Making sure that your ads aren’t seen by everyone is becoming increasingly important – especially with regulators and networks getting more concerned about youngsters seeing age inappropriate content. Declan Pettit, Director of Monitoring Compliance Partners explains what can be done.
The famous US marketing pioneer, John Wanamaker said over 150 years ago: ‘Half the money I spend on advertising is wasted; the trouble is I don’t know which half’. One would think that today, with all our profiling metrics, advertising spend would be better targeted – yielding a more favourable effective spend ratio. This would appear not to be that case, especially when it comes to who you don’t want to see your ad.
Telemedia Week ran an article (15th July) concerning the results of a recent Childnet survey, which revealed that 12% of kids have accidentally spent money on an in-app purchase. This is only part of the problem kids face when navigating their favourite app. Rory McGuire, MD of AIME, warned in the article: ‘It is very important therefore that young people…are also aware that an advert they see may not be appropriate for their age.
Under PPP and MNO Codes, a merchant is responsible for all advertising. Recently, MNOs took to issuing a ‘Pink’ card to merchants, where the marketing journey – which is generally outside of direct merchant control – is age inappropriate. This Pink card requires them to take down ad within 24hrs, or as agreed with the MNO. It’s positive to see that PPP and MNOs now understand that working with Merchants in this area is vital.
This pragmatic approach of Industry is aligned to the regulatory responsibility for thorough DDRAC to be conducted by parties in the value chain. For a merchant, the expectation is that ‘reasonable endeavours’ are made to ensure ads aren’t placed in children’s apps/sites.
Before delving into what is ‘reasonable’, what exactly is the problem?
A lot of publishers do not specify what type of ads they want on their sites/apps. Categories for advertising aren’t granulised – and when selecting a sector such as ‘entertainment’, there may be children’s services included, as the app developer hasn’t specified an age range.
Also, none of the blind networks – including Google – can guarantee 100% that this will not happen – Google terms state an accuracy rate of 90%. So, not only are advertisers exposed to the whims of the publisher from a regulatory perspective, they are also being penalised financially as they have to pay for the wasted inventory that have absolutely no interest in their ‘anti virus software’.
So, what are the ‘reasonable endeavours’? Currently there are two approaches for controlling ad placement in such media.
Firstly, there is White listing. By citing specific sites and apps for ad placement, it’s impossible to build full list of appropriate sites – so advertisers just go for large known apps/sites but miss out on traffic from the large number of lesser-known publishers.
Then there is Black listing. This is the process of selecting categories by working with media companies to block specific sites/apps. This requires regular post advertising analysis of traffic (needing further blocking), monitoring alerts of inappropriate ads that require further action and on-going support from customer services for complaint monitoring and refund policy. To deploy a black listing approach, the merchant needs to undertake the above list of on-going actions – which costs time and money.
The problem is only going to get worse, since Google launched its new automated system that matches up similar logins with patterns and demographics (not cookies as logins are normally wiped). This will push advertisers to more of a ‘placement’ approach rather than display (to avoid age inappropriate issue). An additional problem is individuals have networks (at home/office/public) – so inappropriate targeting will get worse.
To monitor age inappropriate advertising, MCP has developed a solution, called Age Inappropriate Scanner (AIS) with some larger industry players who are keen to demonstrate proactive compliance to regulatory obligations.
AIS is a spin-off from MCP’s VeriScanner tool – an automated ad scanner (online and social) operating 24/7 in 6 European countries including UK. Not only does it capture the full consumer journey through to service landing page, it also provides a plethora of commercial information (competitive analysis, new flows, new services), as well as being a necessary compliance-monitoring tool.
MCP is also developing an online checking facility to establish if the referring app or site is kid-intensive – called ‘KidsCheck’. It will be a real-time solution, allowing merchant to reject or accept an ad on the basis of the app id or the site URL. The service provides a rating of each site, based upon a continuing accumulation of sites and apps, targeted specifically at children.
