FTC's Focus on Opt Out Doesn't Rule Out Good Marketing

Digital Marketing Performance Depends on an Opt-In Base

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In remarks at a conference last month, FTC Commissioner Julie Brill implied that the FTC might crack down on cross-device marketing and native advertising unless the ad industry better empowers consumers to control how and where they are tracked.

Contrary to the knee-jerk reaction many have that nothing good can come out of the FTC, this could be a big step forward for marketing.

On native, the FTC's clear delineation of what is an ad and what is content refocuses energy where it should be: Native advertising needed to have better guidelines so native advertising providers will be forced to operate in a more ethical manner. Attempting to fool consumers only casts a pall on all content -- and that's bad for marketing.

On cross-device targeting, a consumer-friendly FTC ruling could put more emphasis on performance -- not awareness -- in digital marketing. First, though, it has to define how it will "crack down." So far, Ms. Brill simply urges advertisers to opt to deliver ads to customers using less data, arguing this is better than not being able to deliver ads at all.

Opt-out would beat less data, hands down. It would redirect the evolution of paid media and restore a purer emphasis in marketing -- conversion as opposed to awareness.

If all platforms and networks were required to let consumers opt out of cross-device tracking, some people would do that. That still leaves a big audience that understands the value proposition, and doesn't mind seeing relevant ads that are useful in their lives. The more you explain to people about privacy, the less they're alarmed by it. The degree to which online advertising activity is anonymized makes advertising one of the lesser dangers to privacy.

Now, let's admit that a great deal of advertising activity has been built on a foundation that is not sustainable. Predictably, it's coming under fire from consumers and businesses alike. Look no further than the viewability conversation, which would have been dismissed as preposterous by the founders of media planning.

The reason is simple: consumer overload. There are too many messages hitting people who are already overcommitted and overwhelmed with the stuff they absolutely have to do day by day. The industry's response has been to find more ways to intercept, interrupt and intervene. And, of course, to create louder and wackier messaging to "break through the clutter."

In other words, the industry has sought to make more kinds of ads in order to increase the chances of consumer awareness. But that's not the promise of digital marketing. And it's not what business needs, now more than ever, from marketing. Consumers' and marketers' interests meet at one place -- a purchase that fulfills a need or desire.

What counts is conversion. The consumers who are inclined to opt out are not viable advertising targets. They have hated online advertising from the start and probably already have ad blockers or are infected with classic "banner blindness." We're all gaining if we have a sizable universe of people who opt in. Then cross-device targeting can deliver the relevance it's designed for: the right offer to the right user in the right time and place -- within a truly convertible base.

For now, the FTC needs to explain what constitutes "making it clear" to consumers that they are being tracked across devices. For example, Google and Facebook both deploy cross-device tracking via emails and device IDs when users are logged in. Are they being explicit enough so that users know they are being tracked across devices? Do they fall within the guidelines that the FTC might put forth?

Cross-device targeting is essential to relevance and accountability in digital advertising. It's what a great deal of innovation in our business is predicated on, and that innovation supports a thriving ad-tech economy. The utility that consumers now expect from media, and increasingly from advertising, depends on it. And the utility and performance that business counts on from digital marketing depends on an opt-in base.

Consumer experience and advertising effectiveness are inextricably connected. When we get over being our own worst enemy, we'll actually get higher returns from our advertising -- and we might even start to win back some of the consumers we've lost along the way.

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