Debbie Morrison: building relationships, sharing insights and strengthening bonds- Tempemail – Blog – 10 minute

It’s now a year since I took my first commercial role in 30 years, moving from ISBA to Ebiquity to run global partnerships and events. Before I made the switch, I was naturally a little apprehensive about what the change would mean for what I do and how I do it. But 12 months in, I’ve noticed far more parallels and similarities than differences, despite the very different commercial imperatives of a membership organisation and a consultancy.
Looking out with optimism at the start of 2020, I wanted to share three of the most important things I’ve learned through experience in the past year, a year that’s been dominated by the central themes of generosity, mutuality, and relationship building.
Share that wisdom
When peers come together to share knowledge and experiences generously, they can help one another understand that they’re not alone in the challenges they face. By parking egos and competition at the door, they can learn from one another about how to deal with emerging trends. Sharing builds relationships; it creates and strengthens bonds. It also empowers members of the group to share the kinds of insights that can make an ecosystem better for everyone.
Last year, I helped to establish an Ebiquity Media Management Procurement Group, bringing marketing procurement specialists together to look specifically at the issues that dominate procurement of media today. By creating a permanent forum that allows brand owners to come together, learn from each other’s deep perspectives, and share information and experiences, we’ve established an informal grouping with close ties to ISBA and WFA. So far, it’s brought together 120 advertisers. We are now spreading this template across five major European markets – the UK, France, Germany, Italy, and Spain – and into the emerging powerhouse of the Middle East. This approach has sensitised many advertisers to know what behaviours and actions from different players in the ecosystem mean and what they can do about them.
Make listening a priority
Getting time in busy marketers’ diaries is next-to-impossible without meaningful return and exchange on all sides. Early last year, we also established a new client council at Ebiquity. This select grouping of 20 of our most influential global and local customers again provides a sage forum in which we openly discuss the issues that are keeping the industry awake, free from competitive concerns – just as I experienced many times with committees and working groups at ISBA. The advice that comes from this council – about everything from proposed new products and services to topics for thought leadership – is invaluable. Some of the smartest brains in modern marketing help to shape and co-create our output. Leaving egos and competition at the door is to everyone’s advantage.
During our twice-yearly meetings, I’ll often interview our clients – on camera – because they are genuine thought leaders in the field. Some of this content we share just with council members, others more broadly.
Be generous with your thought leadership
The spirit of collaboration and partnership has to be a two-way street, and sharing thought leadership content to trigger and stimulate debate was always a key part of my role and philosophy in trade association days. That’s a major role that industry bodies can play. But it’s also a role that we’ve embraced wholeheartedly at Ebiquity, in part – of course – to build our profile and reputation, to generate and share points of view. But in part, equally, to provide our clients and the marketing ecosystem more broadly with a growing and dynamic library of opinion pieces on the issues that matter to the industry.
Thanks to our procurement forum and client council, we have an inside track on what’s keeping marketers awake and where they need guidance – and quite often just the facts. There’s little point creating content and then jealously protecting it with a firewall to keep those who are interested out. If you’re going to develop something of value, our philosophy is to share it broadly.
Among the most widely-read publications we produced last year were: an innovative research paper titled TV at The Tipping Point, a new, evidence-based assessment of what’s happening to TV viewing and how this will shape the effectiveness of TV advertising in the medium-term future; the Ebiquity Media Model, a new framework to help CMOs make sense of media management; and, a provocative Viewpoint paper titled The end of the golden ratio in planning marketing investment. This paper shows brands why – in the increasingly complex, ever-more digital media and marketing ecosystem – 80/20 golden ratios of working vs non-working media have had their day. At a time when CMOs are spending almost as much on customer experience as they are on media, brands need smarter approaches for optimal budget allocation.
My first year in my new role at Ebiquity – a new role for the business, too – has been dominated by three things: building relationships, sharing intelligence, and strengthening bonds. There’s a virtuous cycle that comes from sharing, openness, and generosity of spirit. I’d observed and worked with these characteristics through my time in trade association land. What’s so gratifying is that these same principles and approaches apply every bit as much in my new role as they did before. It works in formal partnerships with other associations, including the ANA, ISBA, and the WFA. And it works with the world’s leading advertisers too. I can’t wait to get my teeth into 2020.
Debbie Morrison is managing director of global partnerships and events at Ebiquity.

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Mental health websites in Europe found sharing user data for ads – gpgmail

Research by a privacy rights advocacy group has found popular mental health websites in the EU are sharing users’ sensitive personal data with advertisers.

Europeans going online to seek support with mental health issues are having sensitive health data tracked and passed to third parties, according to Privacy International’s findings — including depression websites passing answers and results of mental health check tests direct to third parties for ad targeting purposes.

The charity used the open source Webxray tool to analyze the data gathering habits of 136 popular mental health web pages in France, Germany and the UK, as well as looking at a small sub-set of online depression tests (the top three Google search results for the phrase per country).

It has compiled its findings into a report called Your mental health for sale.

“Our findings show that many mental health websites don’t take the privacy of their visitors as seriously as they should,” Privacy International writes. “This research also shows that some mental health websites treat the personal data of their visitors as a commodity, while failing to meet their obligations under European data protection and privacy laws.”

Under Europe’s General Data Protection Regulation (GDPR), there are strict rules governing the processing of health data — which is classified as special category personal data.

If consent is being used as the legal basis to gather this type of data the standard that must be obtained from the user is “explicit” consent.

In practice that might mean a pop-up before you take a depression test which asks whether you’d like to share your mental health with a laundry list of advertisers so they can use it to sell you stuff when you’re feeling low — also offering a clear ‘hell no’ penalty-free choice not to consent (but still get to take the test).

Safe to say, such unvarnished consent screens are as rare as hen’s teeth on the modern Internet.

But, in Europe, beefed up privacy laws are now being used to challenge the ‘data industrial complex’s systemic abuses and help individuals enforce their rights against a behavior-tracking adtech industry that regulators have warned is out of control.

Among Privacy International’s key findings are that —

  • 76.04% of the mental health web pages contained third-party trackers for marketing purposes
  • Google trackers are almost impossible to avoid, with 87.8% of the web pages in France having a Google tracker, 84.09% in Germany and 92.16% in the UK
  •  Facebook is the second most common third-party tracker after Google, with 48.78% of all French web pages analysed sharing data with Facebook; 22.73% for Germany; and 49.02 % for the UK.
  • Amazon Marketing Services were also used by many of the mental health web pages analysed (24.39% of analyzed web pages in France; 13.64 % in Germany; and 11.76% in the UK)
  • Depression-related web pages used a large number of third-party tracking cookies which were placed before users were able to express (or deny) consent. On average, PI found the mental health web pages placed 44.49 cookies in France; 7.82 for Germany; and 12.24 for the UK

European law around consent as a legal basis for processing (general) personal data — including for dropping tracking cookies — requires it to be informed, specific and freely given. This means websites that wish to gather user data must clearly state what data they intend to collect for what purpose, and do so before doing it, providing visitors with a free choice to accept or decline the tracking.

Dropping tracking cookies without even asking clearly falls foul of that legal standard. And very far foul when you consider the personal data being handled by these mental health websites is highly sensitive special category health data.

It is exceedingly difficult for people to seek mental health information and for example take a depression test without countless of third parties watching,” said Privacy International technologist Eliot Bendinelli in a statement. “All website providers have a responsibility to protect the privacy of their users and comply with existing laws, but this is particularly the case for websites that share unusually granular or sensitive data with third parties. Such is the case for mental health websites.”

Additionally, the group’s analysis found some of the trackers embedded on mental health websites are used to enable a programmatic advertising practice known as Real Time Bidding (RTB). 

This is important because RTB is subject to multiple complaints under GDPR.

These complaints argue that the systematic, high velocity trading of personal data is, by nature, inherently insecure — with no way for people’s information to be secured after it’s shared with hundreds or even thousands of entities involved in the programmatic chain, because there’s no way to control it once it’s been passed. And, therefore, that RTB fails to comply with the GDPR’s requirement that personal data be processed securely.

Complaints are being considered by regulators across multiple Member States. But this summer the UK’s data watchdog, the ICO, essentially signalled it is in agreement with the crux of the argument — putting the adtech industry on watch in an update report in which it warns that behavioral advertising is out of control and instructs the industry it must reform.

However the regulator also said it would give players “an appropriate period of time to adjust their practices”, rather than wade in with a decision and banhammers to enforce the law now.

The ICO’s decision to opt for an implied threat of future enforcement to push for reform of non-compliant adtech practices, rather than taking immediate action to end privacy breaches, drew criticism from privacy campaigners.

And it does look problematic now, given Privacy International’s findings suggest sensitive mental health data is being sucked up into bid requests and put about at insecure scale — where it could pose a serious risk to individuals’ rights and freedoms.

Privacy International says it found “numerous” mental health websites including trackers from known data brokers and AdTech companies — some of which engage in programmatic advertising. It also found some depression test websites (namely:, and, out of those it looked at) are using programmatic advertising with RTB.

“The findings of this study are part of a broader, much more systemic problem: The ways in which companies exploit people’s data to target ads with ever more precision is fundamentally broken,” adds Bendinelli. “We’re hopeful that the UK regulator is currently probing the AdTech industry and the many ways it uses special category data in ways that are neither transparent nor fair and often lack a clear legal basis.”

We’ve reached out to the ICO with questions.

We also asked the Internet Advertising Bureau Europe what steps it is taking to encourage reform of RTB to bring the system into compliance with EU privacy law. At the time of writing the industry association had not responded.

The IAB recently released a new version of what it refers to as a “transparency and consent management framework” intended for websites to embed to collect consent from visitors to processing their data including for ad targeting purposes — legally, the IAB contends.

However critics argue this is just another dose of business as usual ‘compliance theatre’ from the adtech industry — with users offered only phoney choices as there’s no real control over how their personal data gets used or where it ends up.

Earlier this year Google’s lead privacy regulator in Europe, the Irish DPC, opened a formal investigation into the company’s processing of personal data in the context of its online Ad Exchange — also as a result of a RTB complaint filed in Ireland.

The DPC said it will look at each stage of an ad transaction to establish whether the ad exchange is processing personal data in compliance with GDPR — including looking at the lawful basis for processing; the principles of transparency and data minimisation; and its data retention practices.

The outcome of that investigation remains to be seen. (Fresh fuel has just today been poured on with the complainant submitting new evidence of their personal data being shared in a way they allege infringes the GDPR.)

Increased regulatory attention on adtech practices is certainly highlighting plenty of legally questionable and ethically dubious stuff — like embedded tracking infrastructure that’s taking liberal notes on people’s mental health condition for ad targeting purposes. And it’s clear that EU regulators have a lot more work to do to deliver on the promise of GDPR.

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Pro rata rights, immigration, the sharing economy, AWS, Ray Dalio, and China’s smartphones – gpgmail

What founders need to know about pro rata rights

Pro rata used to be reasonably simple. Venture investors who bought preferred shares in startups had the right to lock in a certain percentage of equity provided they continued funding the company in the future rounds of financing. But as VCs have raised ever larger funds and cap tables have become ever more congested, who gets pro rata — and who keeps it — has become a massive distraction for many founders during their fundraises.

Andy Sparks, the founder of Holloway Guides (which, as my co-editor Eric Eldon wrote this week, raised $4.6 million from the New York Times and others), writes in with an analysis of pro rata rights from the latest Holloway Guide on Raising Venture Capital. We are really digging this new model of covering the issues affecting startups, and wish Sparks and his team well in their endeavor.

Pro rata is Latin for “in proportion.” Most people are familiar with the concept of prorating from dealing with landlords: if you’re entering into a lease halfway through the month, your rent may be prorated, where you pay an amount of the rent that is in proportion to your time actually occupying the property.

Almost all investors try to negotiate for pro rata rights, because if a company is doing well they want to own as much of it as possible. After all, why not double down on a winner than use that same money to invest in a newer, unproven company? In the 2018–2019 fundraising climate, though, it’s safe to say we’re at “peak pro rata.” Everybody wants pro rata, even those who don’t entirely understand how it works or affects companies.

Which immigration headlines should you care about?

Every day in the United States, immigration issues dominate the headlines. That can be very taxing for startups, which are often founded by immigrant entrepreneurs and often have sizable immigrant employee bases as well. So which stories should you pay attention to and which stories can you ignore and live in blissful ignorance?

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