At Monday’s OMMA conference, what was both astounding and sad was the almost total absence of corporate responsibility regarding data privacy (among many other issues, which we will turn to later). At a workshop sponsored by Blue Lithium (now being acquired by Yahoo!) a company exec remarked that the current FTC inquiry into digital marketing and privacy wouldn’t result in any serious change. He suggested the FTC would, in essence, `go away,’ just as it did after the establishment of the meaningless NAI self-regulation guidelines in 2000. Those rules were put in place to quell any serious FTC action on online profiling.
The online ad industry should admit there’s a real problem, with privacy and many of the techniques underlying interactive marketing. Then we can move on to meaningful safeguards. Meanwhile, here’s an excerpt from the handy guide Blue Lithium distributed Monday, entitled “Behavioral Targeting: The Good, The Bad, The Ugly.” “Behavioral targeting tracks consumer Internet activity (sites and sections/pages of sites visited, links clicked on, ads seen and responded to or not responded to)…Behavioral targeting follows an audience around the Web…Placed on a homepage, product or category page or into an ad unit, the behavioral targeting pixel marks each visitor. Later, this data is used to target prospects as they visit other sites across the Web.”
excerpt: “DoubleClick Mobile will integrate with DART for Publishers to provide ad trafficking and yield optimization for campaigns designed to appear on phones. Additionally, the company plans to release a mobile ad management product for advertisers sometime in 2008, according to Ari Paparo, DoubleClick’s VP of rich media and emerging technologies…DoubleClick Mobile aims to bring “a lot of heavy iron” to the developing marketplace for ads on handsets. The product is capable of pairing ads with content according to the screen size and capabilities of the device being used to view them, and supports device-specific previews for each ad position and execution. In addition to standard mobile display ads, it supports ad formats such as combination ads and roadblocks. Through pixel-based ad tracking, agencies and other third parties can access campaign performance data through their own campaign reporting systems..
DoubleClick Mobile is launching simultaneously in the U.S. and Europe… Next year, the company plans to release a more comprehensive mobile ad management suite that includes tools for agencies to plan and track their mobile campaigns…
from: “Doubleclick Launches Site-Side Mobile Ad Management, Advertiser Version in Development.” Zachary Rodgers. ClickZ. September 24, 2007
excerpt: “Google has officially launched Gadget Ads–widgets that advertisers can use to spread their messages across the search giant’s content network…Marketers have the option to target consumers by keyword, site, demo- or geographic location, and their Gadget Ads will compete against text, images and other ad formats for the placement on pages in Google’s content network. According to Christian Oestlien, Google business product manager, Gadget Ads are also backed by actionable metrics. “In addition to the combination of precision and scale, advertisers get a whole system for tracking interactions. They can specify particular behaviors like mouse-overs or clicking-throughs, and get an interaction report in the AdWords Report Center.”
from: “It’s Official: AdWords Widgets = Google Gadget Ads.” Tameka Kee. Online Medua Daily. Sept. 19, 2007. reg required:
Google’s D.C. public policy lobbyists need to do better than echo the same phrases that advertisers have used for decades. Whenever questions are raised about unethical and consumer harmful business practices, advertising companies–now including Google it appears–trot out the same old canard. Google’s policy people say that we should all be thankful that online advertising has given the public “consumer benefits in the form of more online resources and more relevant information…Simply put, advertising is information, and relevant advertising is information that is useful to consumers.” We are happy to debate the issue about the role online advertising plays in the future of diverse content, especially news. We have real concerns about the gatekeeping role Google and a few others will play as the online content market rapidly evolves. But Google has not answered the basic question, months after its announced takeover of Doubleclick. What privacy advocates are saying is that the way Google conducts its interactive marketing business (especially in the light of the proposed takeover) is a privacy concern–not online advertising itself.
Google CEO Eric Schmidt (see his new Financial Times op-ed) wrote that although Google is concerned about privacy, the solution does not “…automatically mean new laws. In my experience self-regulation often works better than legislation – especially in highly competitive markets where people can easily switch providers.” But, of course, with Google’s dramatic expansion, along with the rush to consolidate (Microsoft, Yahoo! and Time Warner, among others), it’s questionable whether we will have competition. Besides, we require national laws, not self-serving declarations from CEO’s whose business model depends on the collection and expanded use of personal information.
We urge everyone to read the CIPPIC petition filed yesterday in Canada asking for a investigation of Google and Doubleclick. Among the key questions raised is whether the two companies are violating Canadian privacy law (Personal Information Protection and Electronic Documents Act-PIPEDA). The full document is on the Canadian Internet Policy and Public Interest Clinic website. But here are some key excerpts raising very important issues. Bravo! (and Merci) CIPPIC.
“37. Googleâ€™s servers automatically record information when the user visits Googleâ€™s website or uses Google products. Google server logs record the search request, URL, Internet Protocol (IP) address, browser type and language, and the date and time of the request, and one or more cookies that may uniquely identify the userâ€™s browser. Google stores server logs indefinitely, but â€œanonymizesâ€ them after 18 months.
38. The act of collecting user search queries and IP addresses invokes PIPEDA, requiring Google to provide adequate notice to users of any collection, retention, use, or disclosure of personal information other than that which can be reasonably implied (in this case, collection, retention and use necessary to deliver search results to the individual user). Without such notice, Google cannot be said to be obtaining meaningful consent from users to any other information practices, including retention and use for targeted marketing purposes.
39. The fact that Google’s search service is entirely dependent upon targeted marketing to users is not evident to the ordinary computer user. It cannot therefore be said that users implicitly consent to the use of their data for marketing purposes, even if such use is central to Google’s business model. Indeed, most users likely do not reasonably expect Google to retain their search queries in connection to their IP address for much longer than necessary to deliver the requested search results.
62. Google collects a variety of personal information about its users and uses that information to, among other things, improve its target marketing services. Online advertising services are constantly being improved, sometimes in ways that involve greater collection and use of personal data. This raises the question of what level of data collection and analysis is necessary for the purpose of target marketing; at what point is Google collecting more personal data than necessary for advertising purposes? No doubt Google is limiting its collection of data to that which is relevant for the marketing purposes, but the test in Canada is necessity, not relevance.
63. CIPPIC submits that a determination of what is necessary under Principle 4.4 should be driven not by what is possible or desirable from an advertising perspective, but rather what is actually necessary for Google to provide the service. The same test should be applied to all online advertisers, not just Google.”
From Online Media Daily [“Google’s Mobile Ad Move Gets Everybody Talking.” Tameka Lee. September 14, 2007] excerpt:
The search giant “is acting fast to take control of the mobile search ad market–a crucial move if it expands as predicted,” said Silicon Alley Insider’s Dan Frommer. And with The Kelsey Group predicting mobile search to generate more than $1.4 billion in ad revenue by 2012, Google is trying to get a jump on what right now is anyone’s game.
Google had been testing mobile text ads since last year, but decided to expand the effort–informing all AdWords advertisers through emails that if they didn’t opt-out, their sponsored links would now be served to mobile searchers…
According to a Google spokesperson, the company went full-scale with mobile search ads, partly because of the sheer volume of mobile-ready ads in place, and because “the mobile space is an increasingly important part of how users are accessing information.
Mr. Fleischer made news yesterday when he presented Google’s call for “global privacy standards” at a UNESCO meeting. Google endorsed the weak (“flexible”) APEC proposal as a model framework. Really, Google should be ashamed. Rather than grabbing the lowest-hanging privacy fruit, the company should be calling for national policies that truly protect us. Google needs to engage in a honest discussion about the role data collection and targeted interactive marketing plays in its business. That’s where Google generates (according to its most recent 10K) 99% of its revenues. The reason Google is on a privacy PR offensive now is because of the mounting criticism coming from NGOs and regulators reviewing its overall approach to privacy as well as its proposed takeover of Doubleclick. Google wants to become, in its own words, the “definitive source of marketing intelligence.” In the digital ad era, that means knowing so much about each and everyone of us it can deliver a steady flow of precisely targeted interactive marketing messages across all platforms.
Can Google be candid? It should return to UNESCO and other national capitals (Back to Madrid, Peter! and to DC too) and explain how it plans to deal with Doubleclick and all the data it generates. Be forthcoming about what kind of data collection is at the heart of its mobile marketing plans. But in addition to honestly informing the public, Google must strive to do what’s right. Otherwise, they are merely a huge corporation more concerned about ever-expanding profits than protecting the public interest. It’s hard to believe they can’t embrace a business model where protecting human freedom and autonomy comes first.
PS: We urge you to read Marc Rotenberg’s comments about the APEC standard Google hails as a model. Here’s a link to a CNET story.
The online mobile space will be hugely important to civil society, communities, and the public. We have concerns about how the mobile marketing “ecosystem,” as its called by the industry, is shaping the new medium to promote a powerful pervasive presence for interactive advertising. It’s a subject this column will increasingly cover, including issues related to consumer privacy and autonomy in the mobile communications era. All the techniques and strategies we see with PC-based broadband online marketing–including the use of behavioral targeting and rich media, for example, have been migrated over to the mobile ad platform. So we think this article from ClickZ entitled “Could This Be the Year for Mobile Ad?” [Kevin Newcomb, 9/11/07] is worth examining. We all know the market will grow dramatically, here in the U.S. and elsewhere. This alone should alert policymakers and public interest advocates to begin better addressing the problems. Newcomb cites a study from the Kelsey Group which says that “the U.S. mobile ad market will grow from $33.2 million in 2007 to $1.4 billion in 2012, a compound annual growth rate (CAGR) of 112 percent.” These forthcoming advertising dollars underscore why Google is so interested in open spectrum; it’s contested marketing territory (Google vs. Microsoft vs. the carriers, etc.).
Here are some telling excerpts from the article, including about Google’s future [my italics]: “One of the biggest drivers of the mobile market will be Google, which needs to find another outlet for its text ads. With the rapid growth of search slowing due to the sheer size of the market, Google will need to look elsewhere to keep investors happy. Mobile ads could be a natural extension of that, since the existing text ad format would also work for mobile, Booth said.
In addition, Google’s advertisers are looking to spend more money with Google, but Google doesn’t have the targeted inventory available for them to spend it on. Analysts estimate that between $1 billion and $2 billion in online ad budgets go unspent, so if Google can offer a way for advertisers to spend that money and get a good ROI, they will spend that much and more, he said.
Google has also made investments in audio ads, both in radio and its Voice Local Search,1- 800-GOOG-411. These ad-sponsored directory assistance (DA) applications are expected to grow from 270 million calls in 2007 to 2.1 billion calls in 2012, a CAGR of 50 percent.
By developing an audio ads platform that it can sell to its existing advertiser base, Google can both break into traditional media markets, like radio, and create inventory in new areas like podcasts and free DA applications, which will be largely a local-mobile space.
Besides Google, Microsoft is expected to make a big push into mobile advertising, in an attempt to beat Google to the punch. Microsoft has been investing heavily in mobile, including the acquisition of TellMe in March, and hopes to extend its adCenter platform to mobile ads as well.”
As Google changes its policies so it can dramatically broaden its reach for advertisers, esp. the ones with the deepest marketing pockets, itâ€™s key to understand what it means for the future of democratically distributed content. We believe Googleâ€™s recent change to its â€œtop rankâ€ formula for paid search ads is important to note. One day, â€œqualityâ€ can be a parameter is helping define what sites show up first; the next, as it works to generate greater revenues, itâ€™s who can pay the most. Here are key excerpts from a two-part story on ClickZ: [my italics] â€œThe change is to the formula used to calculate whether Google gives the advertiser (and specifically, the ad) top placement. Top slots are defined as the slots above the organic results, as opposed to ads shown down the right railâ€¦What changed is the formula Google uses to decide whether to show your ad in the top portion of the page or leave it in the right rail. To have an ad considered for top placement, you need a minimum Quality Scoreâ€¦Assuming you have a sufficiently high Quality Score, the new formula uses a combination of maximum bid and Quality Score to determine eligibility subject to a new minimum price for top placement set by Google.
This allows Google to decide, on a keyword-by-keyword and SERP-by-SERP basis, how much it wants to earn for the top spots. The minimum bid price for top positions is undisclosed and subject to change.â€ [blog note: SERP is the search engine results page]
The search function has become an important part of democratic media. Keeping the leading search engine accountable and transparentâ€”let alone ensuring competition and meaningful access for diverse informationâ€”is key. All of the major search engines, btw, inc. Yahoo! and MSN, require serious public interest scrutiny.