The “Revised” Network Advertising Initiative Principles: Ghost-written by Bernard Madoff?

That was really what we felt reading the “NAI Response to Public Comments” released yesterday.  It accompanied the 2008 principles announcement by the self-regulatory trade online marketing trade group.  The “response” is worth reading, because it really reveals the inability of the group to meaningfully address how to protect consumers online.  You would think that an organization which has Microsoft, Google, Yahoo, Time Warner and many others as paying members could at least clearly state what happens to our data in the online marketing process.  But the real goal of the NAI is to prevent the enactment of serious state and federal privacy policies that would protect consumers. My group put out a statement yesterday discussing the new principles.

The credibility of Google, Microsoft, Yahoo and Time Warner are at stake.  They should be able to ensure that their own organization can honestly address the implications of online advertising.  But it’s time to abandon any call for self-regulation.  That has been a failure.  It’s clear that a growing number of consumer and privacy groups are calling for a legislative solution, as well as a more effective FTC.  Responsible online ad companies will support such regulation.

Google’s Doubleclick Using Widgets to “give advertisers the ability to tap into the incredible power of potential brand evangelists”

Google’s Doubleclick division is working with social media and widget advertising company Gigya so marketers can “integrate a viral component into any campaign to allow consumers to “snag” or “grab” the ad onto their personal homepage or social network page.” We think the Doubleclick release is very revealing. So here are some choice excerpt excerpts:

“Widgets are part of a fundamental change within the online marketing arena,” said Ari Paparo, vice president of advertiser products for DoubleClick. “Widget Ads provide audiences with the ability for self-expression and identification with well-loved brands while providing marketers the benefits of virality and engagement along with the measurability of traditional online channels.”…

“Incorporating viral functionality helps give advertisers the ability to tap into the incredible power of potential brand evangelists,” said Ben Pashman, vice president of business development with Gigya,…enabling great creative to enter a user’s social circle, where it may become an even more powerful, user-endorsed ad unit.”

Widget Ads may be distributed in a multitude of ways including branded websites, word-of-mouth outreach and even through another rich media ad… integration with the industry-standard DART platform allows for valuable Widget Ad metrics including impressions, interactions, video metrics, viral “grabs” for different social networks, and reach and frequency…”

Statement on FTC’s Children’s Online Privacy Protection Act legal action against Sony/Additional Privacy Policies are Required

Statement of Dr. Kathryn C. Montgomery, who led the campaign for the passage of the Children’s Online Privacy Protection Act (COPPA), commenting on the FTC children’s privacy lawsuit announced today against Sony BMG Music Entertainment

I applaud the FTC’s actions to enforce the Children’s Online Privacy Protection Act. The government’s lawsuit against SONY sends a strong signal to the online industry that this law must be taken seriously. COPPA was designed to protect children under the age of 13 from unfair data collection and manipulation by online marketers. Congress passed the law ten years ago to establish a clear set of safeguards and principles that were built into the foundation of the emerging digital marketplace. However, in recent years, online data collection has become increasingly sophisticated, expanding into a variety of new platforms — from social networks to mobile phones to interactive games — that are now central tools in young peoples’ their lives. In the new administration of President-elect Barack Obama, both the FTC and Congress must support additional policies that will extend COPPA’s mandate and create privacy protections for all children under the age of 18.

Kathryn C. Montgomery, Ph.D, is Professor of Communication at American University in Washington, DC.

No so sweet on Privacy—a new “Behavioral Targeting Suite” [Behavioral Targeting Watch]

excerpt from Valueclick press release: “Mediaplex, today announced the release of its Dynamic Behavioral Targeting suite…to cost-effectively achieve true one-to-one messaging… Dynamic Behavioral Targeting – Enables advertisers to differentiate and segment qualified customers from prospects based on their prior activity, and serve the most appropriate message using dynamic, real-time creative. This means advertisers can truly deliver the most relevant offer at the right time, in real time… Dynamic Reporting… This level of reporting detail gives advertisers ROI metrics down to each individual offer, giving the advertiser the right level of data insights they need to make informed decisions regarding best performing creatives and offers.

source: Mediaplex Releases Dynamic Behavioral Targeting Suite:
Product Advancements Enable 1-1 Messaging, Eliminate Wasted Marketing Dollars and Improve Campaign Performance [press release]. Dec. 10, 2008

Tales of Behavioral Targeting: Merging Offline Databases with Online User Tracking

The folks at the Federal Trade Commission better toughen up its proposed privacy principles. And Congress and the new Obama Administration, of course, will need to step in. That’s because the online marketing behavioral targeting industry is rushing to push the data collection from unprotected consumer digital envelope. Take, for example, Datran Media. In an interview, a representative explains “Datran’s unique advantage is in the fact that we have figured out a way to aggregate more audience data than anyone else…We derive our behavioral and lifestyle data from real online and offline requests for information or transactions, and obtain our household-level demographics and interests from the most informative and accurate direct marketing databases available. We feel that the combination is unprecedented and unbeatable in the marketplace.”

On Datran’s website it explains to potential clients that its Aperture product “is the first and only advertising solution to leverage the power of offline demographic data – at the household level – with online display advertising to help identify, reach and define your ideal customers – no matter where they are on the Web.” Describing a “smarter way” to reach consumers, the company explains that:

  • Aperture is the only advertising solution that uses household demographic information to precisely target banner ads online, and report on the ads’ audience AND responders.
  • Aperture defines your customers by WHO they are and WHAT they do.
  • Retargeting capabilities bring customers back to your site with an added level of insight into who they are.
  • Leveraging 100 million + demographic profiles combined with proprietary transaction-based behavioral intelligence, Aperture is capable of delivering greater consumer insights than ever before.

Aperture provides deep insights into the effectiveness and reach of your campaigns – by the view and click – so you can make the best business, media mix and creative decisions for your brand.”

The company’s targeting capabilities are also explained:

“Using Datran Media’s proprietary 100 million+ household level profiles, Aperture can layer any of following criteria to define your ideal customer and target your ads directly to them anywhere they go on the web.

  • Household
  • Gender
  • Household Size
  • Number of Adults
  • Number of Children Present
  • Renter/Owner
  • Length of Residence
  • Marital Status

The company can also “layer” in such targeting parameters as one’s neighborhood [“Number of Adults, Median Number of Children Present, Median Annual Income,” etc.] as well as consumer “behavior” [“auto, insurance, personal finance, dating and romance,” etc.].

As we said to the FTC and the industry, just because technology permits you to collect data and target individuals, doesn’t mean one should do it without the complete prior informed consent of users. Industry leaders need to own up to what they are doing, and support the kind of privacy protections a digital democracy requires.

AT&T and a leader of its funded Privacy Forum Raises Questions About the Need for Safeguards

Those busy data collection bees at AT&T–including its funded Future of Privacy Forum co-head–appear to be working to undermine the growing movement supporting consumer privacy protection. According to a news report, a meeting was held last week at the University of Oklahoma on privacy issues. Forum co-director Christopher Wolf, whose law firm represents AT&T, is reported as placing behavioral targeting in a favorable light. Instead of calling for legislation, Wolf suggested that companies should create videos and other technical approaches to serve as supplemental privacy policies.

Also speaking at the event was Keith Epstein, “AT&T’s chief public policy and regulatory compliance counsel.” Here are the last two grafs of the story: There is no legislation pending in Washington regarding online privacy, Epstein said. A legislative solution if it did exist, he said, would be inflexible.

Epstein favored guidelines instead, and said the FTC should be issuing industry standards by the fall of next year.

AT&T’s stance on privacy legislation to protect U.S. consumers is troubling. It will have its deep-packet inspection, all-seeing ISP broadband clout, to monitor and then target each subscriber. AT&T should make it clear it supports legislation which provides real consumer protection (opt-in, transparency, control, extra protections on health, financial and youth data). Where is the privacy leadership at AT&T?

New AT&T-funded “Future of Privacy” Group: Will it Support Real Privacy Protection or Serve as a Surrogate for Self-regulation and Data Collection?

A new group co-directed by former DoubleClick and AOL chief privacy officer Jules Polonetsky, called the “Future of Privacy Forum,” has been announced. It is connected to the law firm representing AT&T–Proskauer Rose–which has a considerable practice in the online marketing and data collection area. Other backers include Intel, General Electric, IBM and Wal-Mart.

We are concerned, however, that the role of the Forum is to help discourage Congress from enacting an opt-in regime for data collection. Both ISPs–such as AT&T, Verizon, Comcast and Time Warner–as well as online advertising companies such as Google/DoubleClick, Yahoo, and Microsoft must be governed by privacy laws which empower and protect consumers. The role of ISPs in any data collection for targeted online marketing, in particular, requires serious analysis and stringent safeguards. AT&T, Google, Microsoft, Comcast, the online ad networks, and social media marketers (to name a few) must be required to provide meaningful disclosure, transparency, accountability and user control (with special rules governing health, financial and data involving children and youth). Self-regulation has failed. If the Future of Privacy group is to have any legitimacy, it will work to support serious federal rules. But if it trots out some sort of voluntary code of conduct as a way to undermine the growing call for real privacy safeguards, this new group may soon be viewed as beholden to its funders and backers.

Project Canoe: Data-mining and Viewer Monitoring for Ad Targeting—-for banks, dog food, and your Cable Company

The cable TV industry’s interactive advertising consortium called Project Canoe is steadily moving ahead with plans that will harness more cable viewer data for profiling and targeting. Here’s some excerpts from a Hewlett-Packard blog:

“…Canoe’s first national go-to-market product is called Creative Versioning Platform which marries the cable industry’s ad zones with demographic databases, and this will offer national advertisers more targeted, relevant and effective advertising with commercials that run simultaneously across the national market with different messages and tags…

So who might this impact… How about consumer banking? Although there is a major consolidation in recent weeks with consumer banks, they still have specific audiences they are trying to target with their diverse banking products. Imagine Bank of America’s Private Wealth Management group only targeting household income over $150k with one specific message and another message for free checking account for households less than $75k. Or how about Purina dog food for only dog owners? Did you know that 40% of all U.S. TV households own a dog? The opportunities are endless.

Data – will be a major emphasis in Canoe’s charter…In the very near future, Canoe will have the ability to measure and monitor viewing via their set top boxes, second by second data by each box. Look familiar? That’s right, the Internet! These boxes will have in-dept and granular data for programmers and advertisers alike…Request for Information (RFI) – another basic feature with high potential…Pretty powerful stuff – high level of tracking…

T-Commerce…What could be better – you buy it during your favorite show, have it billed to your cable bill, have it shipped to your house (as the cable co. has your address) and you pay for it at the end of the month.

So who might this impact….How about credit card companies to begin with! And if the cable company offered to finance the purchases, they could create their own finance companies – similar to auto dealers. That’s called “extra income.”

source: The Changing Face of Media. Oct 6, 2008.

Online Ad Privacy Watch: Google Adding DoubleClick to its AdSense System

Policymakers will need to closely examine the role DoubleClick will play in collecting, analyzing, and helping profile consumers (whether they are online, seeing a video, or using a mobile device, for example). Here’s an email Google is reported sending out this week. My bold:

“We understand that the recent economic turmoil has created a lot of uncertainty in the lives of AdSense publishers. During these difficult times, we’re continuing to invest in innovations that improve publisher monetization and advertiser value in the content network.

We’re focusing on further developing our product offerings and boosting ad performance for publishers. We recently announced advancements in AdSense for search and experiments to make ads more effective. We’re bringing DoubleClick technologies to AdSense publishers, and we’ll continue to launch new products and features. We’re also continuing to improve our offerings for AdWords advertisers, making it easier for them to target the Google content network. Features for advertisers, such as the new display ad builder, are designed to improve ad performance on AdSense publisher sites.

We’ll keep driving technological progress, but our best asset will always be our publisher partners. The strength of AdSense lies in the value of the content you bring to users and the quality of the sites you bring to advertisers. Our success is tied to yours. We look forward to partnering with you for the long term, and remain dedicated to helping you succeed.”

Google’s new funding program for Academics: $ for studies on “Brand Development,” Click Generation” and “for moving traditional video spots from broadcast to broadband”

The advertising industry is engaged in a growing research effort to push the boundaries of marketing. It wishes, for example, to reach deeply into our unconscious mind in order to generate a range of behavioral responses. Marketers are exploring how the new tools of digital advertising can influence consumer emotions.

For example, Google is now engaged in consumer neuroscience research to make its YouTube ads more effective. But Google wants more academic help so it can improve its digital marketing prowess. So Google and global ad giant WPP have joined forces to create “a new research program to improve understanding and practices in online marketing, and to better understand the relationship between online and offline media.” The program will be run by a trio of scholars, including Google’s own Hal Varian, Professor John Quelch, senior associate dean of Harvard Business School (who is a a non-executive director of WPP), and Professor Glen Urban, former dean of the Sloan School of Management at the Massachusetts Institute of Technology. Varian told DM News that “We want to encourage more research about how online and offline media work together to influence consumer choices. We think that such research will contribute to more effective and more measurable advertising performance.” DM News also reported that Mark Read, CEO of WPP Digital and WPP’s director of strategy explained that “[T]he industry, our clients and our companies will benefit from the application of some of the world’s finest academic research minds into how online media influences consumers.”

Don’t expect, by the way, any grants to be awarded that examine the ethical dimensions of interactive marketing; or new threats to personal privacy and autonomy; the implications of Google’s growing global control over online ad revenues on publishing; or the negative environmental and social consequences of promoting a digital marketing system which could lead to over-consumption.

Here are some of the research questions Google hopes will draw academics into its program:

    • How does a brand establish a framework for assessing how much should be spent online? How much advertising should be directed at brand development versus specific click generation?…
    • How do you set digital advertising budgets and tactics when in intensively competitive product categories?…
    • What are good guidelines for moving traditional video spots from broadcast to broadband?
    • What is the causal relationship between brand health and search success? And what is the link between search and sales? How does search contribute to word of mouth recommendation?
    • How can banner ads be more effective?
    • How do you model the consumer response to digital advertising in social networks or mobile media?
    • What do we know and what more do we need to know about on-line audiences?
    • How can advertisers be welcome in social networks?
    • Recipients will be invited to attend a conference in Fall 2009 (Sept/Oct) where they can share their preliminary findings.