Digital targeting of political messages in Norway June 2019 2 3 Contents SUMMARY ..................................................................................................................................................................5 INTRODUCTION ......................................................................................................................................................... 6 OUR DIGITAL PUBLIC SPHERE ..................................................................................................................................... 7 THE TARGETING INDUSTRY ....................................................................................................................................... 8 THE LEGAL FRAMEWORK .......................................................................................................................................... 12 MICROTARGETING IN THE US AND EUROPE .............................................................................................................. 15 THE USE OF DATA AND TARGETING TECHNOLOGY BY NORWEGIAN POLITICAL PARTIES................................................ 18 What do the parties do? .................................................................................................................................... 18 What are the conditions that impact the parties’ use of digital targeting technology? ................................ 22 Challenges and risk factors .............................................................................................................................. 24 CONCLUSION .......................................................................................................................................................... 25 SIX RECOMMENDATIONS FOR THE USE OF MICROTARGETING OF POLITICAL MESSAGES .............................................. 26 REFERENCES ...........................................................................................................................................................27 4 5 Summary In this report, we examine the use of digital targeting of a risk of re-identification when this kind of technology is political messages. We discuss how digital targeting has linked to data on geographic location on street and been used in political campaigns abroad, and how political household levels. Assumptions based on this data, such as parties utilise digital targeting and data analysis in how a certain person may vote, may in some cases Norway. To survey the use of digital targeting in Norway, constitute personal data. we interviewed representatives from all nine political parties currently represented in the Norwegian The uploading of a party’s own data (such as membership parliament. In the final part of the report, we offer some lists) to Facebook and other advertising platforms in order practical guidelines for the use of digital targeting in to customise their own target groups, is currently an political campaigns. ethical line the parties are not willing to cross. However, some parties admit to having previously experimented The targeting of political messaging is generally based on with this. The way Facebook allow targeting based on demographic data such as age, gender and place of finely filtered categories such as interests and behaviour, residence. Microtargeting is a form of digital advertising means that the parties can easily create precise target that is largely based upon information closely associated groups without the use of their own data. In this process, with the individual person. Microtargeting is based on many ethical and legal issues are not necessarily being analyses of among other things the data subjects’ fully considered. behaviour, interests and values, compiled from a number of different sources. The objective is to influence your None of the parties have established written guidelines for actions and choices. the use of personal data and digital microtargeting. This can make the parties vulnerable to slipping into more Microtargeting of political messages can help voters invasive targeting methods. receive more relevant information, and might also increase political engagement. However, it may have an Microtargeting requires significant resources. Most impact on the privacy of the individual. In addition, it may parties state that they neither have the resources nor see increase manipulation and discrimination, and also the value in focusing on very small segments. This means negatively affect the legitimacy of– and trust in – the that the segments that are used are often not specific democratic process. enough to represent a threat to privacy. Resources are also important with respect to which external agencies the All the political parties represented in the Norwegian parties can use, and which tools they can utilise. parliament advertise on Facebook. This means that the platform largely sets the premises for the segmentation The social, political and economic conditions that and advertising tools that the parties end up using. presently restrict the parties’ use of microtargeting may Several parties define their leeway on Facebook as set by change. Furthermore, many of the parties use external the possibilities and restrictions in the platform’s ad companies that process data on their behalf. This may manager tool. This means that decisions made in contribute to microtargeting becoming more extensive in Facebook’s boardroom have direct consequences for how the future. For example, election campaign budgets may Norwegian political campaigns are run. increase and targeting technology may become cheaper and more user-friendly. The use of data analysis to increase the efficiency of door- to-door campaigning may, in certain circumstances, The findings in this report correspond with findings from enable the targeting of smaller segments, such as similar studies from other European countries, where it is residential areas or households. The use of this type of pointed out that modest budgets, the organisation of the technology varies among the surveyed parties. If analyses political systems and ethical and legal barriers contribute purchased from an external agency reveal where persons to the fact that microtargeting is not done to the same 1, 2 with a specific voter profile reside, this would in many extent as have been the case in the US and the UK. cases involve the processing of personal data. There is also 1 Dobber, T., Trilling, D., Helberger, N., & de Vreese, C. H. (2017). Two crates 2 Kruschinski, S., & Haller, A. (2017). Restrictions on data-driven political of beer and 40 pizzas: the adoption of innovative political behavioural targeting microtargeting in Germany. Internet Policy Review, 6(4) techniques. Internet Policy Review, 6(4) 6 Introduction On the 17th of March 2018, various media outlets without the voters even knowing or understanding published the first articles on what came to be a long line exactly why they are receiving that particular message. of disclosures on what was then a relatively unknown company called Cambridge Analytica.3, 4 The company The use of microtargeting for political influencing can had unlawfully gained access to tens of millions of have profound consequences on the privacy of the Facebook profiles, which they analysed and then utilised individual – but also for the democratic public sphere. to run political influence campaigns for Donald Trump’s In addition, it may make a political system vulnerable to election campaign in the US. manipulation, lead to discrimination, and negatively affect the legitimacy of – and trust in – the democratic The Cambridge Analytica case led to increased scrutiny process. on the use and misuse of personal data in the context of election campaigns. For example, the Information Elections all over the world are increasingly Commissioner’s Office in the UK have conducted a large characterised by the fear of manipulation, “fake news” scale investigation into the companies involved in the and interference in the election process by hostile states. Brexit referendum. Furthermore, in connection to the These issues are only briefly touched upon in this report. EU election held this spring, the European Data The focus of our report is primarily on the political Protection Board made a statement on the targeting of parties’ use of personal data to target political messages political messages. In 2019, the Dutch Data Protection in an election campaign. Authority initiated an audit to expose how the political In connection to the work on this report, we interviewed parties are compiling and utilising personal data in representatives from all nine political parties currently 5 marketing political messages. represented in the Norwegian parliament. We asked In the autumn of 2019, local government elections will them about their use of, and attitudes toward, micro- be held in Norway. Even though election campaigns in targeting and data analysis in an election campaign Norway are increasingly digitalized, little information is context. The interviews were conducted in March and available on how digital targeting and data analysis are April of 2019. being utilised for campaigning purposes. With this In the first part of the report we address microtargeting: report, The Norwegian Data Protection Authority hope what it is, which actors are involved, and how to generate more knowledge on the use of such methods microtargeting has been utilised in elections in the US by the Norwegian political