Ad Exchanges, Real-Time Auctioning of Users and Privacy: “our ability to target across many dimensions”

Last week, CDD, USPIRG and World Privacy Forum filed a complaint with the FTC asking it to protect the privacy of U.S. consumers.   Over the last two years, the growth of the data collection, tracking, analysis and targeting industry online–including the real-time auctioning off a consumer based on sets of their data–raises many concerns.  This blog will be covering the field, as CDD works to encourage the FTC and the EU to address the issue.  For now, it’s always useful to see what people from the online ad business say about these practices. In OMMA magazine, here are some excerpts from an article on the topic.

“We are definitely seeing the most exciting things for us in display in our ability to target across many dimensions,” says David Cohen, U.S. director of digital communications at Universal McCann. “Whether that is behavioral targeting or third-party data or our own platform – that is where we are seeing the most excitement – in targetability.” …“If you are an owner of display advertising, this is a great time to be in the marketplace,” says Dave Zinman, vice president and general manager of display advertising at Yahoo, which delivered 521 billion ad impressions in 2009… A new alphabet soup of suppliers and technologies emerged last year that promised at long last to apply better science to the art of display. Data providers like BlueKai or Media6Degrees helped marketers find the right audiences amidst the endless inventory of the Web. Much hope is circulating around real-time bidding (RTB) at ad-exchange engines like PubMatic, Yahoo’s RightMedia and The Rubicon Project. In these models, user data combines with real-time analysis of available inventory so an advertiser can buy individual impressions across a wide array of sites. Your ad appears only when just the right person hits a page… agencies have jumped on board with their own demand-side platforms (dsps) that buy inventory on the exchanges and networks along with third-party data in order to create their own audiences for clients…At the No. 2 seller of display, Fox, Mark Papia, senior vice president of the Fox Audience Network, is as enthused as anyone about the prospects for laser-targeting through the technologies and data layers that have been assembled over the last year. With 158 million uniques combined with data from Fox and 800 other publishing partners, he believes FAN has the scale and data to profit from next-gen display.

source:  Can Science Save the Banner?  Steve Smith.  OMMA.  April 2010.

Health Privacy: Should Health Marketers Be Able to Target You without Opt-in Consent?

We think not.  Consumers should decide–in advance and fully informed–whether they should be sent ads online for health conditions.  Take a look at WedMD’s privacy policy–which like most marketers hides behind claims that the “cookie”–a digital file placed on your browser”–isn’t personally identifiable.  Here’s what it says [excerpt]:

“Even if you do not register with WebMD, we collect Non-Personal Information about your use of our Web site, special promotions and newsletters…

We collect Non-Personal Information about your use of our Web site and your use of the Web sites of selected sponsors and advertisers through the use of Cookies. Every computer that accesses a WebMD Web site is assigned a different Cookie by WebMD. The information collected by Cookies (i) helps us dynamically generate advertising and content on Web pages or in newsletters, (ii) allows us to statistically monitor how many people are using our Web site and selected sponsors’ and advertisers’ sites, (iii) how many people open our emails, and (iv) for what purposes these actions are being taken. We may use Cookie information to target certain advertisements to your browser or to determine the popularity of certain content or advertisements…Third parties under contract with WebMD may use Cookies or Web Beacons to collect Non-Personal Information about your usage of WebMD’s sites. These third parties may use this information, on our behalf, to help WebMD target our advertising on their sites within their network, and WebMD may further tailor the advertising on these third party sites based on your geographic location (zip code), gender and/or age range to the extent known by these third parties….

WebMD Health Manager tailors the information you receive on your personal Health Manager home page to reflect your interests, concerns and personal health characteristics. We attach a concept unique identifier (CUI) to every piece of information that you provide us. For example, if you complete the HealthQuotient and indicate that you have diabetes, that single piece of information is tagged with a CUI that is specific to diabetes. Every user that indicates he or she has diabetes receives this CUI tag. Each time you view your personalized Health Manager pages, this CUI tag is matched to content from WebMD about diabetes, and if our automated algorithms determine that this is likely to be an important topic to you, it will appear on your personalized pages…”

We don’t mean to single out WebMD–the entire online health and pharma marketing industry requires scrutiny from policymakers and other consumer advocates.  That’s why my CDD is asking both the FDA and FTC to conduct a privacy and consumer protection ‘exam’ of this industry.  Don’t you think such a process should be covered under the new–and much needed–national health care plan!

Yahoo to Pharma Marketers: Come `Engage’ & Target Health Consumers Online

As my CDD has explained to both the FDA and FTC, the digital marketing of drugs and health information require serious privacy and consumer protection safeguards.  What may be acceptable when selling cars & travel online using the online ad tool-set is not appropriate when transferred wholesale to such sensitive categories as drugs.  Here’s an excerpt [pdf] from Yahoo!s promotional piece entitled “Social Media:  Pharmaceutical Marketing in the Age of Engagement.”

Social media marketing is a compelling opportunity for pharmaceutical companies to reach their most influential audience. Recent research conducted by Manhattan-based Hall and Partners Healthcare found that online health consumers are hyper-engaged and leverage almost twice as many information sources

to learn about disease states and prescriptions than the average consumer… For every creator of content – a physician writing a blog, for example – there are

roughly 10 synthesizers actively commenting, sharing, rating and reacting. For each group of synthesizers, roughly 100 consumers read, watch, listen and enjoy

while participating only occasionally. All three of these groups have a valid place within the community. event forms. Just as we have built communities of physicians who speak openly with each other about our products, we have an opportunity to nurture and learn from consumer communities as well. First, we must listen with intent…Analyzing what you hear can reveal a gap in consumer awareness. What’s more, a number of tools have emerged to help consolidate the vast array of social media input, from free online evaluators like Intelliseek, to sophisticated and customized tracking services like Cymfony. Once marketers have a firm grasp on the language, attitudes, brand perceptions and key COLs in their consumer community, pharmaceutical company participation can range from targeted media placement to integration and empowerment. All approaches are open to branded or unbranded programs…

“Medical Searches made up 45% of total online traffic”

That’s what Hitwise says, according to a recent report on search engine marketing.  Online ad spending by pharma is predicted to be $2.2 billion in 2011, “up from $1.2 billion in 2008.

source:  Take advantage of pharma sem: Your Rx for success.  Dan Brough.  Search Engine Marketing: Essential Guide.  DM News. 2009

Time for Digital Marketing Wake-up Call at FDA

As we said the other day, we are now covering the online marketing of pharmaceutical and health products. One reason is that we want policymakers to better understand and assess the unique impact of online marketing techniques on the promotion of drugs. Here’s an excerpt from a DTC Perspectives article on the impact of digital media on pharma marketing:

“In video, this means that your target audience will consume three minutes or more of your branded content, and they will do it without being “forced.” Efficiency of the media buy improves, we see brand recall and favorability metrics increase significantly, and this more educated patient is much more likely to ask for a script. In a recent control/test survey conducted by HealthiNation, brand favorability increased by 30 percent over control and intent to ask for a script for the advertised brand doubled…Accurate and true measurement – Digital means you get what you pay for. If you are purchasing media placements to 100,000 viewers who are interested in heart disease, you get exactly that. Each view is counted and reported…”

source: DTC on Demand: The New Era of Qualified Reach for Consumer Rx Advertising. Raj Amin. DTC Perspectives. March 2010.

Black Box Warning Required for Digital Rx Ads

This week CDD expanded its work on public health & digital advertising to include issues related to prescription drug advertising and health marketing online.  It submitted to the FDA, as part of that agency’s proceeding on Internet and social media marketing, comments.  We are speaking on this issue next week in New York.  And we will be dedicating resources via this blog and other venues on the issue.

But meanwhile we will begin by covering some of the latest developments.  In our FDA comments, we raise questions about the online targeting and data collection practices of online health marketers, including the tracking and targeting a consumer by their medical “condition.”  One of the companies we cited was “Everyday Health” and its “ConditionMatch(TM)” marketing system.  Today, that company posted a release saying it was the “faster-growing health network.”  Here’s an excerpt:  GHM audience is up 93% over a year ago — to 32 million unique visitors monthly — due to growth in consumers’ appetite for sophisticated, condition-specific information on niche sites. Advertisers have followed…

One factor driving the ad gains: a precise targeting capability GHM calls ConditionMatch(TM), which profiles “in-market” consumers (people searching for specific medical and wellness information). GHM delivers three primary audience channels: Consumer Medical, Consumer Wellness, and Healthcare Professionals. The Medical Channel delivers condition-specific audiences (e.g., allergy, diabetes, depression); Wellness bridges a marketplace gap by combining fitness and nutrition sites; and HCP aggregates professional website audiences.

“Pharma and CPG brands want condition specific-audiences of scale,” said Bill Jennings, CEO of Good Health Media. “Our site partners attract more a more frequent, loyal audience than broader health destinations online. We’re able to reach people who are actively seeking specific information on partner sites and across the Internet. That’s the ideal platform.”