the gdpr white paper · cookie based marketing is toxic make online advertising so good that...

The GDPR White Paper

Media | The GDPR White Paper | 2

Introduction

Cookie based marketing is toxic

Make online advertising so good that consumers want to engage with it

Welcome to the age of transparency

Surveillance marketing is a form of digital pollution

Yesterday’s friend can become today’s enemy

Contents

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The European Union’s two new

data protection laws - the General

Data Protection Regulation

(GDPR) and the e-Privacy

Directive – represent the biggest

changes to data remarketing that

any of us are likely to see in our

careers.

The GDPR now defines

cookies as personal

data, which is data that

may be used to

single out an

individual, and

the e-Privacy

Directive says that

consumers have to give

us their consent if we are to

retarget them – including what

we are doing with their data and

who we are passing it on to.

These laws were written with the

advertising industry’s targeting

technology in mind.

They apply to any company

collecting or processing personal

data belonging to EU citizens,

and the British government has

announced that it will mirror this

legislation after Brexit. Companies

will be fined 4% of their annual

turnover, or €20m - whichever is

higher - if they do not comply.

Like many companies in the

advertising industry, we

welcome these data

protection laws

because it’s time

for us all to be

transparent with

consumers about

what we’re doing with

their data.

Let’s not forget that Europeans

expect to have the right to decide

what they reveal about themselves.

The advertising industry has

impinged that right by peddling the

argument that consumers agreed

to give up their privacy in return

for a free internet.

That’s bullshit.

Introduction


Silence is a full-service online ad agency based in Hackney, East London, that

creates engaging and transparent online display campaigns for brands.

We work at the intersection of design, technology and media buying, testing

different creative approaches alongside contextual media-buying strategies

in a way that’s reminiscent of how the advertising industry worked before the

separation of creative and media at the end of the eighties.

Our ads are designed to trigger a positive emotional response from consumers

through the use of interactive content, and we increase brand salience by

striving to keep our ads interesting. Our designers, programmers and media

buyers innovate in a fast-paced, collaborative environment where campaigns

are continually tested for their ability to engage consumers. We figure out the

narrative that makes our ads interesting enough for consumers to engage with

them.



When we buy media, we use contextual data to

ensure we’re targeting the right consumers in the

right place at the right time and we concentrate on

how they are engaging with our ads to increase the

overall campaign ROI.

Working with brands from multiple sectors -

including Aer Lingus, Epson, Save The Children, The

Yorkshire Building Society and Christie’s – we’re

best known for running cost-per-engagement (CPE)

campaigns, the format that we launched in Europe a

decade ago.

In response to GDPR, we have a clear message for

our clients: abandon cookie-based remarketing by

May 25th because it’s toxic.

After May 25th Silence won’t be holding any

personally identifying information about consumers

and we won’t be using cookie data to retarget

consumers, for sales attribution or brand uplift

studies.

Instead, we’ll continue to focus on the job of matching

a creative with its audience, using contextual data for

targeting and engagement as our ROI metric.



We believe that the smartest American and European brands are now looking

to conduct their online display campaigns in ways that are in line with the revolt

against ad tracking.

A recent WARC report about the death of the cookie had this to say: “Brands

can eschew the idea of user targeting altogether and instead match creative

to the environment in which the message is being consumed. Advocates of this

approach point out that there is no requirement to procure user data, and that it

contributes and enhances the user experience, rather than proving disruptive.”



At Silence, we’ve developed a

solution for brands that removes

the risk of getting fined for not

complying with the GDPR. We are

abandoning cookie data in favour

of a new way for online display that

focuses on creativity and context,

demonstrating how you can combine

design, technology and media buying

in a way that discovers the most

effective creative and contextual

strategies for engaging audiences

online.

We use our marketing technology

platform, Ada, to test creative

strategies for our high-impact

campaigns and report on the best-

performing websites, contextual

segments, locations and times of the

day.

Our pitch today reflects something

we’ve been saying for ten years: that

you need to make online advertising

so good that consumers want to

engage with it. It’s time to forget

about the myth of the perfectly

personalised advertising experience

- a dream of the advertising

industry’s not the consumer’s - and

get on with the more important

job of understanding the role

of creativity and context in the

performance of a campaign.



We are now coupling interactive creatives for online display with contextual targeting strategies across our premium marketplace of websites.

Our marketing of over 10,000 websites was built to target consumers across two continents – the USA and Europe. It’s separated into ten distinct channels – Arts & Ents, Shopping, Lifestyle, Sports, Tech, Kids & Teen, News & Reference, Travel, Business and Games. A member of staff approved each site in our marketplace, and it was then checked for brand safety by our partner Integral Ad Science.

Unlike our competitors, we have nothing to hide

about where we run campaigns. We are transparent with

our marketplace, sharing the latest version of it with our clients before we launch a campaign,

inviting them to add or remove websites, and closing a campaign by reporting on all the websites on which it ran.

We start a campaign by running it across the best

performing marketplace channels for that audience, targeting by country, region, city or

town.

Working with our data partner Grapeshot, we also target consumers browsing the sites in our marketplace that fall into a particular

contextual segment or are reading an article with three or

more keywords on it.

We then report on which creative strategy is doing the best job of engaging an audience and deliver more of it. We also analyse which websites,

marketplace channels, contextual segments and keywords and giving us the best results, alongside location and time of day.


Targeting

Reporting


The short and turbulent history of online advertising has entered a fourth and

welcome period with GDPR - what we like to call The Age of Transparency.

The first period was the mid-90’s Gold Rush. The first banner ad campaign was

launched then, the cookie was invented, and the ad networks arrived, offering

a scalable solution to brands looking to engage consumers on the first new

advertising medium for 50 years.

We remember online advertising’s second period as The Emperor’s New

Clothes, which was marked by the ascension of ad tech: Google launched

Adwords in 2000, YouTube launched video ads in 2006, and MediaMath, the first

programmatic trading platform, launched in 2008.

The consequences for our industry were severe.



It was the first time in advertising’s

180-year history that the technology

used to deliver the ads trumped the

creativity of the people making them.

With creative directors asleep at

the wheel, adtech pursued its own

big idea: reducing customers to data

points and trading that data. And so

the internet began to stalk us with

ads for shoes, putting us in a place

that people working in robotics call

the ‘uncanny valley’, which is when

you meet a robot that is so lifelike it

creeps you out.

The third period, the Backlash,

started in 2010 with consumers

using adblockers to express their

displeasure. Tired of terrible looking

ads on the page, of fat ads stealing

their bandwidth, of ads that tracked

them without consent, they did

something unprecedented: they

started turning us off.

Doc Searls, the author of The

Intention Economy, describes ad

blocking as “the biggest consumer

boycott ever”.

We also had our internal critics. In

2010, the academic Byron Sharp

published his influential marketing

book How Brands Grow, a call-

to-arms for marketers who were

beginning to wonder if we’d thrown

the baby out with the bathwater in

the rush to digital. In How Brands

Grow, Sharp makes the argument

that you will never increase your

brand’s market share by retargeting

existing customers – the task that

online advertising performs so

efficiently.



It was last year that we saw the dawning of The Age of Transparency in the actions of big brands losing their patience with digital.

Mark Pritchard, Procter and Gamble’s chief brand officer, said this in his speech to The IAB: “We have a media supply chain that is murky at best and fraudulent at worst. We need to clean it up, and invest the time and money we save into better advertising to drive growth.”

Then The Times ran its front-page story with the headline ‘big brands fund terror’, revealing that ads from brands like Mercedes-Benz, Waitrose and Argos were running on the websites and YouTube channels of Islamic extremists and white supremacists. Google was forced to promise to overhaul its advertising policies following a boycott by 250 firms and the British government.

Then in April this year, CNN reported that Netflix, Adidas and Under Armour had served ads alongside Nazi, pedophilia and propaganda videos. Under Armour then announced it was suspending You Tube spending.

This is not the first time that marketers and consumers have united in their

distaste for advertising. In Tim Wu’s influential book about the history of advertising, The Attention Merchants, he points out that the advertising industry has been “left for dead on at least four separate times over the past hundred years”.

He goes on to say this: “Periodic revolts against the arrangement are not just predictable but necessary. For if the attention economy is to work to our benefit (and not merely exploit us), we need to be vigilant about its operations and active in expressing our displeasure at its degrading tendencies. In some cases, as we’ve seen, its worst excesses may have no remedy but the law.”


At Silence, we welcome The Age of Transparency because we believe that it’s leading online display to a future with higher creative standards, that it’s renewing our interest in contextual targeting and that it’s inviting us all to give more scrutiny to exactly how consumers engage with brands online.


Surveillance marketing, using cookies to track consumers without their consent,

is a feature of online display advertising. It’s also a form of digital pollution just like

fake news, cybercrime, trolling and hate speech. The GDPR will make it illegal for

online display to continue polluting the internet in this way.

It was a decade ago when advertising technologists told us that surveillance

marketing was the future: now we can track consumers to deliver the perfectly

personalised advertising experience, they said, as if they were somehow on the

side of the consumer.

And so, with little thought for the future, advertisers began annoying consumers

by chasing them around the internet with ads for trainers. Then they started

targeting whole segments of the population using data from ad tech companies

who hadn’t asked for anybody’s permission to collect it.



Then the direct response marketers

attached themselves to ad tech like

barnacles to a whale and advertisers

started using this personally

identifying information for sales

attribution and brand uplift studies,

too.

Our industry did all this without

thinking to ask for the consumer’s

consent. Surveillance marketing,

with its low transaction costs, was

violating consumers like a randy bull.

The job of brand advertising

is to attract new customers by

targeting them with an ad that

triggers an emotional response and

increases brand salience. The job

of each advertising channel is to

demonstrate a positive ROI.

If you retarget consumers who have

visited your website on another

website without their permission,

or you make inferences about them

using their data, all you’re doing, it

turns out, is reducing their interest

in buying your brand.

To those people in our industry who

are hanging on to the myth of the

perfectly personalised advertising

experience like a shipwrecked sailor

hugging a mast, we’d point them

to a recent article in The Harvard

Business Review that, with an even

hand, systematically debunks that

myth.

The HBR article Targeted Ads

That Don’t Overstep reports on

how surveillance marketing has

reduced consumers’ intent to buy,

how it ‘activates concerns about

privacy and provokes consumer

opposition.’ The article points out

that psychologists already know

a lot about what triggers privacy

concerns off-line:

‘While people may be comfortable

disclosing personal information

directly, they may become uneasy

when that information is passed

along without their knowledge. If you

learned that a friend had revealed

something personal about you to

a mutual friend, you’d probably

be upset – even though you might

have no problem with both parties

knowing the information.’



‘It can also be taboo to openly infer

information about someone, even

if those inferences are accurate.

For example, a woman may inform

a close colleague of her early-term

pregnancy, but she’d likely find it

unacceptable if that coworker told

her he thought she was pregnant

before she’d disclosed anything.’

The authors of this article

demonstrated that these norms

about information also apply in

the digital space. They did this by

collecting a list of the common ways

in which Google and Facebook

use our data to generate ads, then

asked a sample audience to rate how

acceptable they found each method

to be.

They proved that consumers

don’t like it when advertisers use

information obtained on a third-

party site rather than on the site on

which an ad appears because that’s

like talking behind someone’s back.

They also found that consumers find

deducing information about them

from analytics to be just like inferring

information.

Then they looked at the impact

that this violation of privacy norms

has on the performance of ads,

revealing that consumer frustration

at being targeted outweighs any

benefit. Interest in purchasing was

24% lower in the group exposed

to unacceptable sharing. And the

group that viewed the ad generated

through inference showed 17% less

interest in purchasing.

Consumers are now more sensitive

to privacy and less willing to give

up personal information than they

have been in the past. And they are

also less likely to buy from a brand

if they cannot trust how that brand

handles their data. The European

Union’s new data protection laws are

correcting a market failure, removing

a decade old incentive for the over-

disclosure of data. The advertising

industry can no longer violate user

privacy by knowing more about

how it collects and uses data than

consumers do.


The return of contextual targeting is

like the return of the paper bag.

There was a time when plastic was

the hero of the age. Today plastic

bags are Public Enemy Number 1 as

far as the environment is concerned.

In the same way that supermarkets

are dropping plastic bags for paper

bags, the advertising industry is

rejecting cookie base targeting and

returning to contextual targeting.

We think that the end of surveillance

marketing will cause three things to

happen to online display:

It will enjoy a creative renaissance as

it breaks the rusty shackles of direct

response advertising.

Contextual targeting will dominate

as brands focus more and more on

targeting by website, contextual

channels and segments, keywords,

location and times of the day.

And finally, as the cost of inventory

goes up, engagement will mature

into the most valued Return on

Investment metric.

Yesterday’s friend can become today’s enemy


Silence Media | Studio 15-1 | 203 Richmond Road | London E8 3NJ0203 432 1270 | www.silence-media.com

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