Why Click Fraud Should Concern You (Even If You’re Not Paying “Per Click”!)

Click Fraud, the process whereby “bad actors” claim traffic that is being sent to a website, has been an industry problem for years.  It can impact you, even if you’re not doing Pay Per Click advertising.

Many advertising teams measure digital advertising performance using a “Last Click” method. The Last Click method gives credit of the conversion to the publisher which served the last ad that drove the consumer to the website. This means that when performing campaign analysis, media budgets will be weighted artificially towards the wrong publishers (and the ad networks that support them).

Operationally, Click Fraud is accomplished by utilizing automated software programs (bots) and malicious code which make it appear that website traffic is coming from another source.

Business Insider, via a legal declaration from Elyse Burns of Vista Print, recently exposed how Click Fraud can occur:

Burns navigated to the VistaPrint site via search and left the browser on overnight. The declaration states she discovered that, without taking any action, the browser had reloaded the webpage on its own. As a result, the visit no longer had tracking code reflecting that she had reached the site by search, but instead reflected the visit occurred as the result of [another advertising network’s] ad, according to the declaration.”

There are several ways to minimize the impact of Click Fraud (if not eliminate it all together):

  1. Don’t count click traffic coming from self-proclaimed bots. Admittedly, true bad actors will mask their bots as human traffic … but discounting bot traffic from your attribution is such an easy process that there is no reason not to do it.
  2. Watch click behavior. While all humans don’t “click alike”, they all have certain similar limitations and behaviors. For example, they likely don’t click on 30 ads an hour. Similar to the first suggestion, this is not a silver bullet. Savvy bad actors can program their bots to mimic human behavior. But it is an important characteristic to watch for.
  3. Stop doing Last Click attribution. It is, quite candidly, a lazy way to measure campaign performance. A proper measurement and attribution program will take into consideration the multiple cross channel touch points a consumer has – both internally and externally – on the path to their ultimate conversion. And ideally that conversion isn’t a click, but something more tangible like an email newsletter sign up or a purchase.

Much like all technological fraud, Click Fraud is made up of a race between good marketers looking to accurately measure campaign performance, and bad actors actively looking to take advantages of technology loopholes.

The best that you can do is pay close attention to the website traffic which is driving your conversions, and watch for irregularities which could indicate fraud. Your website log traffic can provide vital clues as to the source and timing of each web visitor; a valuable tool for all of your campaigns (even email!).

The Future Of Big Data

What Is Big Data?

Big Data defined:  Extremely large data sets that may be analyzed computationally to reveal patterns, trends, and associations, especially relating to human behavior and interactions.

Quite simply, Big Data is the collection of all of the little things we do as humans.  For marketers, this means the small actions consumers take and the influences they encounter as they move through the traditional marketing funnel.  That marketing funnel in its most basic form is the journey a consumer takes – moving from awareness to interest to consideration to intent, evaluation, and purchase.

Big Data was once only available to select organizations with the resources to collect and analyze it.  Big Data is now accessible to everyone, thanks in large part to technological advancements.  These technological advancements have made collecting data from disparate online and offline sources, pinning that data to persistent universal IDs, and analyzing that data to better understand consumer behavior, easier than ever.

Why is Big Data Important?

Marketers are ever consumed with efficiently finding the right consumer, at the right time, and delivering the right message.  The old adage in advertising used to be “I know that 50% of my advertising is working … I just don’t know which 50%”.  Now, knowing which 50% isn’t good enough.  Marketers need to know individual level data, such as “Who is the right consumer?”, “When is the right time to reach them?”, and “Which message will best influence them to convert?”.

Up until recently, collecting and analyzing the data necessary to answer those questions has been difficult and expensive.  Now, thanks in large part to the ubiquity of Software As A Service providers specializing in data management and execution, it is easy to not only accurately collect greater amounts of consumer data from disparate sources (eg: social, mobile, display, email, direct mail, etc.), but also put that data to use.

These solutions have become so ubiquitous that even mid-sized companies can afford to collect and store vast amounts of consumer data, analyze that data to create more predictive consumer models, index those models against individual cross channel consumer identities to create audiences, execute those models in the form of targeted cross channel audiences, and then measure the results – both within and outside the click stream.

Does that sound complicated?  It is!  But now thanks to technology advances in advertising, almost any company can do it.  Where companies had to rely on third parties and data collectives to generate data, they’re now able to collect and digest consumer data economically, at scale.  The critical component has moved from data collection and storage to data analysis.

This isn’t a fully automated process.  It still requires teams of “smart people” to implement.  (Data Scientists have reached near celebrity status, commanding larger salaries and greater influence in the corporate structure.)  Though those teams are smaller than there were before, and they have greater resources to make more informed decisions.

What Does The Future Hold?

As the accessibility of Big Data (and the solutions that support them) continues to grow, we’ll see several things:

  1. Brands will collect greater amounts of data, as devices become more inter-connected and data storage costs continue to drop.
  2. Brands will demand more access to their data.   We’re seeing this now, as Consumer Product Goods (CPG) companies are demanding access to the supermarket shopping data of consumers who purchase their products using loyalty cards, and also access to person level measurement / attribution data from walled garden publishers like Facebook and Google.
  3. As more first party data becomes available, certain third party data attributes will become more commoditized. Brands will realize the value of their consumer data in the open marketplace, and take steps to monetize it.  We’re already seeing several adtech companies launch platforms to easily enable Brands to monetize their data.
  4. A continued focus on accurate Identity.  Pinning consumers to universal persistent IDs (at the individual and household level) across online and offline channels.  This goes hand-in-hand with an increased effort towards identifying and tracking consumers at all stage of the marketing funnel (aka purchase lifecycle).
  5. Leveraging Big Data to reduce the cost of customer acquisition. This is the ultimate goal of marketers … sell more for less.  And as Big Data enables us to learn more about consumer behavior, we can expect the traditional marketing funnel to adapt as well.

 

 

SEO 3.0 – How to Optimize Your Website For Search Engines

While the importance of ranking highly in relevant search engine queries hasn’t changed in the past 10 years, the process of Search Engine Optimization (aka SEO) has changed dramatically.

One of the foremost authorities on SEO, Moz.com, has published a beginners guide to SEO. This 58 page guide is ideal for business owners who are looking to understand the basics of SEO.

I think that it is one of the most comprehensive guides for SEO beginners that I’ve read in a while, and I highly encourage anyone who utters the word “SEO” in a conversation to read it.

Knowing that we’re all busy, and in the spirit of respecting your time, I’ve created a “cliff notes” version of the Moz.com Search Engine Optimization for Beginners guide (with my notes and comments, having optimized search engines for several years now). This is by no means a substitute for the full guide, which should only take you an hour or so to read. This summary will hopefully make digesting the full guide easier.

Throughout the guide you’ll notice a common theme, which I’ll paraphrase as “don’t try to cheat the system”.  Your goal should be to execute a comprehensive digital marketing campaign that makes it easy for search engines to crawl your site and refer visitors to pages on your site that relate to their immediate query.  While there are things that you can do to expedite this process, by no means does it happen overnight.

Chapter 1:

Search engines “crawl” your website from page to page, following links. So make sure that the search engines can easily go from page to page by making the link structure simple. They cannot follow search fields, so make sure that you provide links (ideally text links) that they can follow.

Search engines cannot interpret video, flash, nor images (yet!), so make sure that your webpages have lots of text, and use natural language.

Google recomends the following: “Google recommends the following to get better rankings in their search engine: Make pages primarily for users, not for search engines. Don’t deceive your users or present different content to search engines than you display to users, a practice commonly referred to as “cloaking.” Make a site with a clear hierarchy and text links. Create a useful, information-rich site, and write pages that clearly and accurately describe your content. Make sure that your <title> elements and ALT attributes are descriptive and accurate. Use keywords to create descriptive, human-friendly URLs. Provide one version of a URL to reach a document, using 301 redirects or the rel=”canonical” attribute to address duplicate content.”

Chapter 2:

Moz.com likes to say “Build for users, not for search engines”. I couldn’t agree with this more. You need to build an online marketing strategy that is natural, and as a bi-product is search engine friendly. Trying to engineer to only support search engines will only lead to your website being de-listed for SEO Fraud.

A search engine’s only goal is to deliver the most relevant answer to the person searching.

You should focus your content on answering questions. Searches fall into three categories: “Do” (I want to do something), “Know” (I want to know something), or Go (“I want to go somewhere – either an event or a webpage).

Search engines still drives a LOT of traffic to websites, and a majority of that traffic goes to the top listings in a search engine query … so it is worthwhile to spend the time / resources to ensure that your website ranks high in search engines.

Chapter 3:

Things that get in the way of search engines include online forms, duplicate content, and other items previously mentioned. Use common terms, make sure that your language is region specific (the Brits are known for spelling words with an S intead of a Z), and make sure that the language aligns with your primary target audience.

Remember that SEO is always evolving, which is another reason that you want to follow “white hat” (aka honest) approaches. You can check how a search engine reads your website by using SEO-Browser.com or Moz.com. Or you can look at Google’s text cache of the page.

The text in the link (eg: <a href = “website.com”>seo advice</a>) is important for SEO.

Use specific, and relevant, keywords. But don’t over abuse them. Make sure that the language is natural.

Chapter 4:

Moz.com recommends for keyword(s) / key phrases:

  • Use the keyword(s) in the title tag. Use them at least once. You can use them more than once, but remember to keep the language natural.
  • Use the keyword(s) / key phrases once prominently near the top of the page. For example, as the bolded header at the top of the page. Remember that search engines cannot read images, so make sure that it is “pure text”.
  • Several times (with different variations) throughout the rest of the webpage.
  • As part of the alt tag of an image.
  • Once in the URL of the webpage.
  • And as part of the Meta Description for the page. Search engines will pull from the Meta Description when creating the “sneak peak” which shows beneath the listing for your site in the query. Not only should the Meta Description include the keyword, but it should be written as a compelling call to action that drives the reader to go to the website!

Chapter 5:

Choosing the right keyword / key phrase is an artform. You need to choose keywords which are not only relevant to the search, but also aren’t so general that you won’t rank highly in the search query. There is an old saying “The riches are in the niches”, and you should think about keyword the same way.

Moz.com’s Keyword Analysis tool can help you understand the competition for a specific keyword or key phrase, and consequently how difficult it will be to rank highly for them.

Chapter 6:

As mentioned earlier, search engines are trying to give searchers the best possible results for their query. Generally, search engines like websites that are:

  1. Easy to navigate and understand.
  2. Provide clear information relevant to the query.
  3. Designed for modern browsers, across numerous platforms (mobile, desktop, etc. ).
  4. Deliver high quality, credible, and unique content.

Chapter 7:

Who links to you, and how they link to you, is important.

  • Trusted sites like Wikipedia (where there are a lot of communal editors who ensure the quality and accuracy of the content and links) carry a lot of value. Also .gov, .edu, etc. sites.
  • Related sites (sites that discuss a similar topic) carry value as well.
  • The Anchor Text is important.
  • The freshness and frequency of linking is important. This is not a “set it and forget it” activity.
  • And more recently social sharing is important.

The guide also discusses techniques you can use to build a strong, legitimate linking strategy.

Chapter 8:

This chapter discusses behind the scenes tools like Robots.txt and SiteMaps. These are things your webmaster should setup for your site to make it easier for search engines to crawl the site.

Chapter 9:

Chapter 9 discusses the “black hat” techniques that are likely to negatively impact your listing, like keyword stuffing, etc.

Chapter 10:

Chapter 10 covers the tools you should use to measure the success of your SEO activity. They include:

  • The search engine share of referring visitors (how many visitors are finding your site via search engines)
  • The terms and phrases that consumers use when finding your website.
  • The ultimate conversion ratio of search engine traffic, by keyword or key phrase.
  • And how many pages benefit from search engine referred traffic.

The chapter also covers which tools you can use to measure these benchmarks, and how to use the tools.

 

 

Protecting Your Home From Wildfires and Floods – A Public Service Announcement

Growing up in Southern California, my family has experienced its fair share of floods and fires.  My grandfather and great-grandfather first build their beach-side summer home in the 1920’s.  During WWII this home burned down, and when my grandfather moved back in the 70’s to rebuild a retirement home, he did so with the intent that this property would be protected from natural disasters.   HIs efforts were tested several times over the 30+ years when we owned the property, the home surviving numerous floods and wildfires – one of which literally went over the house.   You can read an LA Times article about his successful efforts here.

As the article suggests, much of my grandfather’s knowledge came from Dr. Klaus Radtke.  He met Dr. Radtke at a wildfire seminar in 1978, and they would become lifelong friends.

Dr. Radtke has written an informative e-book entitled “A Homeowner’s Guide to Fire and Watershed Management At the Chaparral / Urban Interface“.   A shorter title might be: “Protect Your Home From Floods and Wildfires.”

I know first handle the value of the knowledge in this book – and if you live in any area susceptible to natural disasters I highly encourage you to download it and read it.

 

New Jersey Uses An Algorithm To Eliminate Bias In Criminal Bail System

Faced with jail overcrowding at a near epidemic proportion, earlier this year New Jersey recently overhauled how it determines bail eligibility for persons awaiting trial.  Now, using an algorithm that weighs the risk of a person to “skip bail”, New Jersey has reformed their system bail system – removing cash from the equation.  A person is either eligible to be let out of jail as they await trial, or they are not.

And apparently, this system is working very well. This algorithm, which was designed transparently by prosecutors, public defenders, and judges, measures simple historical factors such as the crime they are accused of, their criminal history, and their history of reporting for court.

Other areas are looking at replicating this system.  It keeps low risk offenders out of jail and (hopefully) productive members of society, reducing costs of incarceration.

Just enough example of data for good.

Succeeding Through The Success Of Others

I recently learned from a friend who works at Google that a key performance metric for managers at Google is the progress of their reports.  I know first hand how this management style can bring value to a company.  Having worked at both “lean startups” as well as established Fortune 100 companies, I can tell you that (not surprisingly) this is a management technique that you’d more likely find in the former not the latter.

I also believe that this is a critical contributor to the rapid growth of many startups, as it enables companies to maximize the ability for all team members to contribute, and ensures that the team stays motivated and engaged.

Quite simply, the key to accelerated growth is to hire the most qualified candidate, then strip away everything that gets in the way of their success.  This includes office politics!

We often hear about the challenges with pivoting.  Whether its as an owner of a start-up (the innovator’s dilemma) that’s experiencing dramatic growth, or as an employee moving from an individual contributor role to that of a manager, making the transition can be challenging.

Early in my career, I made a common mistake of first time managers …  I micromanaged everything.  We were in a situation where we needed revenue immediately, and couldn’t afford any delays nor mistakes.

I quickly learned that an environment where every decision requires my input is not scalable.  I was spending more time doing the employees job, rather than ensuring that they had the resources necessary to do their job. While my attentive actions ensured our immediate success, they weren’t setting my team up for future success.

As a manager, my job is to empower (not enable) my reports to achieve their very best, by identifying areas of concern for the organization, and then providing my team with objectives so clearly defined that I can step aside and let them develop and implement the solution.  My primary day to day role is to make sure that the objectives are clearly understood by all team members, to keep the team focused on those goals, to assist in removing roadblocks, to answer questions, and to ensure that the team gets the recognition they deserve for the work that they perform.

And most importantly, I’m there to ensure that my team is able to achieve their own personal goals.  It’s naive to think that all employees want to stay in their position forever.   Many have aspirations for growth beyond their current role, and that needs to be encouraged and fostered.  With my teams, I meet with each of them at least twice a year to discuss their personal goals.  Then together we blend those goals with their day to day tasks, ensuring that they have an ascension plan and are still able to do their job. Some may want to work in our European division.  Some may want to become managers themselves.  Others may just want to stay where they are.  Whatever their goal, part of my role is to ensure that the opportunity exists for them to achieve it.

When I look back at my career, the managers who took this approach had the most impact on my career – and for that I am grateful.

 

 

 

What Do The New Communication Privacy Rules Mean To You?

A lot is being made about the recent moves to unwind the FCC privacy rules, which made it difficult for Internet Service Providers (ISPs) to share consumer web and app behavior data without permission.

Data collection and sharing comes down to Notice & Choice.  Was the consumer aware that you were collecting data, did they know how you intend to use that data at the time the data was collected, and do they currently have the option to Opt Out of the collection and subsequent use of that data at any time.

The rules around notice and choice vary from channel to channel and region to region.  If you have ever asked yourself why many European websites have begun posting obnoxiously prominent privacy notices (in some cases requiring you to actually accept the privacy policy before continuing), now you know.

As I mentioned, how this is managed varies from channel to channel, in large part because the technology from channel to channel varies.  In a web browser, a specific no-follow cookie is (somewhat ironically) use to indicate to a web browser that the consumer doesn’t want to be tracked by cookies, or other means.  If the consumer deletes that no-follow cookie, then a website assumes it is alright to follow and track that consumer.

But cookies don’t work in every channel. Addressable TV doesn’t accept cookies.  Most mobile webs don’t either.  Given the many to many relationship between the numerous potential online and offline channels, the countless signals that can be pulled from a consumer device (cookie ID, latitude/longitude, mobile ID a.k.a. MAID, cookie, IP address, device type, etc.), and the different ways in which a consumer can opt out (DMA, IAB, no-follow cookies, etc.) – the challenges of properly managing consumer opt-outs is arduous.

Understandably there was concern when it was announced that there might be changes in the policy which governs how ISPs collect and share your viewing and browsing behavior. Questions like:  what data would be collected and shared?  how would consumers be notified of this data collection (through a pop up screen?  in the terms and conditions of their contract?)   and how could they opt out ?

Unlike other “walled gardens” such as Google and Facebook, who each maintain massive databases on digital consumer behavior, ISPs are unique in that they see all of the Internet activity for their customers.   They are the “last mile” ending at the home, so in the case of wifi they see all activity coming from a specific modem or mobile device, and are able to tie that to the identity of the person paying the internet bill.   Google and Facebook only see that activity for registered users which occurs within their own sites, or sites which use their targeting and analytics services.

At this point it is unknown what the specific changes will be, but it’s certain that they will  impact both consumers and marketers alike.

Marketers need to closely monitor how data is collected not only internally but also by their marketing partners (including media publishers) to ensure that it is done so compliantly.

Building the Right Team and Ensuring Their Success

I’ve had the pleasure of being in management roles ever since a young age. Thinking back, my first role in managing people was in the Boy Scouts. We were a small irreverent troop in a rural beach town in Southern California. When the time came to select a senior troop leader, I found my peers all recommending me. My recollection was everyone quietly whispering my name when they were asked who should be patrol leader; an alternative version might be that everyone took one step backwards leaving me standing alone to take the role. Optimists favor fond memories, so we’ll stick with the former version.

It was more of a ceremonial role; no one saluted me or called me sir. I didn’t lead the troop on hikes, nor decide where we would camp. They didn’t do push-ups upon my command. We were all equals – I was simply responsible for a few additional administration functions. Each person had a clear specialty: one was gifted with a sense of direction, another had an early growth spurt so he took on more physical responsibilities, … my specialty was starting fires – a skill I learned from grandfather as we built fires in our fireplace each night. You could best define our group as a collective, connected yet autonomous … and as a result we made major decisions as a group.

Since then I’ve gone on to manage numerous teams in career. I’ve inherited teams, I’ve restructured teams, and I’ve built them “from scratch”. And through each opportunity, I find myself striving to get back to the organic simplicity we had in the Boy Scouts.

Unfortunately, the perfect team structure doesn’t usually happen organically; it must be manufactured to some extent. It starts with hiring the right person. There is a lot that goes into this decision, but some key things I look for in a team member are:

Energy

You can’t fake energy for any duration. My teams work hard, and play hard – and they need an energetic personality to accomplish this goal. Debbie Downer need not apply.

Smarts

By smart, I mean every definition. Street smart and book smart. Left brain and right brain. Whiteboard flowcharts on the fly, mentally calculate complicated math, and all while geniunely winning over the client and making them your next best friend.

Adaptable

I look for someone who learns quickly, and adapts well to change. They don’t need to be an expert. They need to be capable of being an expert.

Fearless
I tell new hires that they have a six month pass to make every mistake that they can. It’s important to encourage employees to push the limits, and not be afraid of breaking a few (little) things in the process. I’ve worked with teams where the fear of making mistakes stifled ambition and innovation.

A Leader

I’ve learned that you need to empower employees, in stages. At first, I openly micromanage everything that they do. Most businesses where I’ve worked have had extremely complicated products and processes, and new hires benefit from the extra attention. But it isn’t sustainable, and over the course of a few months I slowly take off the training wheels and let them ride on their own. And then I make them responsible for teaching someone else.

A Listener
Most of the time clients will tell you exactly what they want, if you just stop to listen. It’s just as simple as that.

It may sound obvious, but “hiring right” is arguably the single most important thing a manager can do. If you hire the right people, your job as a manager is only that much easier. But, of course, your work isn’t done! Their success, and ultimately yours, largely depends on how you work with them.

Several years ago a friend of mine (who works at Google) mentioned that Google’s managers are measured on how successful their reports are. Success is measured not only by how reports achieve their goals, but also how reports advance within the organization. This concept has had a tremendously positive impact on how I view management and work with my team. My primary goal is to ensure their success. Such an obvious statement whose impact is really determined by the metrics of success (hint: it isn’t just revenue).

Since then I’ve made it a point to meet with my team at least twice a year to discuss their career planning. Where do they want to go within the organization (or beyond), and how do we actually make that a reality? Calculating the return on this is quite simple …. I’ve found that by investing in their future, they invest more in mine.

Technology is Making the Billboard Sexy (Again?)

You can trace the modern day billboard back to the 1790’s, when the advent of lithography made it easy to mass produce signage.  In the 1900’s, billboards followed the explosion of the automobile and moved from the sides of buildings to highways.  Close to 100 years later in 2012, the digital billboard was born – allowing content to change interactively.

Thanks to the proliferation of location tracking through mobile devices, digital billboards are now advancing even further.

Clear Channel just launched a program called Radar, which uses technology and location data from partners like AT&T, Place IQ, and Placed, to build audience profiles based upon the people that pass by the billboard. They’re able to tell an advertiser not only the exposure of the ad but the aggregated demographics of the consumers who likely drove by the billboard.  This is a vast improvement over the old method, which relied on a person actually counting the cars that drove by a particular ad.

Synapse Labs is using cameras to identify the make, model, and year of a car passing by a billboard – and changing the ad content in realtime.  So BMW can target the drivers of late model Audi’s differently than early model Mercedes Benz owners.

Technology has vastly improved two of the three legs of addressable advertising for outdoor signage – modeling and targeting.   All that is left is accurate post-campaign measurement, tying those who are exposed to an advertisement to their future purchases.

These are exciting advancements, and this type of technology isn’t limited to billboards and cars; it can be applied to any outdoor signage.  For example, targeted advertising in a shopping mall based upon the gender of the person standing in front of the sign. And I’m certain that this isn’t the last advancement we’ll see to billboards and outdoor signage.  As cross channel hyper-targeting becomes more accurate through technological advancements, you’ll see better uses of this “classic” media.

Sources:  History of Billboards, Wikipedia

The Rise of the Chief Privacy Officer

Your company’s responsibility as a steward of consumer data is greater than ever. Advances in technology have made it extremely easy to access and collect sensitive consumer data from disparate first, second, and third party sources, analyze that data, and then use that data to build sophisticated consumer profiles which could impact how you engage with that consumer.

Welcome to the age of the Chief Privacy Officer.

As market capabilities have grown, so too has the breadth of what could be considered sensitive consumer data.  No longer is it just name, address, birthdate, and social security number.  Collecting personal information such as transaction data at the product SKU level, digital IDs, location, viewing history, etc. is not only very easy, but also quite common.

As is the ability to tie that information directly to an individual – across both identifiable and (seemingly) anonymous online and offline activities. The technology exists to build more sophisticated Device Graphs, which connect disparate signals to a single persistent offline ID which can ultimately can be associated with an person.  Anonymous cookie ID ‘123’ can be connected to mobile device ID ‘ABC’ which is tied to IP address 123.456.789.123. Once you’re able to associate any of those signals to a individual “offline” signal (for example, a name, postal address, email address, etc.), you’re able to align all of the behavioral data through each of those channels back to that same individual.

And the number of signals that can be used for identification continue to grown.   Recent studies have shown that a phone’s battery behavior as well as the characteristics of a phone’s audio hardware are unique enough to create an anonymous identity for the device.

The responsibility of how this data is collected, the notice and choice that is provided to the consumer, how consumers can access and alter this data, and how your organization ultimately uses that data falls directly on the shoulders of the Chief Privacy Officer.

Let’s use the example of Uber’s recent study on the price elasticity of Uber rides, which showed that consumers are more likely to pay a surge fee if their battery level is low.  In this case, Uber is clearly collecting through its app (among other things) the battery level of your phone.  The obvious concern would be the use of that data in determining the price of a ride.  Uber could theoretically increase fares of consumers based upon their then current battery level, giving consumers with lower batter levels higher prices (because, theoretically, they would pay it).  This could have negative PR and legal consequences.

What is the consumer’s responsibility?

The right to collect, associate, and use this data is buried within each provider’s privacy policy.  It’s up to the consumer to understand what data is being collected, and how it is being used.  It is also the consumer’s responsibility to proactively opt out of marketing channels.

Unfortunately, technology has not made this process simple.   What was once a relatively easy offline process of opting out of receiving direct mail either through the brand or the Direct Marketing Association, has become more challenging as the number of media channels has grown.  Each channel has its own opt out process.  For example, in digital display on a browser it is – ironically – an opt out cookie that alerts brands to not track the consumer, while other channels that don’t support cookies must offer different alternatives.

What is your company’s responsibility?

This isn’t just a legal question.  A key function of the Chief Privacy Officer role is to understand not only the legal implications of actions your company takes, but also the moral and branding implications.  Ideally, actions are decided based upon what is best for the consumer, best for your company, and in compliance with local and federal laws and guidelines.

While the Chief Privacy Officer function won’t achieve the rockstar status that Chief Data Scientist has, it is certainly just as important as your company’s role as a data steward evolves.