Versatile AI Risk Assessment
Customer service, marketing and platforms

Personalised online advertising (behavioural targeting)

Also known as: Behavioural advertising, ad targeting

The system uses a person's behaviour and profile to select which advertisements they see.

Explore the interactive model

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A concise PDF covering how the system works, its data flows and points to investigate, ready to share.

The explanations and measures describe the typical system design. Extensive personal changes add an appendix.

Understand the use case

What defines this use case?

Meta states that it uses such models to serve advertisements. The European Data Protection Board has ruled on the permitted legal basis.

This page describes a typical system design. Actual data flows and permissions depend on your implementation.

System design
Analysis and processing
Ability to act
Provides results for subsequent use
Fields of use
online platforms
Also known as
targeting, behavioural advertising, audience targeting

How it works, step by step

System design and data flows

  1. Input data

    Visited pages, clicks, profile details and advertisers' criteria are combined.

    Advertisers supply advertisements and audience criteria; click behaviour can be deliberately falsified. The system analyses individual usage behaviour and profiles.

  2. Processing

    A model estimates response likelihood for each suitable advertisement; an auction determines their order.

    Processing links usage and contextual signals to a target audience or an estimated response to advertisements. Selection or auction logic determines which advertisement is delivered. Model estimates, bids and actual delivery each serve a distinct purpose.

  3. Results

    The person sees selected advertisements on the website or app.

    The result describes the defined model task. A match, category or forecast acquires its professional significance only in conjunction with the underlying data and intended use.

  4. Use and impact

    Selection determines which offers someone sees or misses, and their response feeds back into the profile.

    The model supplies information for subsequent use. Selection, adoption or a professional decision in the following workflow is a separate step and should not automatically be attributed to the model.

Explore the system design: Select a component to see its task, incoming and outgoing data, and role in the use case. The guided walkthrough explains each phase. Then use Yes, Uncertain and No to represent your specific system variant.

How the system is built

7 review first10 clarify9 baseline threats

InputProcessingResultImpact Externalaccess 04 Input 21 Third-partycontent 00 AI model 10 Providerservice 03 Documentcollection 11 Memory 00 Training andfeedback 30 OtherAI agents 00 Tools andinterfaces 00 Result 00 Business appor equipment 00 person 00 Affectedperson 00 AI serviceswithout approval 01 Externalaccess 04 Input 21 Third-partycontent 00 AI model 10 Providerservice 03 Documentcollection 11 Memory 00 Training andfeedback 30 OtherAI agents 00 Tools andinterfaces 00 Result 00 Business appor equipment 00 person 00 Affectedperson 00 AI serviceswithout approval 01
  • Present
  • Depends on your system
  • Absent
  • Review first
  • To clarify

In this system design: 7 to review first, 10 to clarify, 9 baseline threats.

Architecture as a list

How it differs from similar use cases

Data and information

Input data and information sources

Advertisers supply advertisements and audience criteria; click behaviour can be deliberately falsified. The system analyses individual usage behaviour and profiles.

Processing and operating environment

The model processes the inputs. Whether it runs internally or with a service provider must be established for the specific implementation.

Storage and further use

The system retrieves advertisements from a large collection to match the person's profile. The platform trains its models on its own users' responses.

Results and data sharing

Serving advertisements through networks passes personal information to other companies.

Using a provider does not automatically determine where processing takes place. Storage location, subcontractors, deletion periods and use for training must be checked for the specific deployment.

Assess risks and determine measures

From understanding the system to analysing risks

  1. Define the system boundary

    Record data, participants, interfaces and permissions. Resolve uncertain characteristics in the model.

  2. Investigate threats

    Relate review candidates to actual data flows: what could happen, and who would be affected?

  3. Assess risk

    Assess impacts and likelihood in the deployment context. The number of review candidates is not a risk score.

  4. Provide evidence of measures

    Select appropriate controls, assign responsibilities and define effectiveness checks. Document residual risks and approvals.

Key threats in the application context

  • 3 particularly important
  • 4 typical
  • 10 depending on the system
  • 9 for every AI system

A total of 26 threats from the threat catalogue may be relevant to this use case.

Priority review points

  1. Privacy Attacks

    The model assigns someone to an audience such as debt advice or fertility based on browsing. Advertisers indirectly learn information the person never supplied through that audience selection.

  2. Misalignment

    The system learns that people in crisis or with gambling addiction click more and serves them more such advertisements. Click rates rise while the most vulnerable suffer harm.

  3. Training Data Poisoning

    Automated click fraud creates apparent interest in particular advertisements. The model learns false relationships, and advertisers pay for nonexistent reach.

4 further review candidates in the typical design

Other relevant threats

  1. Targeted Poisoning / Label Poisoning

    Falsified training labels can deliberately shift model outputs.

    Listed because of this characteristic

    • Uses operational feedback
  2. Backdoor ML Model

    Training data or an adopted base model can introduce hidden triggers for misbehaviour.

    Listed because of this characteristic

    • Learns from your own data
  3. Sensitive Information Disclosure

    Confidential content can appear in answers, supplied context or logs.

    Listed because of this characteristic

    • Processes personal data
  4. RAG-Specific Attacks (Document Poisoning)

    Content entering the retrievable knowledge collection can influence answers and subsequent steps.

    Listed because of this characteristic

    • Searches its own document collection

Up to 10 further threats may apply, depending on your system design. Nine threats need to be reviewed for every AI system.

System features and open questions

Each Yes adds further threats to your checklist, up to 10 in total. If you cannot yet answer a question, include its threats in your review.

How many threats a Yes adds
  • Added by this Yes

How your system is built

Do documents from several customers, departments or permission groups share one search store?

Advertising platforms hold many advertisers' customer lists and audiences in one system.

If yes, add

Does the system process confidential information such as trade secrets, health or financial data?

Interests and visited pages can reveal health, religion or political views.

If yes, add

How you operate the system

These questions arise for almost every AI system.

Can content leave your environment, for example to a cloud provider, web search or email?

Serving advertisements through networks passes personal information to other companies.

If yes, add

Controls and implementation

Measures for the priority review areas are expanded. Each linked measure explains how to implement it.

Controls for the remaining threats are available on their pages in the threat catalogue.

AI Act provisions

When AI Act provisions apply
  1. Art. 4: AI literacy

    For every AI system Applies since 2 February 2025.

  2. Art. 5 para. 1 point a, b: Manipulation and exploitation of vulnerability

    Depending on use Review trigger since 2 February 2025.

  3. Annex III no. 8 point b: Elections and voting

    Depending on use Review trigger from 2 December 2027.

Applies to every AI system

Art. 4: AI literacy

Applies if staff or appointed representatives operate or use AI systems.

Applies since 2 February 2025.

Obligations and details for Art. 4: AI literacy
Who bears the obligations
Provider, Deployer, Product manufacturer, Provider of a general-purpose AI model

Detailed obligations

May apply in particular uses

Art. 5 para. 1 point a, b: Manipulation and exploitation of vulnerability

Applies if advertisement targeting deliberately exploits vulnerabilities due to age, disability or economic distress in a way that risks significant harm.

Applies since 2 February 2025.

Obligations and details for Art. 5 para. 1 point a, b: Manipulation and exploitation of vulnerability
The general condition is
Applies if the system influences behaviour through subliminal, manipulative or deceptive means, or exploits vulnerability due to age, disability or social or economic circumstances, with a risk of significant harm.
Who bears the obligations
Provider, Deployer, Importer, Distributor, Authorised representative, Product manufacturer, Provider of a general-purpose AI model

Detailed obligations

Annex III no. 8 point b: Elections and voting

Applies if the system targets political advertisements to influence an election's outcome or voting behaviour.

Applies from 2 December 2027.

Obligations and details for Annex III no. 8 point b: Elections and voting
The general condition is
Applies if the system is intended to influence election results or voting behaviour.
Exception
Tools whose outputs do not directly reach people, such as political campaign organisation and logistics tools.
Who bears the obligations
Provider, Deployer, Product manufacturer

Detailed obligations

Other legal requirements

Classify your system with the quick checker All obligations in the obligations compass

Cross-cutting threats

Review these threats for every AI system, whatever its purpose.

Why these threats always belong on the checklist

Atypical system features

View 14 further questions

If any of these features does apply to your system, add the listed threats.

Sources

Related use cases

Also in the field of Customer service, marketing and platforms

Updated: 30 September 2026. Review checklist rules version 0.3.2, threat catalogue version 2026.10.24.2. How these pages are structured