Category: adolescent privacy

Disney’s Bob Iger, Kids and Behavioral Tracking/Targeting: He Claims “Kids don’t care” about their Privacy

My friend the children’s TV activist Peggy Charren, back during the 1970’s and 1980’s, had a favorite expression when it came to dealing with self-serving media moguls who trampled on concerns about kids:  “I’d like to wash your mouth out with soap,” she would exclaim (given her tenacity, they knew she meant business).  Robert Iger, the head of Disney, is quoted in Reuters saying that: “If we could sell your behavior to an advertiser — I am actually pretty bullish about what technology is going to allow in terms of behavioral tracking. I think we are going to have information to sell to marketers.”

Unbelievably, Mr. Iger, when citing concerns over privacy, says that: “Kids don’t care,”…adding that when he talked to his adult children about their online privacy concerns “they can’t figure out what I’m talking about.”

Mr. Iger has just dramatically tarnished the Disney brand, by suggesting that it’s okay to engage in digital marketing and data collection to children and adolescents.  Not only is he thumbing his nose at the bipartisan Children’s Online Privacy Protection Act, but the growing concern health, parenting and children’s groups have regarding youth privacy and consumer protection.  Instead of Disney being a youth industry leader when it comes to digital marketing, it appears the company is shirking what its role should be.  Peggy–I hope you still have one of those bars of soap!

Behavioral Marketers Collect “terabytes” of data on consumers via cookies and other techniques [Annals of Behavioral Targeting]

Take a quick look at the first two graphs from this week’s Behavioral Insider newsletter.  And keep in mind that the online marketing industry is currently working to prevent Congress from enacting safeguards that protect consumers, including their privacy:

The lack of technology that sorts and stores the mounds of data collected from cookies and ad tags could contribute to the slow adoption of behavioral targeting, according to some advertising insiders.

The culprit becomes the terabytes of data from hundreds of thousands of ad impressions collecting geographic location, content on page, time of day, interaction with ads, frequency in which ads serve up, and more.

source:  Behavioral Targeting Creates Filter And Purge Technology Gap.  Laurie Sullivan.  Behavioral Insider.  July 16, 2009

Online Consumers Require Real Privacy Safeguards, Not the Digital Fox [AAAA, ANA, BBB, DMA & IAB] in Charge of the Data Hen House

The self-regulatory proposals released today [2 July 2009]  by five marketing industry trade and lobby groups are way too little and far too late. This move by the online ad industry is an attempt, of course, to quell the growing bi-partisan calls in Congress to enact meaningful digital privacy and consumer protection laws. It’s also designed to assuage a reawakened Federal Trade Commission–whose new chair, Jon Leibowitz, recently appointed one the country’s most distinguished consumer advocates and legal scholars to direct its Bureau of Consumer Protection (David Vladeck). The principles are inadequate, even beyond their self-regulatory approach that condones, in effect, the “corporate fox guarding the digital data henhouse.” Effective government regulation is required to protect consumers. We should have learned a painful lesson by now with the failure of the financial industry to oversee itself. The reckless activities of the financial sector—made possible by a deregulatory, hands-off government policy–directly led to the current financial catastrophe. As more of our transactions and daily activities are conducted online, including those involving financial and health issues–through PCs, mobile phones, social networks, and the like–it is critical that the first principle be to ensure the basic protection of consumer privacy. Self-dealing “principles” concocted by online marketers simply won’t provide the level of protection consumers really require.

The industry appears to have embraced a definition of behavioral targeting and profiling that is at odds with how the practice actually works. Before any data is collected from consumers, they need to be candidly informed about the process–such as the creation and evolution of their profile; how tracking and data gathering occurs site to site; what data can be added to their profile from outside databases; the role that data targeting plays on so-called first-party websites, etc. In addition, the highest possible consumer safeguards are necessary when financial and health data are involved. Under the loosey-goosey trade industry principles, however, only “certain health and financial data” are to be treated as a “sensitive” category. This would permit widespread data collection involving personal information regarding our health and financial concerns. The new principles, moreover, fail to protect the privacy of teenagers; nor do they seriously address children’s privacy. (I was one of the two people that led the campaign to enact the Children’s Online Privacy Protection Act).

The failure to develop adequate safeguards for sensitive consumer information illustrates, I believe, the inability of the ad marketing groups to seriously address online privacy. The so-called “notice and choice” approach embraced by the industry has failed. More links to better-written privacy statements don’t address the central problem: the collection of more and more user data for profiling and targeting purposes. There needs to be quick Congressional action placing limits on the collection, use and retention of consumer data; opt-in control over profile information; and the creation of a meaningful sensitive data category. Consumer and privacy groups intend to work with Congress to ensure that individuals don’t face additional losses due to unfair online marketing practices.

[press statement by the Center for Digital Democracy]

Memo to Acting FCC Chair Michael Copps on Cable TV “Branded Storytelling”: A Tour of Embedded TV Advertising

Dear Mr. Chairman:

We are emailing you the link to this week’s Advertising Age’s story called “Designing a Custom Fit: Cable Offering more integrated, multiplatform deals.”  If you needed any additional evidence that the business model that further merges programming content with advertising requires scrutiny, debate, and safeguards (especially in the youth market), we offer the following article excerpts as evidence.  Clearly, the comedy writers are creating the marketing strategies for some of the cable programming networks.  But I’ve put a few of the best lines in bold:

Call it extreme sponsorship.

As advertisers look for maximum returns on their media investments, cable networks are offering an increasing number of creative, customized and multiplatform ways to partner with marketer brands—and to make sure viewers are paying attention.

The options for integrated marketing have gone far beyond a title sponsorship or a simple product placement. Today the buzzwords are “content-mercials,” “intromercials,” “branded storytelling” and custom marketing. Network series stars are featured in marketers’ commercials—and marketers’ products have a starring role in hit series…USA Network’s approach is to treat an advertiser’s brand as a supporting character in its multiplatform “Characters Welcome” credo. “Our network is not about one genre or one demographic. We are about characters. We celebrate the character of your brand,” says Chris McCumber, exec VP-marketing, digital and brand strategy for USA Network…

USA’s hottest show right now is “Burn Notice.” In its inaugural season, “Burn Notice” partnered with Saab 9-3 for an online game, “Covert Ops,” that allowed users to “drive” a virtual Saab all over Miami…In “Covert Ops,” “while you are playing the game, you are using the elements of Saab. The game drew more leads to Saab.com than the number of cars available to sell,” Mr. McCumber says. “The gaming area has incredible opportunities for brand integration.”…USA’s on-air integrations include using Hoover vacuums to “sweep” graphics off the screen during “Clean House.”…

On A&E Television Networks’ History, Subaru is a presenting sponsor for the upcoming “Expedition Africa: Stanley & Livingstone.”…

“We provided the explorers at certain points in the expedition [in four episodes] with the Subaru—where it made sense,” says Mel Berning, exec VP-ad sales for A&E Television Networks.

The integrations highlight features such as trunk space capacity and vehicle toughness off-road. Thirty-second “content-mercials” will run in every episode…AMC is promoting its Branded Storytelling—a way for advertisers to tell their brand stories through AMC’s programming, says Bill Rosolie, AMC exec VP-sales….Examples include: Takeovers, where marketers can own an entire episode, movie or day with their messages; Matching Moments, where AMC breaks the action with a sponsored pod that directly follows relevant content; and “Matching Attributes,” where brands’ messages are connected to key movie content by using custom creative to run within the film…

Nickelodeon has made multiplatform integration central to its ad sales efforts. This year Nick teamed with Walmart for an integrated effort celebrating the 10th anniversary of the No. 1 kids show, “Sponge Bob Square Pants.” The plan included TV, print and online media backed by in-store support. The Happy Place inside its Walmart stores offered exclusive Sponge Bob merchandise. A microsite (www.spongebobhappyplace.com) requests a sign-on code, only available at Walmart stores, to allow visitors access to exclusive content.

In 2008 Nick and AT&T joined efforts on a Web site where kids could text “iCarly,” get an iCarly ringtone, view cool gadgets (such as the Palm Centro or the AT&T Slate) and see a sneak peek of the iCarly movie “iGo to Japan,” which aired last November.

source:  Designing a Custom Fit.  Nancy Coltun Webster.  Ad Age.  May 4, 2009

“Social Influence Research” from Ad Agencies to Identify “Advocates and Champions” for brands [Annals of Social media Marketing]

excerpt:  In one instance, we used Social Infuence Research to conduct qualitative research for a Web site targeted at teen girls. Participants were recruited and asked to bring two friends to an interview. The researchers used the interview to observe the behavior of the group and the dynamics that occurred among the individuals in it. As a follow-up, the group was given a video camera and asked to document a trip to the mall. The video provided tremendous insight into the influencer and follower behaviors that were naturally occurring in the group… In another research project, we interviewed entire nuclear families to understand how its members managed and allocated financial resources. Families are the oldest and most established “social networks.” As such, they have fairly clearly delineated exchange and influencing processes to make decisions. To map how those decisions were made, we interviewed parents and children separately, and then together. In addition we worked with the family to create a digital photo diary for an entire week. Through those “mapping” interviews and exercises, we were able to canvas how financial decisions were made, how parents implicitly and explicitly passed along “money values” to their children, how children implicitly and explicitly absorbed the parents’ financial lessons and ultimately how the family network functioned around financial matters…

Generating social graph analysis and reporting helps to identify not only the attributes of influencers, but shows us who they are, where they are, what makes them influencers and, most importantly, where they cross other networks. Of course, social networks are nothing new; marketers have observed and responded to influencer relationships across categories for many years. However, the evolution of the social Web has created a new opportunity for digital marketers and researchers to harness a consumers’ social influence across their online network and create advocates and champions for their brand.

source:  Razorfish. 2009.

Alain Heureux, IAB Europe, and the Battle Over Online Marketing and Privacy: Worried about Article 29 Working Party and Calls for Regulation

We recently met Mr. Heureux in Brussels at a EU conference on consumers in the digital age.  He is a most capable representative of the European online advertising industry.  But Alain’s job is also to help prevent the enactment of privacy safeguards that would protect European consumers and citizens when they use digital and interactive media.  Here are excerpts from a recent article on Mr. Heureux in New Media Age [26 March 2009]:

In the battle to protect online advertising from intervention by politicians, Alain Heureux is on the front line. The president and CEO of IAB Europe spends half his time on what he calls public affairs, concentrating on the regulatory agenda in Brussels.  “The three main concerns are privacy, targeting and social media, and all the links between…“We’re very worried,” he admits. “At the moment, the revenues from targeting and profiling are not so big, so if you damage them you might not damage the entire industry immediately. But marketers want to move away from traditional techniques to targeted, efficient forms of marketing, and that shift can only happen with the use of technology and data. So there is a risk of damaging the future of marketing and media.”

Heureux’s concerns include the Article 29 working party which, although it has no power to introduce legislation, carries considerable weight in Brussels. It’s currently working on a paper which would define a person’s IP address as personal data, making it subject to the same data protection regime as other personal information. He’s also worried about the upcoming EU elections, wondering if one of the current commissioners might campaign on a privacy and data protection platform.

“Someone could position themselves as the messiah of data protection,” he says. “You’d get a lot of sympathy from consumers’ associations and citizens who are a little bit scared about all this data stuff, so it would be easy to take that great role and use it politically. That’s why these elections are dangerous, the threat is very much present.”…

Heureux takes the view that the only way to stop regulators passing new laws is for the industry to regulate itself. And while he acknowledges that Brussels is open to the idea of self-regulation, he sees one of his biggest problems as managing its expectations.

“Regulatory affairs take time, but the regulator wants everything now, not in a year’s time.” …“We need to create room for self-regulation but I’m worried about who will take care of enforcement. It’s not clear that the SROs [self-regulator organizations] will do it, because they’re under-resourced and under-funded, so it won’t be easy to extend self-regulation to include new techniques and practices.”

Despite these concerns, Heureux acknowledges with a smile that the current economic situation is helping the cause of self-regulation. He sees companies becoming more pragmatic and open to compromise with their competitors, while regulators are more concerned about the effect of new legislation on jobs and business.

Kraft’s Research to Boost Oreo Sales reveals “resurgent desire for indulgent food products”–A multi-media ad campaign designed to stimulate cookie “licking”

This excerpt from an Brandweek article on the 2009 Super Reggie winning ad campaign deserves to be highlighted, so the Federal Trade Commission can do a better job next time it researches the market.  The agencies involved for this campaign included Draftfcb (general and promotional advertising);  Razorfish (digital); Digitas (online media);  MediaVest (media); IMG (experiential); Weber Shandwick (PR).

“…Double Stuf Racing League (DSRL) …The highly stylized marketing and entertainment vehicle, billed as a professional sport…has enjoyed 16 consecutive months of sales growth since the program debuted in late 2007, per the company. That consistent performance was a resounding reversal of the brand’s previous sales declines that year, and it explains why Kraft continues to build on the effort in 2009.

It all began as Kraft’s marketing team and litany of agency partners searched for a new brand experience that would distinguish the creamier Double Stuf Oreo from the original cookie. Research revealed consumers’ resurgent desire for indulgent food products, and collective brainstorming led the team to focus on a familiar aspect of Oreo consumption.

“The spark came as we were thinking about fun new ways to engage consumers with Oreo,” explained John Ghingo, marketing director for Oreo at Kraft Foods, East Hanover, N.J. “Lots of people partake in the rituals of twisting, licking and dunking Oreo cookies in milk. Double Stuf Racing League focuses on the ‘lick’ aspect and takes Oreo to a new place in an unexpected way.”

Thus far, Double Stuf Racing League has pitted two sets of celebrity siblings against each other: NFL star quarterbacks Eli and Peyton Manning and pro tennis champs Venus and Serena Williams. In January 2008, a national TV teaser spot featured a mock press conference by the all-American football heroes declaring their entry into a “second sport.” The ad directed fans to a Web site (whatsthesecondsport.com) where they enter DSLR and participate in games by creating avatars called “Yoobies.” However, the identity of the second sport was kept alive, leaving viewers to chatter about the mystery on fan sites and blogs…

That buzz continues this year. A spring contest is slated for the Sunshine State, with appearances by both the Mannings and the Williamses. So what other famous athletes may join the competition? “Like any league, DSRL is always looking to scout great new talent,” demurred Ghingo.”

Super REGGIE Winner:  Oreo Double Stuf Racing League ‘Licks’ the Competition.   Michael Applebaum. Adweek.  April 6, 2009

DSRL site
NabiscoWorld.com Privacy [data collection] policy

IAB UK’s “Good Practice Principles” on Behavioural Targeting: Alice in Wonderland Meets Online Data Collection

Last week in Brussels at a EU Consumers Summit, Google and other interactive ad companies pointed to the new Interactive Advertising Bureau/UK “Good Practice Principles for online behavioural advertising” as a model for meaningful self-regulation.  The companies that have endorsed the principles include  AOL/Platform A, AudienceScience, Google, Microsoft Advertising, NebuAd, Phorm, Specific Media, Yahoo! SARL, and Wunderloop.   The message sent to EU regulators was, in essence, don’t really worry about threats to privacy from online profiling and behavioural targeting.  But a review of the Principles suggest that there is a serious lack of “truth in advertising” when it comes to being truly candid about data collection and interactive marketing.  These Principles are insufficient–and are really a political attempt to foreclose on meaningful consumer policy safeguards.

Indeed, when one examines the new online “consumer guide” which accompanies the Principles,  one has a kind of Alice in Wonderland moment.  That’s because instead of being candid about the real purpose of behavioral advertising–and the system of interactive marketing it is a part of–the IAB paints an unreal and deliberately cheery picture where data collection, profiling, tracking, and targeting are just harmless techniques designed to give you a better Internet experience.   UK consumers–and policymakers–deserve something more forthright.

First, the IAB conveniently ignores the context in which behavioural targeting is just one data collection technique.  As they know, online marketers are creating what they term a “media and marketing ecosystem.”  A truly honest “Good Practice Principles” would address all the principal ways online marketers target consumers.  That would include, as IAB/UK knows well, such approaches as social media marketing, in-game targeting, online video, neuromarketing, engagement, etc.  A real code would address issues related to the use of behavioural data targeting and other techniques when used for such areas as finance (mortgages, loans, credit cards); health products; and targeting adolescents.

The IAB/UK also fails to reconcile how it describes behavioural targeting to its members and what it says to consumers and policymakers.  For example, the group’s glossary defines behavioural targeting as:  “A form of online marketing that uses advertising technology to target web users based on their previous behaviour. Advertising creative and content can be tailored to be of more relevance to a particular user by capturing their previous decision making behaviour (eg: filling out preferences or visiting certain areas of a site frequently) and looking for patterns.“  But its new “Good Practice” consumer guide says that “Online behavioural advertising is a way of serving advertisements on the websites you visit and making them more relevant to you and your interests. Shared interests are grouped together based upon previous web browsing activity and web users are then served advertising which matches their shared interests. In this way, advertising can be made as relevant and useful as possible.”

Incredibly, the IAB/UK claims that “the information used for targeting adverts is not personal, in that it does not identify you – the user – in the real world. Data about your browsing activity is collected and analysed anonymously.”  Such an argument flies in the face of what the signatories of the “Good Practice Principles” really tell their online ad customers.  For example, Yahoo in the UK explains that its “acclaimed behavioural targeting tool allows advertisers to deliver specific targeted ads to consumers at the point of purchase.”  Yahoo has used behavioural targeting in the UK to help sell mortgages and other financial products.  Microsoft’s UK Ad Solutions tells customers it can provide a variety of behavioural targeting tools so it “can deliver messaging to the people who are actively looking to engage with what you’re offering…With Re-messaging we can narrow our audience by finding the people who have already visited you. It means we can ensure they always stay in touch and help create continual engagement with your brand…Profile Targeting can help you find the people you’re looking for by who they are, where they are and when you want to be seen by them.”  Time Warner’s Platform A/AOL says “Through our Behavioural Network, we can target your most valuable visitors across our network, earning you additional revenues, or simply fulfil your own campaign obligations.  By establishing certain user traits or demographics within your audience, we are able to target those individuals with the most relevant advertising (tied into their common characteristics), or simply reach those same users in a different environment.”  Or Audience Science’s UK office that explains “While other behavioural targeting technologies simply track page visits, the AudienceScience platform analyzes multiple indicators of intent:

•  Which pages and sections they have visited

•  What static and dynamic content they have read

•  What they say about themselves in registration data

•  Which search terms they use

•  What IP data indicates about them, including geography, SIC code, Fortune 500 rank, specific Internet domains,   and more

Because AudienceScience processes so many indicators of intent, it enables you to create precisely targeted audience segments for advertisers.”  And Google, which knows that the UK is “arguably the most advanced online marketplace in the world” has carefully explained to its UK customers all the data they collect and make available for powerful online targeting.

The Notice, Choice and Education “Good Practice” scheme relies on an ineffective opt-out.  Instead of real disclosure and consumer/citizen control, we have a band-aid approach to privacy online.  The IAB also resorts to a disingenuous scare tactic when it suggests that without online marketing, the ability of the Internet to provide “content online for free” would be harmed.  No one has said there shouldn’t be advertising–what’s been said is that it must be done in a way which respects privacy, the citizen, and the consumer.   Clearly, the new IAB/UK code isn’t a model that can be relied on to protect the public.  UK regulators must play a more proactive role to ensure privacy and consumer welfare online is meaningfully protected.

UK Online Ad Lobby Group: “behavioural targeting is going to be the future of the internet.” [Annals of Behavioral Targeting]

The debate over behavioural targeting, profiling and interactive advertising is heating up in the European Union.  We just spoke at a EU event on the topic.  More later on that meeting (which featured Google, Microsoft, Nokia and others, all wearing their Brussels best).  Google and others pointed to a new code on behavioural targeting created by the UK’s Interactive Ad Bureau, which they suggest is a model (and is designed to foreclose on real privacy safeguards).  I will be writing about this code in the next post.  But here’s what the chairman of the IAB UK, Richard Eyre, said about protecting privacy online and the Internet’s future [via Brand Republic.  March 31, 2009]. Excerpts:

Richard Eyre, chairman of the Internet Advertising Bureau, has said he accepts the European Union’s decision to investigate behavioural targeting as “logical” but hopes that the current self-regulatory process “will satisfy everyone”.

Eyre was responding to the EU’s decision to investigate behavioural targeting by online advertisers, in a move that could result in legislation that overrides the code recently introduced by the IAB with the support of Ofcom and search giants Google and Microsoft…Eyre said that he understood that the EU had to have a point of view on the issue because behavioural targeting is a new tool about which the general public is still forming its opinion. However he hopes the self-regulatory code on behavioural targeting recently introduced by the IAB will satisfy everyone. Eyre said: “It is very easy to dismiss the issues as an invasion of privacy but the fact is that behavioural targeting is going to be the future of the internet.”Eyre told ISBA’s annual conference recently that behavioural targeting would be a “game-changer” for advertisers.
PS:  As for Microsoft’s position on privacy, here’s an excerpt from a March 5, 2009 New Media Age story:  “Zuzanna Gierlinska, head of Microsoft Media Network, said, “It’s better that regulation comes from within the market rather than from government, which might not be fully aware of how behavioural targeting works.”  source:  “Industry unites to defend trust in online advertising.”   Suzanne Bearne.  nma.co.uk

Facebook Connect: “über-targeting” for marketers [Annals of Social Media Marketing]

excerpt from online marketing blog [our bold]:

The Benefits of Facebook Connect

For marketers:

First, it facilitates getting mentioned in Facebook users’s news feeds, which has been the holy grail for marketers because it raises awareness of your business and delivers an implied endorsement.

Second, it provides a treasure trove of user data, allowing über-targeting. You can literally customize the content of your page based on the visitor’s Facebook data, such as his age, gender, location, likes, dislikes, relationship status, even networks, groups, and pages he’s joined – or “fanned.” As a simple example, if you know a visitor is a fan of the band U2, you can highlight your U2-theme stationery, T-shirts, dog bones.