The FTC hosted two new workshops recently, serving notice to two industry segments that they need to get their house in order. The first of these, held October 30 on the lead generation industry, and the second, held November 16, on cross-device marketing, both held to predictable theme -- transparency for consumers is king. That should surprise nobody. But what, specifically, should marketers take away from these events?
Open dialogue, open debate, and open intentions
For both the lead generation segment and cross-device tracking segment, these three directives make for healthy markets and mutually beneficial relationships. As anyone who followed the genesis of the DAA self-regulatory program, "open" and "transparency" are at the heart of what the FTC wants to project onto all interactive segments. For example:
- Open dialogue ensures that opinions are expressed. Is the consumer's opinion kept in mind during any transaction?
- Open debate ensures that all sides of any issue are considered. Can the consumer benefits from lead generation?
- Open intentions ensure that the motivations and mechanics of an industry are transparent and measurable. What does the consumer risk by making his/her personal information available online?
Consumer transparency in cross-device tracking
During the Nov. 16 cross device tracking workshop, Justin Brookman, policy director of the FTC's office of technology research and investigation, claimed that the rise of ad blocking technology adoption by consumers suggests an unwillingness for people to accept the ad industry's access to them. While that claim is disputable, it's clear that consumers are ever more aware of the fact that they're being tracked online. With more than 100 million people around the world having downloaded tools such as Ghostery and AdBlock Plus, the black box of what's happening behind the browser is being brought to light, one user at a time.
Cross-device tracking presents a myriad of other complications for regulators and consumers. Whether one of the unique identifiers becomes the industry norm, or one of the carriers enables a better solution, consumers must have access to transparency-enabling tools.
How often are leads being sold?
"Consumers have been the victim of scams," said Jessica Rich, director of the bureau of consumer protection. Rich shared the details of a pay-day lending scheme tied to the purchase of consumers' personal information from lead generators that netted tens of millions of dollars for the perpetrators.
Although terrible, and good reason for the FTC to take action, such schemes are not typical of the lead generation industry. In the past several years, the various participants that make up the industry (including buyers, sellers, technology vendors, and others) have made great strides toward driving transparency, achieving compliance, and self-regulating. Data attributes that participants now routinely monitor include:
- How many times a lead has been sold
- How old the lead is
- How much intent the consumer demonstrated about a product or service, and
- Whether the consumer consented to be contacted
Today, we witness more than 125 million consumer lead generation events online every month across the mortgage, education, insurance, solar energy, and other home services industries. The tools that enable best practices and the kind of transparency that can only benefit consumers exist today. With the FTC watching more closely than ever, brands and other buyers need to know how to use them.
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