Federal Trade Commission Sets Guidelines for Behavioral Targeting

The FTC has announced new guidelines to cover Behavioral Targeting.  Further to my post on ethical self regulation, it seems the FTC has the same idea when it says that it will "evaluate the development of self-regulatory programs and the extent to which they serve the essential goals set out in the Principles".  Steve Smith has written an interesting summary on Behavioral Insider.

Interesting additions include the concept of Personally Identifiable Information - which goes further than knowing who a person is, to encompass knowing that this is an individual and these are their behaviors, even without knowledge of their formal identity.  That has far ranging consequences for tracking IP addresses, cookies and browsers.

The FTC are clearly targeting advertisers and don't make comment about "within site" product or content recommendations - which I believe is really the way forward with building an engaging web presence.  They do indicate that single site data collection and targeting are considered to be reasonable behaviors and are focusing their attention on cross site and ISP gathered data.

Ethical self regulation, before it's too late...

I'm increasingly concerned about privacy, it seems technology has advanced to the point where it's all too easy to breach fundamental rights of personal confidentiality.  Since my last blog post I've been working with a number of clients and partners that want to look further into behavioral tracking and social media monitoring.

In genetics: cloning, embryo screening and fetal research are carefully monitored by committees to avoid lasting damage or unethical practices.  So when marketing technology gets to the point where companies can effectively follow their customers and prospects around, even rifle through their garbage, I think that it is time for some self regulation before the law makers take a heavy handed approach and stop even reasonable behaviors in order to protect the populous.

Here's the problem, this is all just data stored on computers and fundamentally necessary to maintain the Internet and Web 2.0 practices.  We blog in public, my Facebook page is public, my tweets are public and has to receive all of the searches I type in while my ISP must provide me with access to the web pages I want to view.  Computers are all too good as processing vast volumes of information, mining that data and providing insights - the technology is right there.  The question is: "Should we do it?"

I believe it's time that some industry bodies created a commission to review and set guidelines on best practice - we need to debate these things, set guidelines and publicly identify bad practices before they become the breaking news on Twitter.  Government may have to legislate to protect personal information, the data protection act may need to be modified or clarified to include information derived from publicly available sources - though that itself is a minefield.  If government is to legislate I'd rather it was informed by a well versed body that has considered the position in advance.

I abhor the idea that I might lead a client into a strategy that would cause public outcry over privacy invasion - but like the geneticists my problem solving left brain quickly spots opportunities to capture more information and provide more insights.  I don't believe that this is something I should make the call on alone and indeed the fears over privacy invasion are causing lots of companies to ignore possibilities that would be perfectly acceptable to the masses.

In the first instance the DMA would seem to be an ideal body to form such a commission, they provide an interpretation of the Data Protection Act for marketers and have a good understanding of privacy issues.

I public profile information actually personal data?  Do you have a privacy strategy? Does it make you competitive or uncompetitive? It's high time for a debate...

Hey, are you following me?

No not a Twitter reference, though TweekDeck seems to be constantly on my screen at the moment.  I'm talking about Behavioral Targeting.

There have been a number of interesting articles on this over the last few days, but back in September Brand Republic's title Media Week had identified the trend and on February 5th the Wall Street Journal carried an article talking about how the downturn was pushing an increase in on line spend and in better advertisement targeting.  A lot of this relates to tracking and understanding customer behavior and using this to drive messaging.

This is a great trend; for a long time shops have been merchandised to fit their local area, but the web has remained largely static. Corporate sites try to be appeal to everyone with one face.  I find this strange as the web represents one of the cheapest channels for personalization and testing.  There are many strategies for tailoring sites, even if you don't know who the visitor is, many of these rely on understanding something about the behavior of the visitor on the web.  Where does that leave us on privacy?

There are probably two different areas here - targeting advertisements on social media and other portal sites and tailoring the brand's web property to the individual visitor.

For me, understanding the behavior of a visitor on a site is no different from a sales assistant watching a customer move around the store.  They can see how the customer is dressed, what product displays they visit and how long they spend at each.  After a while that assistant might walk up to the customer and engage them in conversation, help them to find what they are looking for and provide additional information.  Let's say that you are in an electrical store, the assistant comes over and helps you research a number of different televisions, you feel good that you've got the information you want.   The problem with privacy is this; say you walk out of that electrical store and head into Boots next door - the salesman follows you and starts to suggest what deodorant you might like!

That's the dilemma of Behavioral Targeting.  We want to provide the visitor with the best possible experience, they've given us permission to engage with them by visiting our place of business and we should do our best to offer the most relevant communications possible - but we need to do this without becoming creepily like Big Brother, sneaking around and following people.

Is that by asking for permission?  Certainly that is a requirement if we are going to use cross site behavioral tracking that could be provided by an ISP...  What about behavioral tracking on sites that we visit for pleasure like Facebook or MySpace?  Is that like the salesman sitting in the pub and watching us with our friends, building up a picture of us when we are unguarded?

We certainly need to be educating the actual visitor audience about what we can do as this article on Behavioral Insider suggests, because without that the public and legislators will live in a vacuum. There's a lot of thinking going on in this area right now and the outcomes will have massive influence on the way we advertise in the future, one interesting series of interviews and editorial by Sean Egen was published in January and makes interesting reading...

My view is that we can and should use behavior on our own sites to target communication - we need much more explicit permission to do any more.

Superbowl Sunday, $3m for a 30s Ad, how will technology change this in the future?

So yesterday was Superbowl day, obviously big news over here in the States, I was at a friends house for a BBQ and the game was on - this year there was a huge jump in fees to $3m for 30 seconds of air time.  Superbowl remains one of the few occasions that draws a vast audience and cannot be legitimately "time shifted", so there's a guaranteed audience for these commercials - but live sport is rapidly becoming one of the last bastions of high ticket air time.  I can't remember the last time I watched a drama in real time - everything I watch is downloaded or recorded. 

This "downloaded" is an important point though, there are actually some really big benefits of the catch up services offered by the BBC, Channel 4 and anyone watching a station that uses Microsoft MediaRoom: You don't have to remember to set the recording in advance and if you hear about some great show when you're drinking coffee with friends the following weekend, it's there and available for you.  With continued government attention and investment into building the infrastructure necessary to deliver high speed broadband to every household the days of live TV are numbered - in Leo Burnett's 9 Predictions for 2009 they suggest that this year will see a tipping point for Internet TV - that point I found fascinating, although the rest of the presentation is very hard to watch and would benefit from being in "plain English"! 

So Internet TV and catch up now provide a place to put advertising and with fine control over the media player, we're pretty much going to watch it - but it is the direct nature of this channel that excites me.  We can exploited this individual download too, we can target individuals and measure their responsiveness to highly on brand communications.  This is the ultimate shopper or viewer panel, with an ability to directly feed and influence each viewer in a way that "pressing the red button" could never do.  It's going to take some very creative agencies to build these campaigns, but the technology for targeting them already exists.  This is truly merging above and below the line strategies.