing a Korean Demilitarized Zone, land border with North Korea. Its western border is formed ...
via the
London Stock Exchange London Stock Exchange (LSE) is a stock exchange in the City of London, England, United Kingdom. , the total market value of all companies trading on LSE was £3.9 trillion. Its current premises are situated in Paternoster Square close to St Pau ...
's
Regulatory News Service The Regulatory News Service (RNS) transmits regulatory and non-regulatory information published by companies and organisations allowing them to comply with local market transparency legislation. It is owned by the London Stock Exchange and distrib ...
(RNS) on 30 March 2009. Subsequently, they announced via RNS on 21 May 2009 that they had commenced the trial. On 8 July 2009 Phorm indicated that the trials were proceeding as expected. In their Notice of 2009 Interim Report & Accounts, published on 14 September 2009, Phorm stated they were "Nearing completion of a substantial market trial, launched in May, with KT, the largest ISP in South Korea". The existence of the trial in South Korea was publicised by
OhmyNews OhmyNews (Hangul: 오마이뉴스) is a South Korean online news website with the motto "Every Citizen is a Reporter". It was founded by Oh Yeon Ho on February 22, 2000. It is the first news website in Korea to accept, edit and publish article ...
on 2 September 2009. On 9 September 2009 OhMyNews announced that the trial had been shut down.


Brazil

On 26 March 2010, Phorm announced that its plans for commercial deployment in Brazil. In May 2012, the Brazilian Internet Steering Committee issued a resolution recommending against the use of Phorm products by any internet service providers in the country, citing privacy risks and concerns that Phorm's products would degrade the quality of internet services. In respect of the proposed partnership with Telemar (now known as Oi) the claim is that iG, a
web portal A web portal is a specially designed website that brings information from diverse sources, like emails, online forums and search engines, together in a uniform way. Usually, each information source gets its dedicated area on the page for displayin ...
, only has 5% penetration in the market and Phorm did not clear R$400 million "last year".


Turkey

Since launching with
TTNET TTNET A.Ş., operating under the Türk Telekom brand, is the largest Internet service provider in Turkey and has around 7 million subscribers. TTNET is a subsidiary of Türk Telekom Group. Currently, Mohammad Hariri is Chairman of the Board ...
, a subsidiary of Türk Telecom Group, in Turkey in 2012, Phorm has launched its platform with five additional ISPs. Accordingly, on a global basis, there are now over 20 million daily users on Phorm's platform. According to RNS Number : 3504C, as of 16 January 2015, Phorm moved to a remote cookie option whilst scaling back its operations in Turkey.


China

Phorm announced on 3 October 2013 that it had launched operationally in China and had commenced a nationwide opt-in process. The company announced that it has commenced commercial operations in China and is serving advertisements on a paid basis. Privacy concerns in China and Hong Kong are growing, and there have been significant developments in privacy regulation, which could impact on Phorm operations in both the mainland and Hong Kong. In May 2012 mainland China passed new regulations which implement measures protecting consumer privacy from commercial exploitation. Further privacy legislation arrived in April 2013, with the publication of two draft rules from the
Ministry of Industry and Information Technology The Ministry of Industry and Information Technology of the Chinese government, established in March 2008, is the state agency of the People's Republic of China responsible for regulation and development of the postal service, Internet, wireless ...
: "Provisions on the Protection of the Personal Information of Telecommunications (Provisions for Telecommunications and Internet Users)", and "Internet Users and the Provisions on Registration of the True Identity Information of Phone Users" (Provisions on Phone Users), along with draft amendments to the 1993 Law of Consumer Rights. The laws are emerging as e-commerce in China becomes an increasingly significant part of the Chinese economy. These new regulations, which include provisions regulating data collection by smart devices, are discussed in an article published by the
International Association of Privacy Professionals The International Association of Privacy Professionals (IAPP) is a nonprofit, non-advocacy membership association founded in 2000. It provides a forum for privacy professionals to share best practices, track trends, advance privacy management is ...
' "Privacy Tracker" blog called "Making Sense of China's New Privacy Laws". In Hong Kong, The Office of the Privacy Commissioner for Personal Data ("PCPD") has taken a robust approach to the protection of consumer privacy, as they seek to enforce the provisions of the Personal Data (Privacy) (Amendment) Ordinance 2012 ("Amendment Ordinance") which came into force in April 2013.http://www.pcpd.org.hk/english/infocentre/press_20140123a.htm (Jan 2014)


Notes


References


External links

* {{Official website, http://www.phorm.com/ Internet privacy Online advertising Spyware Rootkits