Commentary
So Much For The Con, Now Let's Hear About Some Pros
- by Randall Rothenberg , January 25, 2010
Last week, Online Publishing Insider columnist David Koretz asserted online "publishers are committing fraud" (Online Publishing Insider, January 21), but it's Mr. Koretz who is conning MediaPost readers. As chairman of an online advertising company, he either knows and is hiding the fact that the advertising, marketing, and media industries are driving the largest and most comprehensive self-regulatory program in interactive-sector history -- or he doesn't know and is making uninformed accusations about his competitors in the interactive advertising and media industries.
Here are some of the facts:
- In July of 2009, a coalition led by the Interactive Advertising Bureau (IAB), the American Association of Advertising Agencies (AAAA), the Association of National Advertisers (ANA), the Council of Better Business Bureaus (BBB) and the Direct Marketing Association (DMA) -- which together represent more than 5,000 U.S. companies -- announced the consensus passage of broad cross-industry Self-Regulatory Principles for Online Behavioral Advertising, and the development of an independent enforcement mechanism to be led by the BBB and its National Advertising Review Council self-regulatory arm. These principles embrace and expand on the concerns raised by consumer groups and by the Federal Trade Commission. The principles were praised publicly by FTC Chairman Jon Leibowitz, who said: "These guidelines are a direct response to the call by the FTC and consumer groups for improved practices, including increased transparency and consumer control over the collection and use of data. I commend the coalition's efforts to bring together many diverse industry players to address privacy." FTC Commissioner Pamela Jones Harbour similarly praised the industry's work and strong commitment to self-regulation, and said, "I am gratified that a group of influential associations -- representing a significant component of the Internet community -- has responded to so many of the privacy concerns raised by my colleagues and myself. These associations have invested substantial efforts to actually deliver a draft set of privacy principles, which have the potential to dramatically advance the cause of consumer privacy."
- Since the release of the self-regulatory principles, the associations involved with the effort have committed $600,000 to NARC to launch the self-regulatory mechanism. Work on its construction has begun; as was reported last week, an RFP was issued by the BBB to technology service providers to help build the infrastructure. NARC is best-known for its widely praised track record in monitoring and enforcing standards in children's advertising, through its Children's Advertising Review Unit.
- Publishers have further stepped up to the plate by launching, through the IAB, the industry's first-ever advertising and service campaign devoted to protecting consumer privacy. With creative and media planning donated by WPP's Group M and Schematic, and with a half-billion impressions (and counting) donated by 25 publishers, the "Privacy Matters" effort was called "helpful" by the head of the FTC's Bureau of Consumer Protection, David Vladeck. We expect at least 1 billion donated impressions to be donated for the campaign this year.
Instead of sitting on our "collective asses," as Mr. Koretz ignorantly charges, IAB publisher members and staff also have testified before the House of Representatives and the FTC; brought more than 30 member companies to visit more than 50 Congressional offices; released a comprehensive study by Harvard Business School Professors John Deighton and John Quelch on the economic value of the interactive advertising ecosystem; hosted Virginia Congressman Rick Boucher (the author of a forthcoming "Internet privacy" bill) for a candid give-and-take at an IAB Board meeting; and written many Op-Ed pieces, blog postings and letters showcasing the value and opportunities inherent in (and historically associated with) advertising self-regulation.
We also have lobbied Congress and the FTC repeatedly and aggressively on a subject Mr. Koretz pointedly ignores: the proposals circulating in the House, the FTC, and in state capitals like Albany would destroy much of the interactive advertising industry. Why? Because these proposals label virtually ALL data exchanges that take place in interactive media -- no matter how benign -- as "behavioral," and place them all under a strict regulatory regime. Third-party ad-serving, most display advertising delivery, zip-code-level targeting, page-caching and delivery, and many of the other consumer- and business-friendly aspects of interactive advertising and media would be restricted under these proposals -- without protecting consumer "privacy" in the least.
I'll assume Mr. Koretz is not intentionally hiding all this from his readers, and honestly doesn't know all this is going on. So I'll conclude with a recommendation: Rather than writing inflammatory and badly reported Op-Ed pieces, he and his companies should join IAB, where we are working with some 400 companies he wrongly accuses of doing nothing -- and through our sister associations, with thousands of other marketing, agency, retailing, and media companies -- to create strong, meaningful self-regulation for our industry, and avoid the deleterious regulation he rightly decries. In fact, if Mr. Koretz is so worried about the industry's relationship with consumers, we urge him to follow the lead of his industry peers and put his money where his mouth is by donating ad inventory and funding to the IAB Consumer Protection & Education Campaign, where he'd be joining such IAB members as 24/7 Real Media, CBS, Burst Media, Hulu, Google, Meredith, Microsoft, NBC Universal, The New York Times, Washington Post, Yahoo, and dozens more in protecting our consumers and our industry.
I have already saluted David Koretz and his article "The Fox Guarding the Hen House" and not just for what he has written, but for the general stance he has taken and mostly against what you (yourself) have penned.
And rather than your 'attacking' him as you have done so above, I believe that there is still a 'compromise' or, two that should be considered and if given reasonable though to, could even prove to be a 'win-win-win', for all concerned.
Not just those on the demand side (those advertisers) that you appear to be 'falling over backwards' for in helping them achieve all they are wanting, but so too, for the bulk of your membership.
And perhaps even a case of 'God helps those that help themselves'? Or, are we (the members), all "yes" people? And after-all (I guess?), it is those very same advertisers who do ultimately pay the checks, no?
But it really does appear to me that the IAB is handing it all to them on a silver platter without giving it much of a though, at all. And (in time), will get to regret of your doing so.
You advised all, that....
**-..... The principles were praised publicly by FTC Chairman Jon Leibowitz, who said:
"......These guidelines are a direct response to the call by the FTC and consumer groups for improved practices, including increased transparency and consumer control over the collection and use of data. I commend the coalition's efforts to bring together many diverse industry players to address privacy." - **
Does FTC Chairman Jon Leibowitz have any inkling of 'future' applications that can be used, relating to the further 'fine tuning' of the collection and use of data including 'behavioural' targeting, I would ask? - Individual's IP "addy" next? Effectively do, you say? Has he any idea of (other) developments that may be in the pipe after it all dies down?
Do we then get see a 'divide and conquer' of publishers with the smaller variety falling by the wayside, simply as a result of their not having the kind of lobby support as do the existing, many Premium members of the IAB? (And maybe [only], due to size and general affordability of such membership? - Their suitability and acceptance of as members is your concern, I guess.)
Yet, the opportunity is still there for a compromise (at all levels) and the solutions are so simple. Where 'everyone's a winner' ...
I propose that the all important mining of data for use in conjunction with any "behavioural" serving purposes be permitted, ONLY on users that are 'visiting' all publisher sites from down in the secondary or, that considered as being the remnant Ad marketplace.
And that the use or, application of "behavioural" targeting of individuals can only (then) be conducted on or, at all (considered) 'safe' sites Those sites declared or, accepted as being of the best (safe) premium level, by the IAB.
I propose that users can then get to elect to ONLY "op-out" on the (those that the industry consider as) Premium sites that they visit and that they do get the option to easily do so from a browser 'op-out' button clearly made available to them.
This then ensures that a "family" PC that's shared can (also) be 'safe' for all family users. (With my own odd research conducted on say, porn and some other sites, let me assure you that the ads that are currently being 'served' to me are NOT indicative of the kind of ads that I want my daughter to be then confronted with, when she happens to be using the 'family' PC).
The basis of my (above) proposal should hold no fear (then) for users, in that THEY always will get to elect as to whether they would not like to be 'targeted' with Ads and Ads that are (and would prove) more to their interests or, likings. Smart move, many would agree.
Marketer would love this too and would mostly enjoy much healthier ROI's (across the board), in reaching near on 100% users with either an 'open mind' & outlook or, who may have a definite understanding of or, an affinity for their product or, service being offered to them.
(We are by now targeting individual users. - And, customers, hopefully). And if it has been said that the easiest thing ever to do is to get a new customer and that the hardest thing... is the holding on to them, marketers will surely (then) want to 're-target' such customers on a regular basis, no? Forget about as to how long data is stored for, etc. And who was ever going to be able to 'police' this, anyhow?
Premium publisher sites can then get to see an 'across the board' base (and, meaning, a 'flat rate') eCPM value to commence any auction from.
One that is 'set' (by) and then regularly reviewed by your own IAB - A panel of members (?) and can or, should then equally be applied to all (those many), other publishers. (Non members). That are all, equally considered as being (safe), premium sites.
And, all premium publishers (across the board) can then individually choose (or, elect) to move this 'base' price downwards, should they wish to do so.
Secondary publisher sites or, those that are considered as being 'unsafe' for many Brands to be associated with (along with all or, any other such inventory presented by a premium publisher, that only attract a remnant Ad selection), can again have that same, (a) minimum base price set to start the ball rolling.
And like-wise, secondary market players can (should) also have that option to move this bench-mark price lower (or, naturally, higher), accordingly.
Advertisers (and some brands) can then get to find some "bargains" (over time), down in the basement. And (at the same time) get to collect data or, other 'user' intentions too, if they want the kind of 'exclusive' data or, of the unique aspect that they are looking for. The competition in mining or, 'data collecting' will or, can help in upwards movement of eCPM's, in many cases.
The object here is to install a stronger value on secondary (or, considered non premium) marketplace 'user visits, for marketers to then have a need to always "shop" for that 'treasured' data themselves, at this level.
There-by (as mentioned), effectively raising the price (generally), for all the publishers in this remnant ads marketplace division and will then see it result in both marketplace remaining competitively placed, against each other.
So, we end up with a situation where users are free to "tell it all' (and, as they now do so) on social sites, in their E Mails & about all their likes & dislikes, but get to always have control of that option to want to be served Ads, in line with what is considered their current learnings. Premium sites can then, all have an IAB (approved) "logo", common to all.
All publishers (globally) can then become (token) annual fee paying affiliates of the IAB and with a small (commitment) Fee deducted from any (Network) payment schedule at around renewal time, once a year. (Could even be a micro percentage payment per transaction, deducted by an administrator?)
The IAB can then be an appeals process (for anything that cannot be resolved from down at a network level) with it's minimum involve generally being, publishing the current minimum (daily) 'bench-marks' (and set via an IAB, 'balanced' member consensus panel), or, what is those premium and secondary market 'base rates'.
Details of which (the above) can be placed on a page or, two on the IAB Website. (With placement of either Geo'd or, behavioural 'premium Ad' in support, of course).
Cheers!