THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE

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THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE
THE CAT AMONGST THE PIGEONS

ACCC ADTECH INQUIRY
AND
ADMA’S RESPONSE
THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE
Right Message, Right Audience

THE PERENIAL PROBLEM
FOR MARKETERS
THE DISINTERESTED AUDIENCE
THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE
OLD SCHOOL
TARGETING
THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE
THE ADVERTISING
SUPPLY CHAIN
                           Advertising
                       opportunity and data
                                                          Online Content and
                                                               Services

 ADVERTISER   AGENCY      ADTECH              PUBLISHER     Display ad         CONSUMER
                        SUPPLY CHAIN

                         Payment for ad                   Online Advertising
                          opportunity
THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE
TWO SIDES TO THE
AD:TECH CHAIN

          DEMAND SIDE              SUPPLY SIDE

       Advertisers and media   Publishers and adtech
             agencies                 vendors
THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE
TWO SIDES TO THE
AD:TECH CHAIN

 DEMAND SIDE           SUPPLY SIDE
 Advertisers and
 media agencies    Publishers and adtech
                          vendors
THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE
SUPPLY SIDE

                                                                   ADTECH SUPPLY CHAIN
                       AD NETWORKS
                                                                                    PUBLISHER AD                FURBALLS
                                                                                      SERVER
                                                     SUPPLY SIDE
                                                      PLATFORM
                                                         (SSP)
 DEMAND SIDE

Advertisers and
media agencies

                  SSPs connect to multiple ad networks       Publishers set a floor price and sell   Publishers might sell some
                  so they can maximise the publishers        their spare inventory on called a       inventory through direct buys
                  opportunities to sell inventory            SUPPLY SIDE PLATFORM (SSP)              or private deals
THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE
WHAT HAPPENS ….
                                    Publishers ad server requests an ad to from                          Snowflake goes online to
                                    the Supply Side Platform (SSP)                                       research her furball issue and
                                                                                                         she lands on the Yorkshire vets
                                                                                                         page
                                                  ADTECH SUPPLY CHAIN

                                     Ad Request       PUBLISHER AD      Ad Request to   FURBALLS
ADVERTISER                             to SSP           SERVER            Ad server                   Online
                      SUPPLY SIDE                                                                  Content and
                       PLATFORM                                                                      Services
                          (SSP)

                                     Display ad                         Display ad

Advertisers can                                        Supply Side Platform (SSP) sells the
start bidding on                                       inventory to highest bidder and serves up
that inventory                                         an ad to the publishers ad server
based on what
they are willing to
pay and the
audience they are
looking to target
THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE
THE OTHER SIDE OF
THE CHAIN

                                             SUPPLY SIDE
                       DEMAND SIDE
                                            Publishers and
                                            adtech vendors
                    Advertisers and media
                          agencies
THE CAT AMONGST THE PIGEONS ACCC ADTECH INQUIRY AND ADMA'S RESPONSE
DEMAND SIDE : AGENCIES
 AND BIDDING
                    They use DATA MANAGEMENT PLATFORMS (DMPS)
                    gather, storage, and organise audience data to
                    optimise targeting                            ADTECH SUPPLY CHAIN
                                                                                                                     SSP

                 DATA MANAGEMENT PLATFROMs
                          (DMPs)
ADVERTISER                                                                              DATA SIDE PLATFORM
                                                                                                                     SSP

                                                                                                                     SSP
                 AGENCY TRADING DESK (ATDs)

                                                                                        DATA SIDE PLATFORM
Advertisers
define:
who to target
what they will
                                                                                                                     SSP
pay. They
engage via an
agency or          Agencies & Brands use AGENCY TRADING DESKS                  Demand Side Platforms (DSP’s) are
directly           (ATDs) to manage programmatic media buying. They            the systems used to bid, manage,
                   leverage the data in DMPs to facilitate targeting and       serve and track ad inventories from
                   will manage the bidding process via interaction with        multiple ad sources (e.g. SSPs)
                   multiple DSPs
DEMAND SIDE : AGENCIES
 AND BIDDING               DATA MANAGEMENT PLATFORMS (DMPS)
                           gather, storage, and organise audience data

                                                                                                                              SSP
                                                                         ADTECH SUPPLY CHAIN

                       DATA MANAGEMENT PLATFROMs
                                (DMPs)                        AUDIENCES                         DATA SIDE PLATFORM

ADVERTISER
                                                                                                                              SSP

                                                                                                                              SSP
                       AGENCY TRADING DESK (ATDs)

                                                                                                DATA SIDE PLATFORM
Advertisers define
who they want to                RESEARCH
target and what they            SERVICES
are prepared to pay
                                                                                                                              SSP
to reach them. They
then engage directly
or via an agency in       AGENCY TRADING DESKS (ATDs) buy media                        DSP’s are the system ADVERTISERS
the supply chain          programmatically on behalf of brands. They leverage          use to purchase and manage ad
                          the data in DMPs to facilitate targeting and will            inventories from multiple ad sources
                          manage the bidding process via interaction with              (e.g. SSPs)
                          multiple DSPs
TWO SIDES TO THE
AD:TECH CHAIN

          DEMAND SIDE              SUPPLY SIDE

       Advertisers and media   Publishers and adtech
             agencies                 vendors
AUDIENCE
DATA
                                                                                                  FURBALLS

FIRST PARTY DATA Data collected on your site
Snow has an account on Nine entertainment, they know:
she lives in Newtown, is a creative director, she accesses the site
via an iPad, has high speed internet, based on her DOB she is over
18 (she lied) and her content preferences skew heavily towards
animals and period dramas.                                            SO in the case of Snow and Nine/Science
They currently don’t know she is a cat but they assume she must       Diet
own one …..
                                                                      If Science Diet did a second party deal with
                                                                      Petbarn and chose to advertise on Nine, via
SECOND PARTY DATA Data Someone else has collected on their site       a direct buy, they could target Snow directly
Snow shops at Petbarn online and gets all her pet supplies
delivered. Monthly she buys Science diet (sensitive stomach           If they choose to target snow
kibble), a range of gourmet (gluten free) pates and a special
                                                                      programmatically, they would be doing so
imported brand of cat litter.
                                                                      based on her presumed interest in pets, or,
                                                                      based on her recent browsing history
THIRD PARTY DATA – Data collected from multiple sources               (2 day cookies).
Snow has been added to a number of pools for high end
pet fashion
THE VALUE OF DATA
              First party data - is the most valuable because of its quality. You collect it, it’s accurate, it’s your audience. It’s
              directly relevant to your business.
        $$$
              USES: Direct targeting, Predict future patterns, audience behavior, Insights and strategy. Testing messaging

                       Second Party Data - someone else’s first party data (quality remains high). Extremely useful if you find the
                       right partner. Opportunities to access to information and insights you don’t have on your audience.
         $$
                       USES: Expand reach, predict future patterns, understand more customer behaviors and build out your
                       current audience pool

                                 Third Party Data – aggregated anonymous data organized into categories, bought and sold
                                 programmatically. Major benefits are its scale, the downside is that you don’t know the original
         $                       source or quality and its not exclusive.

                                 USES: Can be useful to expand insights into your first party data, identify prospecting audiences
                                 that hold similar attributes.
                                 WATCH OUTS: Its going to have no value at all in 18 months time
AN EVOLVING
LANDSCAPE
 We are facing one of the biggest
 periods of transition our industry has
 seen
 • ITP (Intelligent Tracking Prevention)
   on Safari
 • GDPR – its not in Australia yet but its
   coming…
 • The imminent death of 3rd party
   cookies
 And this:
 • In 2018 Josh Frydenberg kicked off
   the digital Platforms inquiry (paper
   published in June 2019)
THE DIGITAL ADVERTISING
   SERVICES INQUIRY

ACCC Digital Platforms Inquiry recommendations found:

    ‘complexity and opacity associated   with adtech pricing’

Federal Govt commissioned ACCC’s Digital Platforms Branch to
conduct a follow up inquiry with a focus on:

    Competitiveness, transparency and effectiveness of markets
    for supply of digital adtech services and ad agency services

Inquiry is currently underway
KEY DATES
• Interim report due 31 Dec 2020
• Final Report by 31 August 2021
SUBMISSIONS
                                                                                                                                                            Industry Association
                                                                                                                                                            Agency
                                                                                                                                                            Publishers
                                                                                                                                                            Global Tech

41 Submissions (as at                               25th   August 2020)
                                                                                                                                                            Data Services
                                                                                                                                                            Industry Ombudsmen
                                                                                                                                                            Research
Industry Associations                                       Publishers                                                                                      Scholars
                                                            •    Daily Mail Australia                                                                       Misc
•   Asia Internet Coalition
                                                            •    Guardian News Media
•   ADMA
                                                            •    News Corp Australia
•   AANA
                                                            •    SBS
•   Commercial Radio Australia
                                                            •    Star News Group
•   Computer & Communication Industry Association
•   Country Press Australia
•   Free TV Australia
•   Interactive Advertising Bureau
•   Media Federation of Australia (MFA)                     Digital Advertising Platform/ Global Tech
•   Music Rights Australia                                  •    Facebook (2)
                                                                                                                         Scholars
                                                            •    Google                                                  •   Allens Hub for Technology
Agency                                                      •    Microsoft                                               •   Dr Balasingham (Macquarie Uni)
•   Dentsu Aegis Network Australia                          •    Oracle                                                  •   Dr Katharine Kemp (UNSW)
•   Havas Media                                             •    Verizon Media                                           •   Dr Nico Neumann ((Melbourne Business School)
•   Kinesso
•   Omnicom Media Group (OMG)                                                                                            Misc
•   WPP AUNZ                                                 Industry Ombudsmen
•   Sites N Stores                                           • Australian Small Business & Family Enterprise Ombudsmen   •   Confidential Party 1 & 2
                                                             • Telecommunications Industry Ombudsmen                     •   Damien Geradin & Dimitrios Katsifis (for Google)
                                                                                                                         •   Daniel Bitten Stephen Lewis
                                                                                                                         •   Timothy Whitfield & Denise Shrivell
Data Service Provider
                                                                Research
• Loyalty Pacific (Flybuys)
                                                                • Consumer Policy Research Centre
                                                                • International Center for Law and Economics
IS IT
                        SUSTAINABLE?
                                             ARE WE
      WHO GETS THE                          BUILDING
        MONEY?                            BRAND TRUST?

                                                            FOCUS AREAS OF
                                                            ADMA RESPONSE
                                                  WHAT
WHERE IS THE                                   DETERMINES
  VALUE?                                        SUCCESS ?

               STANDARDS
                                    BIDDING
                   OF
                                   PROCESSES
               MEASUREING
                                   AND FLOOR
                  AND
                                     PRICES
               REPORTING
WHERE DOES THE
VALUE LIE?
WHERE DOES VALUE LIE IN
THE SUPPLY CHAIN?

• Media channels remain the largest expense
  in any marketing budget. Digital spend has
  eclipsed traditional channels

• It is in the best interest of the consumer, the
  advertiser and the media channel.
THE LANDSCAPE IS
GETTING COMPLEX

2011               2020
WHERE DOES THE
VALUE LIE?
• Marketers don’t generally know
• In Australia, spend less in programmatic
  than other economies (40% vs 60% in US)
• Media remuneration models have been
  slow to adapt
• Technology is often inconsistent in
  measuring value
• Many clients are looking at different
  models e.g. taking media inhouse, media
  managed, who owns the invoicing
THE
CREATIVE
SUPPLY
CHAIN HAS
BECOME
MORE        • Volume of content required has increased (in 10 years from 150 – 200 pieces a year to
COMPLEX       almost 3000 pieces of work (Trinity P3) … is this necessary?
            • Digital channels all have multiple different creative requirements
            • Specialist skills are required to execute
            • Niche agencies and suppliers with varying business models have evolved
            • Production has commoditized creativity and remuneration models have been slow to
              adapt
Recommendation 1:
ADMA welcomes scrutiny of the extent of value creation and value capture along
stages in the marketing and advertising supply chain.
Generalisations and quantitative analysis of value points in the advertising services
supply chain is inherently difficult, given the diversity of paths of players,
technology and data that collectively constitute the marketing and advertising
supply chain.
ADMA supports efforts to improve transparency in the marketing and advertising
supply chain. ADMA can assist in development of case studies that would assist in
providing better transparency of some reasonably representative value chains.
WHO GETS
THE MONEY?
THERE ARE COSTS AT EVERY STAGE
           OF THE SUPPLY CHAIN
Retainer Fees

                                                       3rd party data $
                                                       2nd party Data $$
  Tier 1
 Agency
                                                                           DMP hosting and
                                                          DATA             transaction fees
                Setup fees
                                                       MANAGEMENT
                Transaction fees
                                                        PLATFROM

                   Agency
 Digital
                   Trading               AGENCY
 Agency
                    Desk              TRADING DESK                                      Floor Price                   Ad serving fees
                                                            Bid price
                                                                                                      Ad Request to                     Ad Request to
                                                                                                          SSP         PUBLISHER AD        Ad server
 Production                                                                           Supply Side
                                                                                                                        SERVER
    Fees                                                 DATA SIDE                     Platform
                                                         PLATFORM                        (SSP)
                    Media
                   Agency                                                                                                               Ad is returned
                   Strategy                            Transaction fees
                                                                                                                                                          Page      Snow
                                                                                                                                                          about
                                                                                                                                                         Furballs
                Retainer Fees
                Research Fees
                                   So Science Diets Agency, via their trading desk, bids on inventory, ends up buying space on Nine
                                   entertainment which results in an ad being served to snow when she next visits the Yorkshire
                                   vet site.
THE
ISSUES
• AUDIENCE QUALITY
    • Few standards of measurement
    • It can be subjective
• MARTECH AND AUDIENCE BUYS
    • What adds value and what doesn’t?
    • Are marketers seeing a full market view?
    • Is it transparent?
    • Are there commissions involved?
• REAL TIME BIDDING
    • Are fees and commissions visible
    • What is the floor price
    • What assumptions are being made?           UK ISBA PwC study reviewed fifteen UK
• REMUNERATION                                   advertisers and found 300 distinct supply chains
    • Are all stages being captured              to reach 12 publishers.
    • How is value add being measured            Out of a total of 267m of ads placed online, it
    • Are rates consistent
                                                 was only possible to match the end-to-end
                                                 process for 31m.
Recommendation 2:
ADMA welcomes an assessment of the remuneration models applied by the
publisher, agency and adtech process in addressing the value that the relationships
provide to the marketer, to the advertising supply chain and to the campaign itself.
Contributing factors in a range of different campaign types will need to be
considered. ADMA can provide assistance in pulling together case studies of a
range of campaign types and on varying platform delivery success identifiers to see
if pricing models have been constructed fairly with proper weighting given to the
right elements and thereby parties delivering such elements.
IS THE CURRENT
MODEL SUSTAINABLE?
WHAT IS
REASONABLE?
Publishers
• Traditional Print publications in Australia where
  slow to invest in digital adtech
• Google and Facebook, together consumed more
  than half of all online advertising spend in
  Australia in 2018
• For every $100 spent online: Google ($47)
  Facebook ($24) Everyone else ($29)

• QUESTION: Is advertising a sustainable model for
  generating news?
THE SUSTAINABILITY
OF AGENCIES
• Traditional Media Agency models often relied on retainers and commissions and some
  lack transparency.
• Some digital models appear to have leakage and raise questions of double dipping
• Multiple tiers of creative agencies are required to deliver specialist digital assets
• Clients beginning to question multiple different fee structures.
Recommendation 3:
ADMA welcomes an assessment of the efficiency and sustainability of an advertising
economy with an expanding range of supply chains co-existing to support the
introductory of new innovative ways in which to deliver campaigns and targeted
messaging. ADMAs member base includes a range of different suppliers along this
supply chain and acknowledges that the analysis of these models will need to be careful
to ensure that any increase in transparency does not come at the expense of
competitiveness and the ability for new businesses to enter the market.
MEASUREMENT
STANDARDS
FOR
MEASUREMENT
AND
REPORTING
REPORTING
STANDARDS
This is a continually evolving space:
• Industry growth has been organic and fast
• Many systems and variations in standards and reporting
• Timing variations and methodologies create conflicts in data
• Interpretation is often in the hands of vendors and agencies
  which may be subject to bias

BUT …
• Reporting frameworks need to be fair and flexible
• Measurement metrics need relate to their source
• The future holds many unknowns, Innovation can not be
  predicted and should not be stifled
Recommendation 4:
ADMA recommends a detailed look into the possibility of standardising metrics of
measurement in reporting of campaigns so that advertisers can make a qualitative
assessment of the campaign in terms of success. This would assist both marketers and
platforms in benchmarking the relative contribution of one dataset over another in the
advertising supply chain as well being more informed about what to expect from a
campaign. Additionally, the governance underpinning the management of any reporting
data needs to comply with a minimum standard to ensure both the privacy of marketer's
data insights and the personal information and behavioural patterns of consumers that
may have contributed to targeting the campaign. ADMA can assist in gathering a
comparative dataset across industry to help better understand the extent to which future
standardisation may be able to occur.
COMPETITION:
WHAT DRIVES SUCCESS AND
ADVERTISER CHOICE?
BIG DATA IS NOT
  ALWAYS BETTER
• Data is data but how are you capturing it, reporting it,
  measuring it?
• Effectiveness is complex and requires planning
• Scale of audiences and the depth of data held does
  gives big platforms an advantage, however it is not the
  only factor driving advertiser selection.

ADMAs position on factors influencing the success of
brand marketing campaigns:
• Brand equity
• Use of a brands first party data
• Contextual targeting
• Alignment and direct buys with niche publications
                                                             There is a role to be played in educating the
• Importance of segmented targeted messaging                 market and the regulators on these factors
                                                             before making sweeping regulations
Recommendation 5 :

ADMA welcomes a market-wide audit to assess contributing factors of success to a targeted
advertising campaign with the view that an understanding and/or education of such
contributing factors to the campaign itself (separate to the supply chain provider) would better
inform advertisers on the elements to be considered for future campaigns (including but not
limited to) platform capability, brand equity, creative collateral, market targeting capabilities
and contextual significance. This will help advertisers evaluate the true value that needs to be
attributed to behavioural data and targeting via platforms of scale and improve
competitiveness in the market for all sized market participants.
BIDDING
PROCESSES
AND FLOOR
PRICES
TRANSPARENCY
CHALLENGES

• Floor price and the conditions around access are still
  determined by those holding the data.
• This creates distortion in comparing value and pricing
  between platforms.
• The Industry needs a clearer understanding of the
  methodology applied to valuing:
    • Data
    • Terms of access
    • Floor prices and changes to them
    • Practices of those bidding for data
    • Actual demand
Recommendation 6:

ADMA sees great benefit in identifying where and how the value is attributed in the
auction bidding process and what transparency and accountability measures might be
appropriate to identify that an advertisement has been served to the intended audience
as well as anything else in this process that needs to be improved to validate the value
chain and make all those involved more informed and/or responsible.
BRAND TRUST
AND DIGITAL
MARKETING
PRACTICES
TRANSPARENCY

• Personalisation assumes a level of consumer trust
• Privacy breaches erode consumer trust
• All platforms should offer control of privacy and targeting
• Marketers can build trust through:
    • relevance and variety
    • transparency,
    • respect for the individual
    • minimisation of collection and handling of PI

• ADMA members agree to adhere to our codes of practice
Recommendation 7:

ADMA believes that an evaluation of effectiveness of both regulation and processes can play a
key role in promoting fair and transparent practices in targeted digital marketing as well as
protecting individuals from harm. ADMA can assist with providing information on how
businesses have evolved to operate in this space and some of the challenges they face as
business parameters extend and global data best practices evolve. ADMA agrees that more
transparency and a better understanding of value points is good in promoting fair competition
in the supply chain.
NEXT STEPS
• The ACCC has requested information and case
  studies to further understand the industry
• It is in the interests of the industry to make sure that
  the regulators are as informed as possible and the
  industry is seen as responsible.
• ADMA has agreed to work with Members and other
  interested parties to collect anonymized case studies
  and examples to further inform and educate the
  ACCC

Any participants that are interested should contact:
Jenny.williams@ADMA.com.au
BUILDING
      A STRONGER INDUSTRY
•   ADMA Offers regulatory advice to members

•   Bespoke Workshops on regulatory topics

•   Toolkits and Webinars

OUR NEXT WEBINAR:
  Regulatory Reshaping of the Online Advertising and Marketing Sector and
  Privacy: Current Status and What’s Next

•    Marketers, advertisers, intermediaries and data: new norms for governance
     of data about users
•    The ACCC and opacity in the advertising value chain: how codes and
     reporting transparency will transform marketing
•    Digital platforms vs media publishers: Will advertisers be collateral damage?
•    Behavioural marketing: Will reform of privacy regulation reshape what can
     be done?
•    The ACCC as litigant: Trivago and Google and the future of consumer
     protection law
•    Presented by Peter Leonard, Principal, Data Synergies and Professor of
     Practice, UNSW Business School
What happens next
    IMPLICATIONS
The draft report from the ACCC is due December 2020. Likely
outcomes:
• A forced reshaping of transparency and reporting requirements
  in the advertising supply chain between marketers and
  publishers.
• Regulation which may effectively force industry to implement a
  binding code
• More intrusive regulation is now inevitable. There is the
  potential for the ACCC to impose excessive or inappropriate
  regulation.

WHAT WE CAN DO ABOUT IT:
• ADMA seeks to represent the interests of marketers and
  adtech and martech intermediaries in achieving fair value for
  money in digital targeted advertising.
• ADMA will assist the ACCC to understand the advertising value
  chain and how transparency as to value-adds could be
  improved.
QUESTIONS?

             @snoopflake
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