We need to make sure that our houses are in order. Is yours? Ask yourself these questions:

• Do you always know exactly where your ads are being served?
• Are your publishers accurately conveying the privacy practices on their websites?
• Are you vetting, monitoring and auditing the intermediaries between you and those publishers?
• Is your privacy policy accurate?

You must have the right answers to these questions-- just look at the recent lawsuits coming out of the New York Attorney General's office and the H.R. 29 legislation and you'll see why.

It's not just what YOUR company is doing
Legally speaking, the "agency theory" of liability is catching on.

Having your own dirty house can invite government regulation, but so can a failure to adequately vet, control and audit your business partners.

So it’s not just a question of what your company is doing, it’s about what your company and your partners up and down the chain are doing. You've got to:

• Know how your partner represents your company
• Review your partners' privacy policies
• Know what's going on behind the scenes with your partners-- what, for example, do they do with cookies?

Who really cares about this?
Lots of people, including consumer watchdog groups, anti-Spyware companies and the Walt Mossbergs of the world.