Summit Snapshot: With Data Infinity, the Advertising Operating System Has Evolved to Become a Society Operating System – with Ethical Ramifications

August 5, 2021

Big Idea: Data ethics matter, because a mind shift and generational shift tells us they matter. In the advertising ecosystem, we need data-driven operational systems with oversight to keep pace with people, feelings and fairness.

Data ethics was a central focus of this year’s Digital Advertising Accountability Workshop, held June 24 in conjunction with the Digital Advertising Alliance’s Virtual Summit 2021 – and a keynote conversation between author Rishad Tobaccowala, senior advisor to Publicis Groupe, and Sheila Colclasure, global chief digital responsibility and public policy officer, IPG Kinesso, moderated by 4A’s President and Chief Executive Officer Marla Kaplowitz.

“Because of the Internet, because of data and because of technology, we are entering what I call the third connected age where we will continue to thrive,” Tobaccowala said, noting that first connected age allowed us to discover and transact (notably through Google and Amazon), while the second connected age enabled connecting all the time and with everybody (Apple, Facebook) in an always-on way.   

We have now entered the third connected age – and that is far deeper and far broader than ever before, he said. “In this particular case, we’re going to be grappling with data connected to data, which is AI [artificial intelligence], much faster forms of connection, which are 5G, new ways of connecting voice AR [augmented reality] and VR [virtual reality], and the connection to the great God in the sky, quantum-based computing. And the toddler version of that is Google Home, and Amazon ECHO, they are just the beginning. As a result, what all of us do as an industry is going to be very important.”

Tobaccowala: Welcome to a ‘Society Operating System’

While we have created great amounts of wealth, great amounts of empowerment, and great amounts of opportunity for people, we also – unfortunately – have to deal with the three dark horse people.

“One of them happens to be the increasing rise of inequality. Surprisingly, technology has not been the level playing field that people had expected,” he said. “A second has been a great deal of polarization. We are now living in a world where everything is optimized to us. So we no longer listen to anybody, and that’s because of the technology in how algorithms work. And the third – and this is at heart of what we do at this conference – is a breakdown in trust.”

Image of Rishad Tobaccowala

Rishad Tobaccowala Describes a Society Operating System at DAA Summit 21.

In order to understand this, we have to change our minds about something, Tobaccowala declared: “What has been run as an advertising operating system has become a society operating system.”

We need to accept this construct to win back trust, he said. “What we have failed to understand, we are now going to not just have to optimize for the consumer, but we are now going to have to optimize for the citizen,” Tobaccowala said. “In order to regain trust, we have to think broader than an advertising operating system. Philosophically and ethically, that is the way we have to go. Without that, we are just optimizing for money, and I’m not sure we’re necessarily going to get to an ethical answer in the end of that.”

‘Without Privacy, You are Not an Individual’

Marketers, in coping with the realities of such an operating system, have four concerns, beginning with data privacy: “When somebody is looking, you are not who you are. It’s that simple. Without privacy, you are not an individual,” Tobaccowala said.  “It is the most basic human right, and it’s not something for us to give, it’s something that we are trying to take away.”

“Brands are worrying about brand safety, but there is a third concern as well, corporate reputation. It’s not just where your ad may be showing up in a good or bad place, it’s that you may underwriting a problematic thing. And this is what boards are now paying attention to.”

The fourth concern is perhaps the most profound, the loss of “strategic optionality” where some parts of our industry have achieved godlike power and feel free to make the rules for everyone else.

“Who told you you could make rules for all of society? And so a lot of boards are asking how did we get ourselves into a place where we do not have strategic optionality? Why is it that we have one dominant search player? One dominant mobile player? One dominant social player? That is wrong. This is happening not at the CMO level, but at the board level. Something is off. That is something we have to win back, and that is a society operating system.”

Such a system, too, represents both a mind shift -- and generation shift, he said. “These [younger] folks are really the driving force behind ESG [environmental and social governance]. ESG is not because Blackstone decided it was important, or the Business Forum decided it was important – but it was something business had to do because there’s a generation that says it is important. There’s a generation that says DEI [diversity, equity, inclusion] is important. And there’s a generation that says purpose and values are important. Combine the mind shift and a generation shift, there’s a tsunami of opportunities as well as challenges,” Tobaccowala said.

The Pandemic, Digital Adoption and Now, Data Infinity

IPG Kinesso’s Sheila Colclasure described the global pandemic’s impact on human life – and how we digitally connect.

Data Ethics Matter Because We’ve Achieved 'Data Infinity,' IPG Kinesso’s Sheila Colclasure reports at DAA Summit 21

“The statistics say we accelerated five years of adoption [during COVID] in one year. And that really means, as we all pivoted quickly to live our best connected life – personal life, professional life, social life, some of us a connected religious life – the foundation of that is two things, data and technology.”

“I want us to really grasp we are in a different place with data. It’s not just big data – where we’ve talked about data in volume, velocity and variety. We have reached data infinity,” she said. And hence the necessity for data ethics.

“This is really the intersection of where data ethics comes. Data is essential. Data is central. Data is certain and data is infinite. And as we use it to drive our businesses, our people experiences, we in the digital advertising world know that we are custodians. We intend to use data for good. We intend to use data to satisfy our customers and delight them. That’s why we’re here. So if you have infinite data – the data we need to survive – we have to become data-driven. It’s a certainty.”

Is it Legal? Is it Without Harm? Is it Fair?

There are three hallmarks of data for good, Colclasure said. “Is it legal? Because law is a codification of a social norm. It’s something we’ve wrangled through our legal systems to decide.

“Using data for profit before people is really what has given rise to privacy law, and of course, way more enforcement, the rise of consumer advocacy, of civil libertarians, and concerns about digital equity, digital inclusion, digital democracy, and – very interesting – the rise of executives’ criminal liabilities for data issues, that’s here now happening.”

“The next category of obligation is the harms test,” she said. “Are you using data in a way that the impact and consequence of that data outflow is financially harm, physically harm, or the newer harms – emotional, social, reputational, bias, discrimination. We have to detect and prevent.

“The third bucket is the ‘F’ word – fairness. Fairness really gets at the people perspective. It is the fundamental of human civilization. …When something is not fair, as Rishad spoke a moment ago, there’s a feeling that something is off and not working. We care now because things aren’t fair. So fairness really really matters, and that gets to heart of what we’re trying to solve for.”

North Star: Ethics by Design and Let the Benefits Flow

“It’s a design ethos that must start with intention, and must be instrumented into operations with the use of data, with monitoring and oversight. The ability of our industry to do good things with data, to create good effects for people, for good outcomes that put people before profit, goes to not just consumer trust, but the trustworthiness of our industry. I give a shout-out to DAA, they’ve done really great things with instrumentation to solve for some of our woes.”

“I talk about the work that I do as the North Star,” Colclasure said. “As we take our clients into the Digital Age… we talk a lot about digital responsibility and that means four buckets: Ethical, Accountable, Safe and Secure. So it really is the North Star. It is a star to guide everything we do. And I like to start with ethics – I think that’s key.”

In speaking to how data may be regulated – either by law, by tech settings or by industry best practice – Colclasure was adamant: “Whatever law we end up with, the fundamental is that the benefits flow, and then we have a lot of good transparency… and choice mechanisms to participate or not to participate, you can tune those dials. You have to start with ‘benefits on.’”

Brands and Publishers Need to Think Through Their Customers’ Privacy Experiences – and Own It

A follow-on to the data ethics conversation, included a “brand” response from Sal Tripi, vice president, digital operations and compliance, Publishers Clearing House /, with Senny Boone, senior vice president, accountability, Association of National Advertisers. Tripi noted that the pandemic has brought people’s personal, professional and online lives “all melded together.”

PCH’s Sal Tripi Says Brands and Publishers Need to Own the Privacy User Experiences of Their Customers

“That is enhancing the need for transparency, trust and ethical business practices,” Tripi said. “As businesses, we are at a pivotal point to make sure we are conducting business in a way we’re proud, and in a way that’s transparent to the consumer, in order to make sure we establish and maintain trust.”

“Put yourself in the consumer’s shoes and make sure that what you’re doing is not only legal, but as Sheila was saying earlier, but is it ethical – with both a consumer standpoint as well as a business standpoint.”

Tripi noted that his company has a cross-function team for privacy, data security and ethics – and emphasized that every vendor the company works with must weave data and ethics as a thread. It’s part of the company’s vetting, contractual and monitoring process with service providers. When the consumer has a challenge, he noted, it makes no sense to point to a third-party provider – it’s the brand the consumer holds accountable. 

“As a national brand for 63 years, establishing trust in our sweepstakes, and trust in our organization, is absolutely essential because… if they don’t trust in us, consumers will not enter or buy merchandise, or view the advertisements that are shown on our page,” Tripi said. “We closely monitor all customer contact, and listen to what consumers are telling us. We audit our security and privacy procedures as a result.  We continue to strive to be better.”

“We’ve always said that privacy can’t be managed from the legal department, or can be managed within the compliance group,” he said. “It has to come from culture that comes out throughout the organization.”

“Consumers have expectations that we’re going to deliver very relevant targeted experiences,” Tripi continued. “Advertising needs to be as relevant as the content on your page. Advertisers expect it. Consumers expect it – and it takes data to do that. I think everybody understands that. Yet there’s still an ‘ick’ factor about how the advertising ecosystem works. I think we – as brands as publishers – have an obligation to make sure that the consumer has a good understanding about what’s happening.” For consumers that want to know, that translates to just-in-time disclosures and privacy policy disclosures that are easy to access and understand, he said. “And we need to deliver that experience as a brand.”

DAA as an Indispensable Brand and Publisher Resource

Toward that end, Tripi also acknowledged the Digital Advertising Alliance in his remarks. “If the Chairman of the Board of Publishers Clearing House came to me and said, Sal, you’ve got an unlimited budget to staff your organization with the right people, the first thing I’d do is go out and look for people that are really smart and knowledgeable. I would look for people that have contacts and know everyone in the industry and could bring appropriate parties to the table.  I would look for people who have industry relations with legislators as well as others in industry, and knew how to bring them all together and help us, when we need them.  The DAA is all that.”

“When identity first started, and identity resolution and token-based identity were getting big, and Publishers Clearing House wanted to dip our toes in – do we really want to get involved with this… one of our first calls was to DAA and Lou [DAA Executive Director Lou Mastria]. Where do you see this? Where is this going?”

“And his perspective on this is just fantastic,” Tripi said of Lou. He’s able to provide us not only the perspective that’s important to me as far as being a publisher, but was also able to tell me the brands, how they are, how are the ad ecosystem and the service providers looking at this. A 360-degree view of the issue – and okay and now to stay on top of this, we’re going to provide you a tool to help you manage it because, you know, technology evolves very quickly. I’ve got my own technology team on a roadmap that’s as long as my arm. We’re really looking forward to integrating with DAA’s token-based opt out, and I think the DAA – as well as the ANA – I throw you kudos as well as the other organizations that are there to make our jobs easier.  They do a lot of the heavy lifting, and they do a really good job at it – and they’re really friendly, nice and accommodating.” (Gee, thanks Sal.)

While data ethics is all fascinating, compelling, dynamic and must be an integral part of brands and their customer engagement mapping, it is understandably complex. Having these perspectives shared at this year’s Summit truly helps place both perspective and context around the DAA Principles and the work being undertaken to bolster consumer trust in how we use data “infinitive” responsibly to deliver benefits to the marketplace.

Editor’s Note:  Rishad Tobaccowala expanded on some of his thoughts on privacy in his Substack blog. Read more here.

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