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September 14, 2021

Email pixels, banks and the ICO 🎉

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Email pixels, banks and the ICO

Back in February, I launched No To Spy Pixels. It’s a tiny project with two goals:

  1. Raise awareness about tracking pixels in emails and the privacy issues they present

  2. Encourage UK residents to raise complaints with companies that track them without consent

Around the time of the launch, I raised the issue with my bank who were embedding spy pixels in statement emails. The complaint was checked by the bank’s data protection officer (DPO) who considered everything was above board.

I escalated it to the ICO and – after a few months – had an email to say they were investigating. A couple of weeks later I noticed the spy pixels disappeared from my bank’s emails, then the ICO emailed me to confirm the action they’d taken.

A couple of things struck me about this sequence of events:

  1. The bank’s DPO considered that their use of tracking pixels was ok, even though my complaint included a link to the specific section of ICO guidance that showed it was not

  2. Action works, even if the ICO’s track record on enforcement isn’t encouraging

If my bank’s DPO is getting this wrong, it’s likely that many other organisations are getting it wrong, too. In fact, I noticed that the ICO have updated their guidance to include a specific example of tracking pixels in emails:

Screenshot of ICO’s updated guidance, reads: “An organisation conducts electronic marketing and incorporates a tracking pixel within the emails. The pixels record information including the time, location and operating system of the device used to read the email. Whilst the majority of electronic mail marketing is governed by Regulation 22 of PECR, where tracking pixels store information, or gain access to information stored, on a user’s device Regulation 6 also applies.”

I’m taking it to Apple, Amazon and PayPal next.

If you’ve complained to an organisation about their use of tracking pixels – with or without success – I’d love to hear from you. If you would like help with raising a complaint, I’d be happy to help so get in touch.


Absorbing

Interesting links from the web.

Plain-English Privacy Notice

Thanks to one of my subscribers for forwarding this. A free open-source privacy notice designed for people to actually read.

Disabling sponsored tiles in Firefox

If you use Firefox, you might have noticed that there are some sponsored ads on the new tab page. These instructions show you how to remove them. If you want something even cleaner, check out A Fine Start.

Digital Identity Protection

Andra Zaharia told me about a freelancer whose name and image had been used to create an account on a freelancing platform: someone had stolen their identity to land work. It’s never been easier for this type of thing to happen, and Andra recommended this service to keep tabs on your profile across the web. Worth a look.


Scruples

We want to work with individuals, companies and organisations that make the world a better place. A few days ago, we started a list of the sectors we’d love to work with:

  • Culture
  • Sustainable energy
  • Social good
  • Human rights
  • Privacy advocacy
  • Ethical business initiatives

We’re also interested in collaborating with researchers and organisations working to subvert the spread of disinformation and surveillance capitalism.

We have some availability coming up before December. If this is you and you think we might be a good fit, email me (or Scruples at get@scruples.studio) as we’d love to hear from you.


Unoffice Hours

My Unoffice Hours remain open on Wednesdays (3pm – 4.30pm GMT).

I’ve been really enjoying these: no agenda or email needed ahead of time, just book a slot and turn up.


If you have related links that might be of interest, or thoughts on any of these topics, I’d love to hear from you: just hit reply.

Until next time,

Dave

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