Committing Social Media Suicide – No Really, Read This

Over the last two years of explosive social media growth, I have written several times about the growing issue of information and inbox overload, and the dunbar number and ambient relationships. I’ve observed a segment of consumers going on social media diets, if you will, eliminating social media from their lives or at least restricting it to limited networks and a limited amount of time.

Enter SuicideMachine.org, a service that automatically deletes your social media life, in some instances with no possibility of reinstating it. Facebook is taking them seriously enough to ban the service from accessing their servers.

I’m still not sure how much of this is parody and how much is serious. The service itself is for real, but is this a trend that taps into consumer desires? Are that many people this fed up with social media infringing on their “real lives”?

“My internet life is dying, but my real life is starting”

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Where Digital Marketing Is Heading in 2010

At the risk of sounding cliche, welcome to a new decade of marketing. Indeed it is an exciting time to be a marketer. The past decade may prove to be the most pivotal ever in terms of the changes in how we communicate with consumers. It was also the decade of aggregation – or better put, the decade that killed the “big idea”. The era of the big idea is over (in the context of marketing communication). Since the explosion of digital marketing during the last decade, the new big idea morphed into an aggregation of many smaller “ideas”. This aggregation has a bigger impact than any one “big idea” ever could, by distributing risk and providing more chances to develop successful approaches.

Marketing evolution continues in 2010, and here are some of the areas to keep your eyes on.

Mobile Forges Forward

We keep joking about how “this year has been the year of mobile for the last few years”. Well, we’re waist deep the age of mobile and moving further along every day. We’ve crossed the proverbial tipping point. The handsets and data speeds provide better experiences, and the data plans are affordable. Over 60 million US consumers access the web via mobile device.  Globally we’re on track for more people to access the mobile web than the PC web (of course I’ll need to save that post for Jan 2020). The thing is, the distribution of this access is skewed, significantly towards the iPhone. While the iPhone catalyzed mobile web usage, competition is not far behind with the Droid, Pre, new Blackberries and other devices to come in 2010. Consumers are using, and even paying for mobile applications and mobile websites that provide value. Of course, as with any marketing channels, there are plenty of misguided executions that do not focus on the consumer, provide little value and flop. Unfortunately oftentimes the medium gets blamed for poor strategy on the part of the marketer and/or agency. Provide experiential or utility-based value to consumers and you’ll reap the rewards of consumer engagement. Additionally, keep your sights set on the convergence of mobile and social experiences as well. This will prove big in 2010.

Location Based Applications

As consumers become more comfortable with GPS enabled smart phones and the first generation of applications that incorporate GPS into the experience, the marketing opportunities that utilize geo-location data will come to fruition. However, it will be 100% predicated on permission, transparency and trust. Of course the recurring theme of providing actual value to the consumer experience is key as well. An early success story is FourSquare, which combines social actions and geo-tagging. But FourSquare is definitely not for everyone. Marketers will have to provide utility in order to gain access to consumers’ private lives and  geo-location data. A few bad apples can spoil the bunch very easily here. Where your brand attributes meet consumers’ needs is a good crossroads to  aim for. Note: If would be interesting to see Facebook acquire and incorporate FourSquare into their current platform.

Real Time Search & Social Search

As social media has become ingrained in the digital media experience for consumers and marketers alike, real time search was inevitable. Information is distributed via so many channels including consumers’ social media feeds, that not including real time data in search results created a void in the relevancy of search results at the major engines. Google’s roll out of social search results from “people in your social circle” also fills the void that was otherwise filled directly from the social media sites like Twitter and Facebook. Real time search will indeed make search results more relevant, but the algorithms for filtering signal to noise will be an interesting evolution to watch and participate in.  The implications for marketers is a new era of SEO that ties even more tightly into social media.

Social Media Expands Its Journey

There are two major areas to keep an eye on here. First is the portable social graph. Facebook Connect really took off in 2009, and 2010 marks the tipping point for social graph / data portability. The social graph is just beginning to become part of the overarching digital platform. Through this ubiquity consumers are empowered, taking the influence and social activities of their social connections with them everywhere they go (well not everywhere, but soon enough). Check out one of my favorite implementations of Facebook Connect so far in the Prototype trailer. Try it out. It takes a minute to load, but it’s worth the wait.

The social graph has become portable on the PC-based and mobile web, and the second area to keep an eye on is the expansion of the social graph to your television. Samsung was the first to release high end flat screen TV’s with internet based widgets that allow you to access Twitter on your TV (currently via Yahoo, but inevitably this will become more open very soon). Expect the social graph to become a standard part of our TV viewing experience in the future (note: not in 2010).

Multiple Attribution

While all marketers would agree that reaching consumers at multiple marketing touch points is essential, most marketers still maintain disparate data systems and utilize the last ad standard protocol when it comes to attribution of influence or conversion.  Multiple attribution tracking capabilities have existed at the major ad servers for a couple of years now, provide a solution to attribution modeling, yet are underutilized by the industry. Third parties, such as ClearSaleing, also offer dashboard, reporting and analytics platforms to provide multiple attribution reporting for marketers. Let’s face it, we are constantly increasing the number of digital marketing channels we are working in and as an industry our analytical capability, or more accurately – marketers’ and agencies’ willingness to utilize the tools available,  has been lagging behind . Some of the dashboard tools can also incorporate a limited set of non digital channels as well. If you are not using a multiple attribution system currently, make 2010 the year to do so. There is simply no excuse not to.

The Privacy Issue Marches On

Privacy is always a heated topic. This has been true since the dawn of digital data collection. The issue is over-hyped by the media and advocacy groups, however there are some underlying truths to the hype. As we have seen with the privacy policy changes on Facebook over the last year, if nothing else, consumers do pay attention and now have the means to spread the word quickly.  As digital marketing technologies evolved, more parties gained access to more data. Although most of this data does not actually contain personally identifiable (PII)  data, in some instances it can be associated with other data assets that do. Tying the  vast amounts of anonymous and PII data together will become a bigger focus of the FTC and advocacy groups as the portable social graph  continues to morph the internet as we knew it into one big social web. The FTC warned the industry in 2009 that a day of reckoning was near, and that the self governance was not working due to a lack of enforcement. The industry will have to take the issue more seriously in 2010 or the government will do so for us.

Augmented Reality

For the uninitiated, augmented reality (AR) is conceptually any technology that ties the real and virtual world’s together. For the mobile device, AR will utilize the built in GPS, compass and video camera, creating an unlimited potential to layer content onto any physical location in the real world. On the PC, AR utilizes the webcam to overlay data, usually in the form of a virtual hologram. Most of the augmented reality executions to-date have focused on the novelty factor and have not provided consumers with much actual value. The few mobile AR applications available, including Yelp, are beginning to provide actual utility. I see a bright future there. On the PC side of things, the USPS Priority Mail box simulator is by far the most useful application of PC/webcam based AR implementation to date.

The key to AR is to hone in on the utility aspect, and provide real value to the consumer. (That concept is starting to sound awfully familiar, huh)

Long Live Display

Display ads get a bad rap. The reality is that online advertising works, and not only for direct response. While search see’s the lion’s share of industry ad spending, display is a standard part of the mix and will continue to be for the long term. That is not to say that display doesn’t have its issues. Lack of creative prowess, challenges with media currency and an inefficient process still plague the industry, but all are common topics of conversation and ad hoc work-arounds are being implemented every day. Most agencies and media buyers have had to develop large infrastructures to support the inefficiency of digital media. Clients constantly challenge the process and costs. Yet very little industry-level research is being conducted to better the situation. The IAB, nor any other industry body has set forth to develop the correlational research required to make advertisers feel more comfortable about the market-level impact of online advertising. The last industry-level research was released almost 10 years ago. Some individual agencies embark on this type of research on a client by client basis, but there is little public domain research readily available for most marketers, who for the most part, park the vast majority of their brand budgets elsewhere. Hopefully in 2010 we will see more industry collaboration to develop research and studies and the tools and systems to create more efficiency in the media buying and management process, without commoditizing it.

Even with all that said, display ads do work at creating influence, this can be and is measured by many marketers and agencies, and display is a standard part of the media mix just like any other medium. The degree of inclusion is what is in question, and hopefully we will at least see more discussion and proposed improvements that make advertisers confident to allocate more brand dollars online.

The Elephant in The Room … The Economy

All indicators lead to a slow and steady economic recovery ahead of us.  But this will happen at a different pace for each category and client. The reality for digital marketing is that most marketers have not been and won’t be experimenting much, and focusing on the more accountable (read – DR) focused channels and tactics. I do expect budgets to open up for social media and mobile. Amid the greatest recession of our lives we witnessed the explosive growth of social media. Some marketers had the budgets to allocate proper resources to understanding, monitoring and integrating social media into their corporate culture, while others put forth a minimal effort and yielded an equal impact. The brands that embraced social media have developed social voices separate from their brand voices and are on their way to becoming accepted social brands. Most are still playing catch-up, and we’ll see a lot of that in 2010.

So there you have it, some areas to keep your sights set on for 2010 and beyond. Have any additional thoughts about what else will be big in 2010? Post your ideas in the comments.

Consumers Are Just Not That Into You

Seems like most marketers are still having a hard time understanding that consumers really don’t care about our brands. Sure, the Nike, Starbucks, and Apples of the world have iconic brands that consumers are truly fans of and are proud to flaunt their association with these types of brands. But for the average marketer, large or small, there comes a realization that although every brand has its advocates, the size of their advocate pool is much smaller than they’d like.

Enter the misguided Facebook “strategy” that is so rampant today.

Folks – Facebook, like the internet itself, is not a magical parallel universe. It won’t  make people love your brand. People just need to love your brand…or at least like it, and then you can nurture those relationships.

There is no commitment in becoming a fan of a brand on Facebook. It takes one second to click the ‘Become a Fan’ button – commitment over. Either you will or will not engage the consumer from this point. Most brands do a poor job. Particularly when most of the content  posted is about you. This week alone, I pointed out to four clients and prospects  who launched Facebook pages this year, that the posts in their Facebook pages that had the most engagement EVER were their thank you posts to veterans on veteran’s day. Why? Simple – because these were the only posts that had absolutely nothing to do with the brands. Although I’ve explained this concept several times before. This instance really opened their eyes.  A new, enlightened era is upon them. Facebook status updated: [Insert Brand Name here] saw the light.

Mobile Payments, Coming To an iPhone Near You

interactive_quickOrder_2Aren’t the constant glimpses of the future in our everyday lives awesome. I just downloaded the new Starbucks applications on my iPhone and caught one of those glimpses.  Note: I’m not sure why they split these apps into two, I was unhappy that this now takes up two spots on my iPhone deck and the two apps should have been one – just one of those dumb things smart marketers do. But I digress and don’t want to take away from the innovation here.

One of the apps is exactly what you would expect from Starbucks – you can find store locations, hours and features and you can build your regular drinks and share them with friends so they have your order for the next coffee run (for the record the Dunkin’ Run app offered that utility first). It’s clean, it’s intuitive, it’s a great app that we’d expect. The second app however is a mobile version of the popular Starbucks card, and this is where you can glimpse into the future with me. Close you eyes and join along (well, metaphorically. please don’t close your eyes or you can’t finish reading this post.)

In 16 test stores (8 in Silicon Valley and 8 in Seattle) mobile Starbucks card users will actually be able to pay for their orders at point of sale (POS) with their iPhones. Starbucks has installed special barcode scanners  that are capable of scanning semacodes, which would be created by the card holder for each order. Quite literally, your iPhone becomes a mobile Starbucks card. 

interactive_quickOrder_3

So – why is scanning a barcode innovative you say? Well, conceptually it’s not. But the challenge we have faced with mobile coupons and barcode scanning stem from the fact that the mobile handset emits light and the barcode displayed is an image that is being emitted as part of the light. Current barcode scanners at POS everywhere cannot scan a code on a handset! It is an issue that many smart technologists are working on solving, and present a market-level opportunity. JC Penny, as an example, is the first national retailer experimenting with the deployment of mobile coupon scanners. It’s big news, albeit only a test in 16 stores for now (not sure what’s up with these 16 store tests). The stores required new scanners – to be specific, the Motorola DS9808 digital imager scanner, which can read 1D, 2D and PDF-417 bar codes. I trust that we’ll all agree that once mobile coupons and barcodes can be scanned at (POS) at retail everywhere, we will see another boost in mobile participation from consumers and marketers alike. Call it coupon clipping 2.0. This aint your grandma’s couponing!

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Uniformity Across Social & Mobile Applications

mobile-socialFollowing last week’s DigiDay Social & DigiDay Mobile conferences,  I had a chance to brainstorm about how social and mobile marketing were becoming such interconnected bedfellows. The trend is only strengthening.

Consumers are looking for experiential and utility value in social and mobile channels. The experiences we provide consumers are converging, and becoming less about the channel, platform or destination, and more about experience itself (I’d argue that it was always that way),  the development, distribution and measurement of these distributed experiences must strive for complete interoperability.

Currently, devices and platforms have various protocols and standards that make this a lot of work for developers, and more importantly, a major expense for companies. The end result – few companies have a consistent digital experience to offer consumers that transcends any platform or device the consumer chooses. Consumers want this, marketers want this.

Enter Adobe…yes, Adobe.

Apparently Adobe plans on creating uniformity across social and mobile applications.  Essentially a developer could build flash-based apps in a to-be-released authoring tool, that will be customized to deliver experiences to consumers in each native environment. Sounds like the holy grail of a uniform experience across various social platforms and channels. Of course the acquisition of Omniture will provide deep analytics into the performance of these distributed experiences. Adobe, I applaud you for taking this stand.

Not The First Time

Flash has been the basis of rich experiences online for over a decade. And why wouldn’t the makers of Flash want to maintain and even bolster this ubiquitous position? Those who have been in the digital media space for sometime remember when Macromedia (original brand that developed Flash) partnered with Doubleclick to develop DART Motif. Well, Macromedia’s involvement was limited, but the strategy was the same – create a level of uniformity between otherwise disparate systems that develop and deliver Flash-based experiences. Times have changed, and Adobe has far more skin in the game now. This is a big play. This can be a major boon for the  entire ecosystem – developers, marketers, content providers, and of course consumers.

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Commoditizing Valuable Service- “We Didn’t Budget For This”

Agencies have become commoditized. To a degree many may have deserved it. But a good strategically minded agency is a good partner and needs to be treated as such. Commoditized agencies have no problem doing spec work, or bowing to clients’ every demand. Clients – I love you, how can I not, but if you see yourself in this video, know that you are often hurting yourself more than your agency or partners. The reality is – good work is not cheap. As the adage goes: Pick two of the following: Fast, Cheap, Good.

Enjoy!

Augmented Reality – The Future Is Now

Augmented reality, recently in experimentation mode and mocked at by many in the advertising industry as a gimmick, just grew up.

Layar is the first official augmented reality app, and guess what – it’s not available for the iPhone…yet. So I downloaded it onto my wife’s Android phone (thanks baby), and I am proud to say that the future is now folks. Augmented reality in mobile apps mark the beginning of something HUGE.

For the uninitiated, augmented reality (AR) is conceptually any technology that ties the real and virtual world’s together. For the mobile device, AR will utilize the built in GPS, compass and video camera, creating an unlimited potential to layer content onto any physical location in the real world.

This promo video from Layar and the video from Yelp below are great examples of the potential. I’m excited!

Yelp is officially the first iPhone application that supports augmented reality, however, it seems to be a hidden  feature in the app since it’s technically not supposed to be ready for prime time yet. If you have an iPhone 3Gs, download the Yelp app, shake the hone three times and the AR icon will appear. I know it sounds silly, but it’s actually kind of a cool way to unlock the feature. Really, I’m not trying to make a fool of you shaking your iPhone all about. Now you can point your iPhone at a restaurant and the reviews come up – sans searching. Did I mention this was going to be HUGE! Kudos for Yelp for implementing the perfect complimentary feature for their app early. They are going to kick butt with this.

And I think this is the first full fledge AR iPhone app, which is a version of the New York City subway map – outstanding!

Some examples of the first generation of AR application in marketing are sort of snoresville (except the Star Trek one, check that out below). There is definitely a novelty factor to it, but I don’t see these AR ads going very far. It’s just more of the same, with a twist - but still feeble attempts by marketers at getting consumers to care more about their ads versus providing experiences that consumers truly value. Here’s how it worked — A print ad or computer print out, is held up to your webcam (yes all of the existing marketing applications of AR require the use of your webcam), and you can then see and interact with a three dimensional advertisement on your screen. “Hey buy my stuff (in 3D)”

Here is an example of one of the Best Buy circulars that incorporated AR (you can also see more on the Best Buy in 3D website)

BB

The GE Smart Grid ad (one of the first US-based AR ads) was more of a brand campaign and included a neat interactive component.

Super cool Star Trek Trailer (I’m not a Trekie, but totally geeked out on this one)

My buddy Adam Broitman’s new firm Circ.us recently launched an AR game as a marketing asset for A&E Television’s Chris Angel. I like the application of AR in a game format. People want to play games, they don’t necessarily want to interact with advertising as much.

So there you have it folks. With the new mobile operating systems’ ability to handle this type of technology, we are about to witness an explosion of innovation that will benefit consumers and marketers alike. Think about it…any physical location, anywhere in the world can be layered with content (information, reviews, photos, videos, commerce).

 The future of augmented reality is now!

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One Marketer’s Reflection On A Career Changing Moment

Iidea_bulb‘ve been so busy with projects that I have actually let a month go by without posting to the DigitalBlur. I can’t believe it – shame on me! 

Therefore, after a bout of silence, maybe kicking off  with a fairly self-serving guest blog post is a little cheesy. But hey –  in this crazy fast paced and often thankless world we live in, it’s always nice to get some additional inspiration from the kind words of others.

Thanks to Tim McHale, Managing Editor of Madison Avenue Journal, for the (unsolicited) words of inspiration.

by Tim McHale

I’m compelled to shout from the rooftops about a career-enlightening moment, facilitated by Jason Heller.

I recently attended a social media marketing course led by Jason for Laredo Group. He was outstanding. It was like the perfect screen play.  Each line and/or action draws you into the story so quickly that you almost immediately experience a ”Suspension of disbelief.”  The difference here though is that I experienced a “Suspension of belief.” The belief that I thought I knew almost everything I needed to know about social media, before I walked into the room.

When is the last time you did not step out of a conference room or event to take a phone call or catch your breath? When Jason announced we should take a 10 minute break, everyone around the room was almost like, “Oh, really? Why?” That is no joke.

At the end of the day I was speechless. Those who know me can vouch that is indeed a rare occasion, even when I sleep, or so my wife tells me.

In essence, the ultimate reason I found myself short on words was due to the fact that I had what you might call an “aha” moment. I wanted to savor it personally because it happens all too infrequently. Most insights we enjoy come about more gradually.

It was a paradigm change in how I view social media, and now, the media business overall. Did I know a lot about social media going in?  Yeah. But for me, what I walked away with was that all-too-rare sense of buoyancy, the feeling of being nimble, a Butch Cassidy quality that makes you smile and excited about what awaits you. You can’t put a price tag on that.

As consultants, sales people, agency execs and many reading this blog might agree, we make a living from sharing credible knowledge about the media business of yesterday, today and every so often, about tomorrow. For me, those who boast that they have the same level of confidence and insight into the future are kidding themselves.  Or at least that’s what I thought before the training.

Actually come to think of it, there was only one thing that really p-ssed me off; envious in fact. Heller not only has a full head of hair, he has a pony tail, no less!

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United Airlines Breaks Guitars, Can Social Media Fix Them?

In a moment of David v. Goliath gloUnitedry, a United Airlines passenger, David Carroll of the Canadian folk band Sons of Maxwell, has become an interesting thorn in the side of United’s marketing department after his revenge video goes viral on YouTube and beyond.

The backstory here is that about a year ago, Carroll’s guitar was broken by United baggage handlers. After nine months of red tape and ultimately a denied claim for damages, Carrol produced a song and video about the incident. As of this posting there are over 3,250,000 views and over 15,000 comments. It is the fourth link down in the organic search results fo the term “United Airlines” – a classic example of how social media reflects real world problems, and can be amplified to the point of a major PR nightmare for a major brand.

The blogosphere, twitter, and even traditional media (including the Rolling Stone and CNN) picked up the story. United Airlines breaking Caroll’s guitar was in fact the biggest thing that ever happened to his career. “I’ll have a side of invaluable PR with my revenge please”.

There is now a Wikipedia entry about the Son’s of Maxwell (primarily focused on the United Incident), and I assume the number of fans and level of participation on their Facebookpage has increased since the incident (although it is a paltry 3,674 at the time of this post).

Taylor Guitars even posted a response video (rightfully taking full advantage of the PR opportunity) with tips about travelling with guitars:

If you search Google for “United Airlines”, the “United Breaks” Guitars parody sits just above a parody from Mad TV about United employees, which must have been much funnier to United Airlines’ marketing department prior to it reinforcing the current state of the consumer experience. Nonetheless, it’s pretty funny!

Moral of the story…if you have bad customer service – there is no place to run, no place to hide, and apparently no place to fly!

So why did this particular video go viral while others with similar attributes (funny, parody, well seeded in social channels) don’t? Well, first of all, there’s no magic formula. Remember, “viral” is a result, not a marketing discipline. Compelling content shared and distributed in social channels will have the potential to go viral, period. Perhaps the collective comradary surrounding the fact that we’ve all had bad airline experiences helped. One thing is certain – at some point the right combination of social (people/bloggers) and traditional (media) influencers propelled this video and incident into even more hearts, minds, tweets, blogs, emails, and broadcasts. Within the fabric of the social web, momentum begets momentum.

Social media is forcing companies to rethink operational, service and product related issues.  It is vital to address and correct problems proactively, otherwise, inevitably, the problem will force a fix the hard way.

 

The Privacy Man Cometh

ComputerLockWhile the Network Advertising Initiative (NAI), a cooperative of online marketing and analytics companies committed to building consumer awareness and establishing responsible business and data management practices and standards,  has existed since 1999, its policies and lack of ubiquitous participation and enforcement ability have not been enough to curtail the FTC’s scrutiny on our industry’s data practices.

The proliferation of data usage for targeting and providing relevant consumer experiences has been a vital component to the progression and growth of the online advertising industry since the emergence of ad servers and data collection in the mid-to-late ’90’s. The argument has always been that no personally identifiable information (PII) is being collected or used and therefore the anonymous data is harmless and in no violation of any privacy guidelines or ethics. However, data collection and applications used to be limited to far fewer players. Today every ad network, marketing technology firm, and now all the major media agencies have developed or are in the process of developing the capabilities of collecting and applying consumer data in the quest to better identify and target specific consumer audiences.

Of course this benefits the entire ecosystem – including consumers. Publishers are utilizing their inventory more efficiently, marketers are able to reach the audiences we want and consumers online experiences are more relevant.

The Privacy Man

Behavioral targeting has been in the FTC’s cross hairs for the last few years (not to mention the unrelenting cries of consumer advocacy groups). It was only this past February when the FTC issued a last warning that the industry self regulate or the man will do it for us. In fact they issued a report on recommended self regulation principles for the industry. Here are the highlights:

Transparency and Consumer Control: Simply put, clear & concise disclosure of targeting practices and a method for consumers to opt-out. Fair enough.

Reasonable Security, and Limited Data Retention, for Consumer Data: Data should be stored in a reasonably secure manner based on the sensitivity of the data, and only retained for the duration required to fulfill a business or legal need. I can see the data storage duration becoming an issue on both sides.

Affirmative Express Consent for Material Changes to Existing Privacy Promises: Express consumer consent must be provided in order to use previously collected data in any manner that materially deviates from the policy in place and disclosed at the time of collection.  This includes instances when a company merges with or is acquired by another company with different data collection and usage practices.

Affirmative Express Consent to (or Prohibition Against) Using Sensitive Data for Behavioral Advertising: Any “sensitive” data collected for the purpose of BT must be done so on an opt-in basis.  BT data is rarely “sensitive”, however, several otherwise seemingly anonymous data points can be combined and used to create PII, which by definition is sensitive. I can see some conflict arising out of this guideline.

The FTC also (accurately) states that self regulation only works when there is a process in place to “monitor compliance and ensure that violations have consequences.” Commissioner Jon Leibowitz, in a separate statement also warned “A day of reckoning may be fast approaching.” “The jury is still out about whether self-regulation alone will effectively balance companies’ marketing and data collection practices with consumers’ privacy interests.”

Congressional meetings on the subject have been escalated as recently as last month.

The Ad Industry Finally Responds

The biggest hurdle to self regulation was that no industry trade group was prepared to bear the responsibility nor the cost of enforcement. Over the last year the IAB went from not having the desire nor the ability to monitor and enforce any BT guidelines, to seriously contemplating the proposition, to finally collaborating with the Direct Marketing Association,  the American Association of Advertising Agencies, the Association of National Advertisers and the Better Business Bureau to establish and issue formal guidelines and enforcement mechanisms.

Advertisers, agencies, publishers, search engines, ad networks, ISP’s, and marketing technology firms will all be held responsible to disclose data collection and usage practices in a “clear, prominent, and conveniently located” manner on their own sites and at the time of data collection.

It is the disclosure at time of data collection that is the interesting development. This disclosure will include an icon or text link that consumers can click on to go to a (soon to be developed) 3rd party site that provides education on industry-wide data collection and usage options. This may be an easy addition at the  ad server level. Effectively this moves some of the disclosure that may already exist buried in websites’ privacy policies, and brings it front and center. It does beg the question of how long we’ll need to do this? Two years? Five years?  At some point are consumers just educated and BT practices become as normal to them as they are to us? An icon on every other ad served online? Well, according to critics and advocacy groups even that is not enough. Cries for do-not-track lists and more stringent opt-in practices abound, so it is vital that the industry start by appeasing the FTC and enforce violations.

Enforcement – The Scarlet Letter Approach

Enforcement includes reporting of violations to government agencies and the general public. There is certainly motivation for the industry to police violators and ensure that the few proverbial bad apples do not spoil it for the rest of us. Will this be enough to ward of the privacy-man and ensure self-regulation survives? We sure hope so.  The strong arm of the law may be less than favorable or practical for the industry.