Greenlight digital marketing - when the digital cookie crumbles


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Browser ‘cookies’ are the life blood of online marketing. They tells us where our site traffic comes from, in what quantities and what it does when it gets there. But the humble Cookie is under threat from many angles. Come May 26 2012, European privacy laws come into force. All UK websites must offer users opt-in consent tools to allow cookies to pass information about browsing activities to 3rd parties. So here’s our brief and easy to read slide pack giving you an overview and highlighting options.

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Greenlight digital marketing - when the digital cookie crumbles

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  2. 2. Who is Greenlight?I should begin my presentation by declaring any interests by explaining a little aboutGreenlight, the agency I represent in the capacity of Client Services Director.Greenlight started originally as a search marketing agency back in 2001 specialising innatural search optimisation (SEO) and paid search advertising (PPC) but we have sinceexpanded to cover all forms on digital paid media, Social Media expertise and a fullstrength data technology arm to allow us to provide better strategic value to clients. 2
  3. 3. What is a cookie?And it is data that I want dwell on today starting with the humble cookie.Browser ‘cookies’ are the life blood of online marketing. These tiny dumb text files tell us whereour site traffic comes from, in what quantities and what it does when it gets there.I don’t know if you ever taken the time to look at one of the multitude of cookies that your webbrowser stores but each cookie file is really no more than a string of variables written in a textfiles usually around just 5 Kilobytes in size.Cookies are integral to the delivery of two of online marketings key USPs personalisation and trackingThey are used by essential systems such as: Content management systems – enabling the personalisation tweaks which improve site conversions Site analytics systems that count the numbers that tell marketers how their site is working Ad delivery networks – that help marketers place ads and track their effectiveness 3
  4. 4. Why is it under threat?Google’s use of secure serversGoogle’s increasing use of secure servers for all logged in traffic means thatincreasing amounts of natural traffic is now stripped of its valuable meta datarevealing precious information about its source. This first started about sixmonths ago in the US and was finally rolled out in the UK this month when westarted to experience this uncomfortable form of data blindness.The meta information blocked by Google’s secure servers critically includes thekeyword entered in the user’s search query from which we can determine somuch about not just the motivation behind the user’s visit to a site but also theeffectiveness of our online marketing investment. 4
  5. 5. Why is it under threat?Multi-platform marketingThe second threat comes from the increasing use by consumers of a multitude ofdifferent platforms. This means that an analytics system tuned to a single deviceis no longer sufficient to reveal the full click-path of your potential customer.As they hop from desktop to mobile to tablet each platform drops a differentcookie file to track usage on it. These files do not natively cross-reference, leavingthe marketer blind to the contribution to a sale from each channel and thereforeto the effectiveness of the marketing spend dedicated to it. 5
  6. 6. Why is it under threat?Last but by no means least is the legal threatThe EU Commission has been on the hunt for the cookie since the Directive onPrivacy and Electronic Communications Regulations was first announced in 2003.This rules that businesses must tell users about the cookies used on theirwebsite, what the cookie is doing, and – crucially – gain their consent to use thatcookie.Incredulous online marketers have been in denial about this slow burning butfundamental threat to their existence ever since.These regulations came into law in May last year but the InformationCommissioner’s Office (ICO), stated that they would not be enforced for the firstyear which gives us just 1 month left to get compliant! 6
  7. 7. Why is it under threat?The Legal ThreatIt is worth pointing out here that, in the eyes of the EU Commission, not allcookies were created equal.The table on the left of this slide shows a clear distinction between the activitiesusing cookies that the EU will accept without prior consent from the user(shaded in green) and those that it will not (shaded in red). If it wasn’t before, itshould be clear now, that the Commission is particularly targeting the use ofcookies for explicitly marketing purposes. It specifically names: the counting of unique visits to a website, first and third party advertising, and onsite personalised messaging to returning visitors On the right you can see how the website of the UK’s Information Commissioner’s Office has kindly added the consent box to its website to show us all how it should be done. 7
  8. 8. Despite this exemplary behaviour, 90% of visitors to the InformationCommissioner’s Office (ICO) website did not consent to their cookie. 7
  9. 9. Why is this a problem?On 25 January this year, the European Commission unveiled its full proposals forfar reaching changes to EU privacy legislation beyond eCommerce.While the swanky media lawyers Olswang only "foresee the Regulation being inforce by 2015" they note gloomily that "every aspect of an organisationscompliance obligations will increase – and there will be fines of up to 2% ofglobal turnover for breach".At the risk of stating the obvious, the Direct Marketing Association said it had“serious concerns” about the potential impact of some of the new DataProtection Regulation’s requirements. It said:“If the Regulation were to come into force tomorrow, then it would have costlyramifications for companies involved with direct marketing, and in turndetrimental consequences for the UK economy.” So what are its concerns specifically? 8
  10. 10. Why is this a problem?1 - Opt-in / opt-out and obtaining consentThe new Regulation doesn’t go as far asheralding a comprehensive opt-in onlyregime for direct marketing - but it comesclose.Companies will have to obtain explicit 9
  11. 11. consent from consumers by ‘clear statementor affirmative action’ (ie. clicking) to usetheir data for marketing purposes. 9
  12. 12. Why is this a problem?2 - IP addressesThe new regulation would also class IP addresses aspersonal data which would result in web analytics nolonger being available to companies without theconsent of individuals.The additional impact on online user experience makesthis ruling a double-whammy as many sophisticatedwebsites make considerable use of cookies and IP datato improve conversion rates by providing an enhanced 10
  13. 13. user experience. 10
  14. 14. Why is this a problem?The right to be forgottenThe third specific issue is that companies currently holding an individual’s dataand passing them to third parties would not only have to delete that information,they would have to ensure the third party deletes that information too. Thiswould spell disaster for data list brokers but companies would also have to faceincreased data processing costs. 11
  15. 15. Why is this a problem?Free right of access to consumer dataWhere companies currently have the right to charge £10 to recover some of thecosts of providing consumers with access to the data they hold on them, underthe new Regulation, companies would have to supply this information free ofcharge.In 2009, the Ministry of Justice estimated that UK businesses spend £50 million ayear in fulfilling subject access requests through added manpower costs. 12
  16. 16. Why is this a problem?Other issuesMarketers will need to secure parental consent to market to under 13s. Whilethis sounds sensible it is so impractical as to make it almost unviable.All companies will need to keep data on record and demonstrate compliant datamanagement processes while companies with more than 250 staff will also needto appoint a designated independent data protection officer. 13
  17. 17. What can marketers do about it?Online marketers have to re-examine how they track and optimise theirmarketing spend in the light of the multiple threats to cookie-based data whichcurrently provides them with almost all their data.What options are available?1 – Look into the compliance of your site2 – By making better use of the data that users do consent to provide throughcookies3 – Make better use of non-cookie-based data gathering 14
  18. 18. What can marketers do about it?1 – Look into the compliance of your sitePerhaps unsurprisingly, many website owners don’t know how many cookies areactually in use across their site. So the first task is simply to understand theextent of the problem.As you would expect, there are now a number of companies offering to help outhere. One that we have recommended to clients at Greenlight is called Optanonand operates as a simple Chrome browser extension alerting you to each cookiebeing used as you browse through your site. 15
  19. 19. What can marketers do about it?2 – By making better use of the data that users do consent to provide throughcookiesMulti-channel attributionMarketers are increasingly turning to attribution models to understand the full impact oftheir marketing investment across all channels. Measuring the weighted contribution ofeach online marketing channel is a service offered by an increasing number of analyticstechnology providers with varying degrees of user-friendliness.However, the recent acquisition of AdInsight (to whom I owe this image) by Tagmansuggests that attributed tracking both online and offline is becoming a distinct possibilitywith AdInsight tracking sales from websites to call-centres via unique telephonenumbers and Tagman attributing these sales back to online channels which previouslywould otherwise have been left uncredited. 16
  20. 20. What can marketers do about it?2 – By making better use of the data that users do consent to provide throughcookiesThe second way I would recommend to make better use of your precious cookiedata is behavioural segmentation. By collecting very granular data about eachuser visit we can identify the common characteristics (such as source channel &campaign, pages viewed or actions taken on the site) and segment usersaccording to their propensity to purchase.The graphic above was supplied by QuBit, a relatively new tracking technology,that enables marketers to view behaviourally attributed sales data in real time inbrowser-based dashboards. However, the system does not stop there.By creating customer segments based on behavioural attributes, the system canthen identify users by their likely segment which allows marketers to adjust themessaging, product display or purchase path accordingly in order to achieve thehighest conversion rate for each user. The system can also push feedbackrequests to users from each segment to provide specific responses to more 17
  21. 21. granular questions that you might have. 17
  22. 22. What can marketers do about it?3 – Make better use of non-cookie-based data gathering.Hydra - 1Natural search traffic is, by definition, untracked until it gets to your site butthere are tools that can help to visualise the opportunity from non-paid searchresults which, Google admits, attract on average 75% of the clicks from theaverage search query.The image here is taken from the Hydra platform and displays the natural searchkeyword categories in terms of their total search volume (shown by the size ofthe squares) and the impression share of the site against this volume (shown bythe colour, with green meaning good and red meaning poor). 18
  23. 23. What can marketers do about it?Hydra - 2By overlaying the average position in Paid Search of the same keywords we canstart to formulate actions based on an integrated view of natural and paid searchactivity. 19
  24. 24. What can marketers do about it?Hydra - 3 20
  25. 25. What can marketers do about it?Influencer AnalysisThere are many so called ‘buzz monitoring’ tools that provide marketers with non-cookie-based quantitative data on the proliferation of their brand on Social Mediaplatforms. While this is certainly interesting, it is often more useful to identify the keyinfluencers associated with a given topic in order to devise practical strategies on how toengage with them to promote their product more effectively.The Google+ tool ‘Ripples’ as shown is a great example of this and even allows you to“play back” the spread of the influence on a given topic to show the viral effect in action.The topic (as defined by a URL) I will show you now is the infamous Kony 2012 video onYouTube. On the left you can see the standard YouTube statistics which tell you that thevideo was viewed over 80 million times in its first week online and some data on thesources and demographics of these viewers.On the right you can see a more interesting visualisation of how this internet memeconquered the world earlier this month and, specifically, who was responsible forspreading it! 21
  26. 26. [Click]As I play the video you can see the timing of each new post linking to the video, who sentit and who in their sphere of influence passed it on. 21
  27. 27. Recent headlines showed that Google is willing to test the EU Commission’smettle with a sweeping revision of its terms & conditions being deemedincompliant. I suspect many marketers will be playing a dangerous waiting gameto see the outcome of this battle of the giants.But only this week there was a new development on the legal saga that is the EUPrivacy and Electronic Communications Directive.[Click]No less an body than the UK’s Government Digital Service has weighed in to thedebate with their “Implementer’s Guide” to the Directive.The GDS takes the view that web analytics are “essential to the effectiveoperation of government websites” and that “at present the setting of cookies isthe most effective [and “minimally intrusive”] way of doing this”.They point to the following statement in the Information Commissioner’sGuidance to justify their gamble that this fellow governmental body will not crack 22
  28. 28. down on analytics: “Provided clear information is given about their activities weare unlikely to prioritise first-party cookies used only for analytical purposes in anyconsideration of regulatory action.”Frankly this only serves to muddy the water as it is unlikely the ICO will be astolerant of a major private company making this same argument. So meanwhile,the rest of us can return to our default position of checking our potential liability,preparing our transparency and consent procedures and waiting it out whilehiding behind Google. 22
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