Google says it’s “at the forefront of a revolution in Marketing”– that includes for the health industry.

One of the areas requiring online privacy and consumer safeguards is the health and medical area.  As CDD told the FDA, the use of behavioral data profiling & targeting, immersive multi-media techniques, social marketing [via stealth-like influencer and word-of-mouth tactics, and brand channels, such as on YouTube, raise a host of concerns.  I don’t believe one’s largely private concerns about a health condition or remedy should automatically be fodder for digital marketing.  To see how important the health online marketing is to Google (and others), here’s an excerpt from a “Consumer Packaged Goods or Healthcare Industry Marketing Manager job opening:

Google is at the forefront of a revolution in Marketing – a shift from traditional Marketing tactics to new online, mobile and social strategies. Google’s advertising platforms provide savvy advertisers with multichannel marketing opportunities, linking online marketing to brand impact and offline sales.

Consumer Packaged Goods or Healthcare Industry Marketing Manager position shapes Google’s point of view on the changing advertising landscape. This leader will uncover, understand and explain the impact of evolving online media to industries that have traditionally relied more on offline media, such as healthcare, CPG, restaurants, education and more. This is a unique opportunity to set Google marketing strategy within our Emerging Industries practice and advise Fortune 1000 advertisers on cutting edge marketing strategies. You will arm the Google salesforce with marketing programs that establish fresh thinking in the industry and deepen engagement with clients…


  • Ideate, develop, and execute marketing campaigns that drive Google’s advertising business.
  • Develop thought-leadership materials, client/executive presentations, case studies and other content designed to accelerate our business momentum and better engage Google’s customers.
  • Develop compelling positioning and messaging for Google’s advertising solutions targeted to companies in industries relatively new to online marketing, such as healthcare and CPG
  • Partner with Google’s market research team to identify, execute and package compelling market research that supports Google’s value proposition to large advertisers in these industries.
  • Evangelize Google’s value proposition, best practices and perspectives to our customers and our industry peers via events, webinars, and other direct client communications channels.

Google to Host Online Ad Lobby as it Campaigns Against Privacy bill

Google is going to help the interactive ad lobby in its campaign to undermine privacy legislation.  The Interactive Advertising Bureau (IAB) plans a DC lobbying blitz on June 14-15, bringing in its cadre of small publishers.   As the IAB explains, “our day of advocacy gets underway as you divide up into teams for individual meetings with members of Congress and their staffs. Each team will be assigned a “chaperone” to help you make your way around the Hill, as well as answer any questions you might have.”

The message the IAB reps will make will undoubtedly be that the Internet way of life as we know it will end if Rep. Boucher’s proposal–or most any other bill protecting privacy–is enacted.  Sort of the Internet meets the film 2012:  all that will be left, if the data stops flowing for targeting, will be a handful of digital survivors.  Google, which serves on the executive committee of the IAB board [along with Microsoft, NBCU, Disney, CBS], plays a key role in the lobbying plans.  The small publisher/lobbyists are to be “guests of honor at a special networking reception and dinner at the Google offices in Washington, D.C.”  Presumably, at the “Cocktail Reception & Dinner – Courtesy of Google,” the troops will be rallied to the `defeat the privacy bill’ cause.  A guest speaker at Google HQ for the event is the IAB CEO Randall Rothenberg.

I know Google uses its facilities to host many meetings;  I have had lunch there and a dinner once at events where Google was discussing its data collection practices.  But Google claims to want to see meaningful national privacy legislation.  Yet they are aiding and abetting the anti-online privacy lobby (which is also leading the effort to undermine the FTC’s role in consumer protection).  The irony here is that Google appears to have successfully convinced Mr. Boucher that its ad preference manager system should be the basis for a safe harbor in the bill.  But Google likely wants to facilitate weakening even Mr. Boucher’s proposal–hence the dinner, drinks and cheer leading that will no doubt be heard across to Capital Hill next month.

Google Paper on “Opt-in Dystopias”: Doesn’t Reflect What Google Actually is doing with data

The Google Policy blog promoted a paper by two Google employees on the opt-in/opt-out policy debate.  The paper is worth reading, but its use is limited because it doesn’t reflect the actual online marketing data collection process.  Here’s what I just wrote on the Google site:

The authors need to revise their paper based on the goals and actual practices with online marketing and data collection done by Google and its affiliates. While it’s true that the binary opt-in, opt-out debate is unfortunately narrow, it is used to address far-reaching data collection and targeting strategies implemented by Google and other online marketers. The authors, for example, should examine Google’s use of neuromarketing for its YouTube advertising products; or the role of purposefully developed “immersive” multimedia tied to data collection by DoubleClick. They should analyze Google’s advertising goals, including what it promises to the largest pharmaceutical and financial advertisers, for example. Or examine the growing role of merging offline and online data collection tied to a specific user cookie to be auctioned off that is now routinely used in online ad exchanges (Google owns one such exchange). They should also reflect on how Google–when rushing to catch up with Facebook in the social media marketing business–launched its Buzz product without a careful analysis of its impact on data collection. Google’s researchers on privacy, in other words, would be more credible if they carefully analyzed how their own company uses–and plans to use–data. This issue deserves a robust debate–and we know the authors are sincere in their interest to make an important contribution. But they should also have been candid that Google is fighting off policy proposals from privacy advocates that would empower a user/citizen by allowing them to protect their privacy–including using opt-in.  The failure to have global policies that protect privacy is the high social and political cost the public should not have to bear.

A Glimpse into Google’s Ad Exchange: Account Execs are to “acquire high revenue strategic leads” while they have “mindshare”

Google is currently looking for an account executive for its Ad Exchange.  Here’s an excerpt from the posting:

As an Account Executive, you will be charged with initiating and growing partnerships with buyers for the Ad Exchange. You must be comfortable selling the value of the Ad Exchange over the phone and in person. Acquisitions representatives will acquire high revenue strategic leads, close multiple new accounts weekly, and maximize revenue performance during a partner’s first 90 days while we have the greatest mindshare…

  • Optimize new buyer performance to exceed quarterly revenue targets.
  • Drive hundreds of thousands of dollars in new 90-day revenue each quarter.

CDD & Consumer Watchdog ask FTC to Block Google/AdMob Deal and also Protect Mobile Consumer Privacy

News Release
Monday, Dec. 28, 2009

Two Consumer Groups Ask FTC To Block Google’s $750 million Purchase Of AdMob
Deal to Buy Mobile Advertising Company Is Anti-Competitive And Raises Privacy Concerns

WASHINGTON, DC — Two consumer groups today asked the Federal Trade Commission to block Google’s $750 million deal to buy AdMob, a mobile advertising company, on anti-trust grounds. In addition, the groups said, the proposed acquisition raises privacy concerns that the Commission must address.

In a joint letter to the FTC, Consumer Watchdog and the Center for Digital Democracy (CDD) said Google is simply buying its way to dominance in the mobile advertising market, diminishing competition to the detriment of consumers.

“The mobile sector is the next frontier of the digital revolution. Without vigorous competition and strong privacy guarantees this vital and growing segment of the online economy will be stifled,” wrote  John M. Simpson, consumer advocate at Consumer Watchdog  and CDD Executive Director Jeffery A. Chester. “Consumers will face higher prices, less innovation and fewer choices.  The FTC should conduct the appropriate investigation, block the proposed Google/AdMob deal, and also address the privacy issues.”

Last week Google said the FTC has made a so-called “second request” for additional information about the deal indicating the commission is scrutinizing the proposal in great detail.

Besides the anti-trust issues, the letter from the two non-partisan, non-profit groups said, a combined Google/AdMob raises substantial privacy concerns.  Both AdMob and Google gather tremendous amounts of data about consumers’ online behavior, including their location.  AdMob, for example, targets consumers using a wide range of methods, including behavioral, ethnicity, age and gender, and education. In addition to its extensive mobile ad apparatus, Google also provides mobile advertising and data driven analytical services through its DoubleClick subsidiary.  The consolidation of AdMob into Google would provide significant amounts of data for tracking, profiling and targeting U.S. mobile consumers.

Read the letter here:

“Permitting the expansion of mobile advertising through the combination of these two market leaders without requiring privacy guarantees poses a serious threat to consumers,” the letter said.  It noted that earlier this year several consumer groups, including CDD, petitioned the FTC to specifically protect consumer privacy on mobile phones, especially involving mobile advertising.

Initially Google was able to obtain its dominance in online search advertising largely because of innovative efforts.  It then moved into display advertising through the acquisition of DoubleClick. When the FTC approved that acquisition, the Commission said it would watch developments in Internet advertising closely. Since that deal was approved, the online and mobile ad markets have evolved substantially, with Google becoming more dominant in the Internet ad market.

“The proposed Google/AdMob deal offers the FTC an opportunity to check Google’s increasingly anticompetitive behavior,” Simpson said. “This deal is yet one more example of Google attempting to eliminate a threat to its power.”   “The FTC must protect competition and personal privacy in the key mobile sector,” noted Chester.

– 30 –

Online Financial Marketing, Subprime Loans, Digital Banking & Neuromarketing–Why We Need the Consumer Protection Financial Agency

How we handle our money–including credit, loans and banking–is moving online.  Digital marketing of mortgages, credit cards, student loans and other financial products will become the dominant way we relate to banking and related services.  The CEO of Capital One has already said that ” [A] mobile phone is just a credit card with an antenna.”  So called M-commerce (mobile commerce) will be a crucial avenue where we actually apply for credit on “the fly,” so to speak, with our cell phones themselves used to buy products.   Banks and other financial companies are using Facebook, other social media, online video, Twitter, search engines and interactive online marketing techniques to sell their services to consumers.  They are also using digital media in PR campaigns designed to make consumers forget about their unethical behaviors which led to the current fiscal crisis.

Financial services companies are even using so-called neuromarketing–testing messages via fMRIs, for example–to help hone their marketing messages.  Neurofocus, a Nielsen backed company that helps create digital and other ads based on brainwave research, released a study  earlier this year that “dived deep into test subjects subconscious minds to discover their hidden, unspoken beliefs and feelings about financial institution brands.” They “tested consumers in its laboratory to determine exactly what financial brand messages they responded to best, at the deep subconscious level of their minds, where brand perceptions, brand loyalty, and purchase intent are truly formed.”  Financial marketers are also using behavioral targeting online, which stealthily collects data on us for tracking and target marketing. That’s why we keep seeing ads for credit cards and other money-related products.  The information gathered as we fill in forms on the Internet  can be sold as part of the online lead generation business.  Online lead generation played a role in the subprime debacle, as consumers provided marketers with personal information that helped trigger pitches for mortgages and other credit.

Alternet has just published my article on these issues.  It can be found here.

Consumer and Privacy Groups at FTC Roundtable to Call for Decisive Agency Action

Washington, DC, December 6, 2009 – On Monday December 7, 2009, consumer representatives and privacy experts speaking at the first of three Federal Trade Commission (FTC) Exploring Privacy Roundtable Series will call on the agency to adopt new policies to protect consumer privacy in today’s digitized world. Consumer and privacy groups, as well as academics and policymakers, have increasingly looked to the FTC to ensure that Americans have control over how their information is collected and used.

The groups have asked the Commission to issue a comprehensive set of Fair Information Principles for the digital era, and to abandon its previous notice and choice model, which is not effective for consumer privacy protection.

Specifically, at the Roundtable on Monday, consumer panelists and privacy experts will call on the FTC to stop relying on industry privacy self-regulation because of its long history of failure. Last September, a number of consumer groups provided Congressional leaders and the FTC a detailed blueprint of pro-active measures designed to protect privacy, available at:

These measures include giving individuals the right to see, have a copy of, and delete any information about them; ensuring that the use of consumer data for any credit, employment, insurance, or governmental purpose or for redlining is prohibited; and ensuring that websites should only initially collect and use data from consumers for a 24-hour period, with the exception of information categorized as sensitive, which should not be collected at all. The groups have also requested that the FTC establish a Do Not Track registry.

Quotes from Monday’s panelists:

Marc Rotenberg, EPIC: “There is an urgent need for the Federal Trade Commission to address the growing threat to consumer privacy.  The Commission must hold accountable those companies that collect and use personal information. Self-regulation has clearly failed.”

Jeff Chester, Center for Digital Democracy: “Consumers increasingly confront a sophisticated and pervasive data collection apparatus that can profile, track and target them online. The Obama FTC must quickly act to protect the privacy of Americans,including information related to their finances, health, and ethnicity.”

Susan Grant, Consumer Federation of America: “It’s time to recognize privacy as a fundamental human right and create a public policy framework that requires that right to be respected,” said Susan Grant, Director of Consumer Protection at Consumer Federation of America. “Rather than stifling innovation, this will spur innovative ways to make the marketplace work better for consumers and businesses.”

Pam Dixon, World Privacy Forum: “Self-regulation of commercial data brokers has been utterly ineffective to protect consumers. It’s not just bad actors who sell personal information ranging from mental health information, medical status, income, religious and ethnic status, and the like. The sale of personal information is a routine business model for many in corporate America, and neither consumers nor policymakers are aware of the amount of trafficking in personal information. It’s time to tame the wild west with laws that incorporate the principles of the Fair Credit Reporting Act to ensure transparency, accountability, and consumer control.”

Written statements and other materials for the roundtable panelists are available at the following links:





A Google Online Ad Goal: “engage advertising agencies and brand marketers in programs that move the needle for their companies”

That phrase is part of a Google job ad for a “Display Account Manager” focused on the auto industry  (based in Detroit).  Here’s an excerpt:

You will drive the online video marketplace forward and engage advertising agencies and brand marketers in programs that move the needle for their companies. The primary responsibility of the Display Account Manager is to drive new business revenue for YouTube and other Google display services and products with Fortune 1000 advertisers across multiple industries. You’ll manage business relationships to ensure that your clients’ needs and requirements are met. Additionally, you will be involved in the operational execution of your clients’ campaigns. This role is not for the faint of heart…Identify and execute on new business with new clients and upsell opportunities for existing clients and prospect within accounts and agencies to uncover leads, new contacts, and revenue.

Huffington Post CEO Opposes Consumer Privacy Safeguards [HuffPost CEO Eric Hippeau Doesn’t Get Privacy]

File this under “we aren’t concerned about the public interest when it may affect our bottom line.”  At yesterday’s Web 2.0 Summit conference, a panel on the future of news included representatives from HuffPo, Google, the NYT and others.  When a question was asked from the audience about behavioral targeting, here’s what Huffington Post CEO Eric Hippeau said [according to the WSJ]:

“it’s much ado about nothing. “I’d much rather see an ad I’m interested in,” he says. Efforts at regulation are made by people who “don’t get it.”

Shame on Mr. Hippeau.   Perhaps he opposes protecting consumer privacy because it would be inconvenient while his company expands its online ad targeting business.  HuffPost uses a range of online data collection and targeting tools, including Pubmatic for ad optimization, and Admeld. It uses Time Warner’s behavioral targeting subsidiary Tacoda [] and also Google’s DoubleClick service.  Here’s an excerpt from HuffPost’s privacy policy:

“The more we know about you, the better we are able to customize our web site to suit your personal preferences and interests… We may also from time to time send you messages about our marketing partners’ products. To maintain a site that is free of charge and does not require registration, we display advertisements on our web site. We also use the information you give us to help our advertisers target the audience they want to reach…the ads appearing on are delivered to you by DoubleClick, our Web advertising serving partner. Information about your visit to this site, such as number of times you have viewed an ad (but not your name, address, or other personal information), is used to serve ads to you on this site. And, in the course of serving advertisements to this site, third party advertisers may place or recognize a unique cookie on your browser.”

Google & ad giant WPP search for scholars who can help them better target teens, mobile users, and promote pharmaceutical brands

For the second year, Google and global ad conglomerate WPP are searching for academics who will apply for their Marketing Research grants.  A look at some of the topics that are listed as “of interest” should help provide you with a better picture of the `brought to you by interactive advertising’ digital world to come:

excerpt:  Google and the WPP Group have launched the 2nd round of the research program they jointly created to improve understanding and practices in online marketing, and to better understand the relationship between online and offline media…

Topics of interest include, but are not limited to, the following:

Online and offline media interaction

  • 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 does offline media affect search and vice versa?
  • What are the best models for mobile advertising?…
  • 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 do you model the consumer response to digital advertising in social networks or mobile media?…
  • How can advertisers be welcome in social networks?
  • How should online audiences and online marketing tactics be measured in emerging markets – Asia, Eastern Europe, Latin America? Does mobile hold the upper hand over online in some markets?…
  • How do teens interact with digital media and what are the implications?
  • Should heavy internet users be given different treatment than light users?
  • How influential are online influencers and what categories of consumers/behaviors are most affected by them?…
  • How can pharmaceutical brands engage more effectively online? How should marketers approach creative development given the full/risk disclosure requirements?
  • What are the unique marketing and targeting opportunities for other verticals: financial services, insurance, entertainment, consumer goods, retail, etc?
  • How do consumers interact with the mobile web and what are the opportunities for retail (coupons, QR codes, etc) within mobile?…
  • What is inhibiting mobile advertising and how can it be overcome? What is the role of mobile advertising in a new marketing communication strategy?