Fairness may be the first principle of the Data Protection Act in the UK, but it is a difficult concept to define. Is the use of open source data to help build a profile of a consumer that determines the offers they receive fair? Marketers would argue that it is, but does the consumer see it that way if their estimated income, house price or love of golf is involved?
To Europeans, that might seem a step too far, but in the United States it is commonplace. Far more data is freely available to marketers from a wide range of both public sector and commercial sources. Little wonder, therefore, that the concept of open data originated in America. Or that a significant step towards greater openness about what data is held on individuals and how it is being used has just been taken by a US business which is one of the largest marketing data companies in the world.
Earlier this Summer, Acxiom unveiled AboutTheData.com, a website that puts access - and to a large extent control - over the information held on them at the fingertips of US consumers. The move is notable for two reasons: firstly, data brokers have not historically been that transparent about the volume and nature of information which they hold, and secondly, the website was developed without any direct requirement from regulators to do so.
“It goes to the issue of transparency about the data Acxiom holds on consumers. It is an initiative which has been under development for two years and was driven by our CEO, Scott E. Howe,” explained Jennifer Glasgow, global privacy and public policy executive at Acxiom in an exclusive interview with DataIQ.
The site’s goals are to provide access, control and choice - educating US consumers about the data held on them and especially how it is used in marketing and also providing a degree of control over that usage. “The US doesn’t operate under data protection laws like the European Union has. Although there are a lot of sector-specific laws, they are not as robust - there is no right to access data, for example,” explained Glasgow.
Acxiom’s decision to create a privacy centre of this sort should be all the more lauded as a consequences, even if, as Glasgow points out, the company has provided an opt-out mechanism from marketing via its website for the last 15 years. AboutTheData.com now offers two control mechanisms - detailed review and editing of specific variables or a simple route to the opt-out.
The site explains in consumer-friendly language how marketing uses data and also where different pieces of information are derived from. Users first verify their identity using their social security number (a commonly-used identifier in the US and one advantage for data owners of America’s more open data culture) and then access data sets organised into six categories - personal characteristics, home, vehicle, economic data, shopping and interactions. If a consumer sees a piece of data that is wrong or out-of-date, such as the age of their children, they can correct it.
One ongoing dilemma for Acxiom is how to deal with these consumer-directed changes to pieces of data which initially came from verified sources, such as the sale price of a house or the type of car registered to an individual. Variables can be edited simply, as Glasgow shows in a demonstration by switching political affiliation with one click. “We intend to analyse the data that individuals change and may make some adjustments to this function in the future. More correct data is always better, but data quality is a by-product of this,” she says.
Less contentious was the desire to get ahead of the data protection agenda. “We have seen in the last two years more interest in understanding data among consumers. We want to be involved in that debate, which is why we are involved in a number of industry working parties to shape that discussion,” says Glasgow.
Creating the data portal has been a technical challenge since it requires information to be available online in real-time. Changes to marketing were already driving Acxiom in that direction. “We tipped the balance last year, with most of the data we have about people now deployed for online use in ad targeting as well as for emailing. We had to be able to offer our data in an interactive way, rather than in batch,” says Glasgow.
That meant migrating from offline storage into a new infrastructure which offered the incidental benefit of being able to support the consumer portal. Its commercial focus is the new Audience Operating System or AOS (www.aos.acxiom.com), a cloud-based single view of the consumer based on multiple data sources (including first and third-party data) made available through an expanding, open-source application suite. It claims to deliver true one-to-one marketing across any channel or device at scale. “We came together as a business and decided it was time to do that,” she says. “It was driven by Acxiom, rather than being dictated by a specific law.”
“We see the site as answering three basic questions. Firstly, people didn’t understand why companies wanted their data. Secondly, they didn’t understand how we got the data, even though US consumers realise there is a lot of data in the public domain because they can search for things like car ownership and house price. Thirdly, they didn’t know what type of decisions companies were making about them based on that data,” says Glasgow.
Why, how and what are fundamental dimensions of any debate around data protection, so providing greater transparency and clarity should help as the US starts to frame its legal response to the issues. On the back of Do Not Track and Federal Trade Commission enforcement, companies are being pulled into a de facto regulatory framework.
Glasgow believes it is vital for the data industry to keep the consumer onside throughout that process. “It has not really done enough to demystify data, so Acxiom is taking a different approach to make sure we are more transparent than ever,” she says. To that end, she has been presenting a call-to-arms for data owners, including at an Ad:Tech presentation this Autumn in the UK, urging fellow brokers and marketers to adopt a more consumer-focused approach.
“What that means is that being relatively secretive about your business practices is the old school of thought. You now have to be open and transparent. But equally, you need to defend those practices that are worth defending. We need to establish which are the new marketing norms based on the analytical power we have at our fingertips,” she argues.
Direct marketers may have held an individual’s date of birth, but in the past would not have sent a card saying Happy Birthday for fear of appearing creepy. Instead, they might have offered a discount coupon to disguise this knowledge. Glasgow believes the new paradigm is to be obvious that you hold this data while providing the individual with the opportunity to pushback, by opting-out or amending data. (Consumers can use the AboutThe Data.com to opt-out even without providing their date of birth or tax ID, she points out, but fewer consumers exercise this option than simply correct one or more pieces of data.) Indeed, a key part of the education angle is ensuring consumer realise that, by opting out, this will not result in them receiving no advertising, it simply means the ads and promotions they do receive will not be personalised based on data. Instead, they will be a random selection. The question is whether this randomised - and possibly less relevant - marketing is the price we have to pay for privacy? Only individuals can asnwer that question.
Regulation will undoubtedly still come into play in the US to make things tighter for data brokers. Consumers will also voice concerns about who holds their data and for what purpose. But in launching the site and being as transparent as possible about their business, Acxiom has undoubtedly got ahead of the curve. It is now for other data companies to play catch-up.