Commentary

A Questionable Endeavor: The MRC Media Auditor Guidelines Project

As reported in MediaPost nearly a year and a half ago, the Media Rating Council is leading a working group through the development of standards for media auditors in the U.S.


In addition to the MRC, the working group is comprised of reps from various industry trade groups (advertisers, agencies and media sellers), as well as individual agency holding companies, advertisers and media-audit firms. However, there are no guidelines or accreditation processes in place for the other entities in the media-buying ecosystem involved in this process.  

Furthermore, many have a vested (financial) interest in the outcome of media audits — being the subject of them — and their inclusion in a process for establishing guidelines of audits is wholly inappropriate.

If Your Waiter Washes His Hands, Can You Still Get Food Poisoning? Of course. What happened to the food before it got to your waiter?

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The concept of establishing voluntary guidelines for media-audit firms, as originally introduced and led by the MRC, has been positioned as necessary to ensure that such firms consistently understand and use third-party media research data appropriately. We fully support that proposition, but as my colleague Thomas Bridge pointed out in a recent MediaPostcolumn, that reality is the tail wagging the media industry’s dog.

The media audit is the final process in the media supply chain, typically conducted weeks or months after activity has run. By this time, it has been planned, estimated, negotiated, bought/sold, stewarded, reconciled and posted by other entities throughout the supply chain (i.e. agencies, sellers and other third parties).  

There are no consistent standards for use of research data across these entities. Indeed, the various electronic platforms are not consistent in their treatment of data. Many people operating the platforms (agency buyers, media sellers) don’t understand the various platform settings and capabilities or the inconsistent math behind them.

Much media audience measurement research (Nielsen, etc.) is accredited by the MRC. Under the current initiative, guidelines would be instituted for media auditors. However, none of the steps between research gathering and audit are subject to accreditation, guidelines, etc. Think about that.  

This would be like approaching food safety by regulating farmers and restaurant servers, but no one else in the food chain. Pay no attention to how the food is processed, distributed, stored, prepared, etc. Then wonder why the food is still unsafe.  Crazy, right?

This is the exact same thing. If the worry is media research data being used inconsistently, irresponsibly and incorrectly — this doesn’t fix it. Any legitimate effort to standardize the responsible use of accredited third-party research data in the media-buying ecosystem must extend to third-party processors, such as buying platforms, media buying agencies and media sellers – not just media auditors.  Otherwise, why bother?  Unless that isn’t really the issue.

Why Don’t Construction Companies Write Building Codes? Because they would have a vested financial interest in the outcome, which might conflict with the safety of the building.  

Frankly, the scope of the media auditor guidelines being created by the working group extends beyond the responsible use of third-party media research data by media auditors. They present guidance on everything from how media auditors should be compensated to how and when they should interface with audit subjects (agencies and/or media sellers) to protocol for communicating findings.

These issues have nothing to do with responsible use of data and are typically driven by the advertiser that commissions the media audit — as they should be.

It could be argued that the inclusion of these areas in the guidelines has occurred because the entities that are the typical subjects of media audits (i.e. agencies and media sellers) are inappropriately involved in a process in which they have a vested financial interest in the outcome. It was at the behest of one or more of these parties that the MRC undertook this initiative in the first place – which was, in itself, not appropriate.  

Underperforming vs. advertiser expectations can cost agencies and media sellers money and time. If these entities can impact guidelines for media auditors that limit the financial impact of media audits, would they do so?  Maybe, maybe not, but it’s a clear conflict of interest.

Entities which have a vested financial interest in the outcome of audits, reviews, inspections being conducted on their work by expert third parties on behalf of their clients (the buyer of the goods or service) do not play a part in writing the guidelines for those exercises. It’s a clear conflict of interest.

What If Drivers Licenses Were Voluntary? Wait. Technically they are, aren’t they?  If you don’t want to get one, you just can’t drive.

The mission of the working group assembled by the MRC has been to craft “voluntary guidelines” for media audits.  However, a key and controversial provision to the guidelines includes a stipulation: Firms that volunteer to adhere to the guidelines “attest” they do so. And, that there be some process in place to police firms to assure their compliance to the voluntary guidelines.

Suggestions for this “enforcement” have ranged from peer reviews by competing audit firms to an “independent” panel to review complaints to a system where complaints are tallied and made available to others in the industry for review.  

There are a few common problems with the various “enforcement” protocols being considered.  

Every situation is unique. No one is better qualified to understand the specific intricacies of a given audit than the advertiser that commissioned it. That is why when an agency or auditor has issues with the process or findings, they go to the client. Clients vote with their checkbooks.

An outside review process introduces confidentiality questions and risks the introduction of frivolous complaints. Agencies and sellers have a financial motivation for minimizing the impact of media audits. Any assertion that a media audit firm is not compliant with the guidelines would need to be thoroughly vetted.

Even under the simplest “file and compile” complaints scenario, there are significant questions. There would still need to be a process for assuring that complaints are material and not frivolous. Who would be responsible for doing this? The MRC?  

The MRC’s mission statement is: “Secure for the media industry and related users audience measurement that is valid, reliable, and effective; to evolve and determine minimum disclosure and ethical criteria for media audience measurement services; and to provide and administer an audit system designed to inform users as to whether such audience measurements are conducted in conformance with the criteria and procedures developed.”  

The MRC’s industry-funded work in establishing and administering standards for audience measurement providers and auditing and accrediting those providers is an essential function in today’s complex, multi-billion dollar paid media ecosystem. However, this project and any ongoing “enforcement” support the MRC might engage in seems to extend beyond its stated mission.

Clearly, the objective is to have all audit firms “volunteer” to adhere to the guidelines. Which would be fine if the guidelines appropriately covered the entire paid media ecosystem (which they don’t) and if the discussion were being driven by advertisers rather than sellers (which it isn’t).

Audit firms have every right to be concerned about this process and the potential implications of agreeing to the “voluntary guidelines” and the attestation process, which will apparently come along with them.

Ultimately, these “voluntary guidelines” are voluntary and guidelines in much the way that a driver’s license is a voluntary guideline. If you want to drive legally, you must have one.  And if you don’t adhere to the rules, it will be revoked.  

The introduction of an “enforcement” protocol to these “voluntary guidelines” makes this entire endeavor look a great deal more like a certification or an accreditation.  And, again, if that is the approach, then it should apply to all entities throughout the supply chain.  

Will attestation of adherence to these guidelines become a prerequisite for media auditors in the U.S.?  We will be asking our clients (who spend upwards of $20 billon in paid media in the U.S.) for their thoughts on exactly that question in the coming weeks.

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