Google’s “Health Vertical” Division and the YouTube `Branded’ Channel for Obesity-related Medical Product

Google is in, as we know, the interactive marketing of health products and medical information.  Here’s an excerpt from Advertising Age on one of Google’s new YouTube related efforts.  We are deeply concerned about the role of interactive health marketing, including the techniques used to present information, influence consumer behavior, and collect user data.

Excerpt: In the video, Viki, a middle-age blonde, tears up recounting her moment of truth: A couple of years ago she was so obese that she could not chase after her toddler to keep him from running into the street…If this sounds like a setup for a weight-loss ad, that’s because it is. But not for a diet shake, pill or plan. The video is for Ethicon Endo-Surgery’s Realize adjustable gastric band — a device placed around the stomach that restricts food intake. The video is on Realize Band’s branded YouTube channel.

Video is such a powerful medium for people who are having this type of surgery,” said Mary Ann Belliveau, managing director of Google Health Vertical. “What the channel does is give the patients a home for this, so they can get a more thorough experience, specifically with the company and the brand.”…The Realize band’s YouTube channel went live June 20 and already has received nearly 8,000 channel views. Ethicon also has a branded site for the band, where patients can learn more about the surgery and join the device’s online support program. In the video on YouTube, Viki describes her own experience with the Realize band. On the Realize website, consumers can read Viki’s diary, as well as those of other patients. Complementing Viki’s story on YouTube, there is a video simulating implantation of the band, and another explaining how to financially prepare for the surgery, which costs $17,000-$26,000 on average…”

source:  Gastric-Band Maker Reaches Out with YouTube Channel.  Marissa Miley.  Ad Age.  July 6, 2009 [sub required]

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]

Protecting Privacy and Consumers: Testimony on Behavioral Targeting Before House Commerce Subcommittees

Last week, I testified on the threat to both consumer privacy and welfare from the growing data collection, profiling, and targeting interactive online marketing system.  I told Congress it was critical to enact legislation that would protect consumers, especially as they use online and mobile networks for financial and health-related transactions (credit card applications, banking, health inquiries, etc.).  As you can see from the testimony, I said we should be able to have an online privacy policy that  ensures the public is protected, while also promoting the growth of the commercial online medium.

The link to the testimony via a press release is here.

Google Promotes Carls Jr. via special YouTube Ad Deal: But “won’t be marked as ads”

excerpt via Adweek:

Justine Ezarik might not be a household name, but the 25-year-old has a cable TV-size audience… Thanks to Google, she’s also now part of Carl’s Jr.’s effort rolling out this week to sell the Portobello Mushroom Six-Dollar Burger to young men. The search-engine giant drafted Ezarik and eight other popular YouTube creators to participate in an ad campaign for the fast-food chain on the video-sharing site…

The YouTube stars were chosen not only for their creative flair, but for the networks of followers they can mobilize. Ezarik, for instance, not only has 94,000 subscribers to the iJustine YouTube channel — the nine YouTube celebs combined total 3.8 million subscribers on the site — but also boasts 590,000 followers on Twitter and 25,000 Facebook fans…Google is adding such deals to its advertising arsenal as it attempts to turn the video site into a moneymaker… Other new tools include tying advertiser videos to search results and matching high-profile creators like Seth MacFarland with brands…

The Carl’s Jr. videos will live on a dedicated YouTube channel, the creators’ pages and in ad units across sites in the Google ad network. They won’t be marked as ads on the YouTube pages, but will carry a notice they were paid for by Carl’s Jr. Each video also invites users to upload their own videos of how they eat a burger.

source:  Carl’s Jr. Makes New Kind of Network Buy:  Burger promo leans on vast reach of YouTube content creators.  Brian Morrissey.  Adweek.  June 1, 2009

Video Metrics: “gauged by the millisecond” [Annals of Social Media Marketing]

The Obama Administration’s use of social media and analytics should trigger a serious debate.  How much information on citizens and others do we really want the government to have?  As part of the discussion, consider this excerpt from social marketing company’s RockYou’s pitch to advertisers and others [our bold].  This about the Feds tracking as you watch government-funded videos:

“…Social Video Ads and Cross Platform Video Distribution on the RockYou Ads Network…Looking at the landscape of online advertising – on social networks and beyond – it’s obvious that video advertising is the medium of choice for brands and marketers who have a story to tell…Video metrics go far beyond impressions. Audience interactions (views, stops, rewinds, sharing) are gauged by the millisecond and response can be measured, in real numbers. Advertisers who can combine that data with behavioral or demographic profiling, to reach exact targets, get amazing results. 

“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.

Annals of Branded Social Media–Ford Chooses 100 Bloggers to Serve as “Fiesta Agents”

Anyone tracking social media marketing recognizes that major brands and ad agencies are playing a highly influential role shaping the new medium.  It’s something we are closely observing.  Here’s an excerpt from Ad Age’s “Ford is Counting on Army of 100 Bloggers to launch new Fiesta [Eric Tegler.  April 20, 2009.  sub required].

“…the automaker is counting on 100 bloggers to introduce its new Fiesta, which is set to reach U.S. dealers in early 2010. The idea behind Fiesta Movement is to get the model’s target audience to drive and, hopefully, chatter about the car for months to come…Ford is loaning 100 German-built Fiestas to social-media trendsetters for six months. The 100 “Fiesta agents,” chosen from 4,000 who applied online, will share their experiences behind the wheel, completing monthly, themed missions from travel to social activism; posting videos; and updating their friends and followers on YouTube, Facebook, Twitter and elsewhere…Early signs indicate a ripple effect from simply signing agents to the Fiesta Movement… several of those selected have already gotten interviews with regional newspapers or TV stations based on their acceptance into the program…JWT will undertake the bulk of reviewing/posting online content generated by Fiesta agents, while mining data with the new metrics made possible through social media.”

Facebook’s COO: “There aren’t that many places where an advertiser can connect with users and do so as a part of their experience”

An excerpt from a Businessweek interview with Facebook COO Sheryl Sandberg:

“…our business is advertising…What we do is we enable connections. We enable people to connect with users and provide advertising in such a way that it’s not obtrusive at all, but it’s part of the advertising experience and part of the user experience… We believe advertising needs to blend into the experience…There aren’t that many places where an advertiser can connect with users and do so as a part of their experience and as part of the sharing. We actually offer that ability.

from:  “BusinessWeek Editor-in-Chief Stephen J. Adler talked with Facebook Chief Operating Officer Sheryl Sandberg”

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