New Data Ethics Compass Looks Beyond What's Simply Legal

WPP's GroupM has unveiled a Data Ethics Compass tool, developed in partnership with client Unilever, that grapples with a concept Jurassic Park's scientists never seemed to grasp. "It is around the notion of 'just because you can, doesn't mean you should,'" explained Krystal Olivieri, GroupM global svp of data strategy and partnerships, echoing a sentiment shared by GroupM North America CEO Kirk McDonald at Adweek's Outlook 2021 virtual event last week. With the increased importance of data privacy and ethics, the industry's largest holding company claims this tool helps remove subjectivity from decisions around data ethics, operationalizing and democratizing the process around such decisions. In a statement, Olivieri said the tool provided clients with "a consistent approach on how best to navigate ethical risk and prioritize and respect the privacy of people on the other side of the screen." "Creating a responsible digital ecosystem continues to be a priority for Unilever, and adding an ethical overlay for use of data in media is a key next step," said Jennifer Gardiner, Unilever senior director of media, in a statement. "Consumers are growing increasingly distrustful of advertising and lack clarity in how their data is being collected and used in profiling tactics. "Our partnership with GroupM on the launch of this much-needed tool sends a reassuring and bold signal that we must all hold ourselves, our partners and agencies to the highest standards, truly putting consumers first." Going beyond what's legal to what's right GroupM and agency Mindshare worked with Unilever as the first client engagement for the tool, spending the past four to five months fine-tuning individual aspects of the tool and where it should fit in the process, Olivieri explained. The tool addresses ethical uses beyond the bounds of the law, grappling with questions of when legal use of data could still spark ethical questions or privacy concerns from the consumer's perspective. When WPP introduced its data ethics standards about a year and a half ago, the holding company included guidance for the rollout of data privacy programs. A little over a year ago, according to Olivieri, when WPP embarked on one such program focused on privacy by design and governance across given markets, questions kept arising outside of what was and wasn't legal use of data. "As we started to explore these different areas, we would notice that the questions that we were having coming in from the markets and our teams more and more were falling under that bucket of this ethical gray space, where it was less a legal issue by itself and more around the standards and the ways we wanted to operate as a business and what we were comfortable with from a consumer’s perspective," Olivieri said. So Olivieri and GroupM general counsel Nicola McCormick decided to get to work writing a set of principles, a process which ultimately proved much more complex than anticipated. One system for 35,000 users "There had to be a way where we were going to be able give our teams this tangible guidance so that across our 35,000 people globally, there was a consistent way of thinking about data ethics that didn’t always come back to a central group of a couple of people making a decision," Olivieri said. GroupM put together a group of people from across the organization to address individual variables across four key areas: the client sector, the data source, the data type and the case use of the data. "As we went through the process, we realized that what we were building was a capability or tool that could be democratized across the business and remove some of the subjectivity from our own team's perspectives as it pertained to GroupM's best practice," Olivieri explained. Rather than a binary answer on data ethics, the tool weighted each of the key areas to provide guidance and a democratized approach, allowing for more meaningful conversations with clients. "When we think about where this tool sits in the process, we think about compliance and governance as … the most important foundation you can have in any data strategy," Olivieri said, built on by considerations around data quality—whether it's the right data set for the situation. "Data ethics sits on top of that," she added. "It is the summation of, from a consumer’s perspective, would they think that this tactic deployed was creepy, or cool if they understood how it came about that they were served that ad?" Olivieri said that while primarily a tool to be used across GroupM agencies, the long-term goal is to democratize the process so that it can be used by anyone across the WPP network. Data use is top of mind The Data Ethics Compass launches amid heightened awareness around data ethics issues in advertising and marketing. IPG CEO Philippe Krakowsky also touched on the importance of data ethics in an Adweek Outlook 2021 panel last week, something he said the holding company is addressing in a number of ways. In a World Federation of Advertisers survey last year, 74% of CMOs said they believe data ethics will be more important to their roles in the next five years. While these questions are largely concerned with ethical dilemmas around the use data in established legal contexts, new revelations have also emerged around past illegal use of data. Last week, Epsilon agreed to a $150 million Department of Justice settlement for selling information that facilitated elder fraud.

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New Data Ethics Compass Looks Beyond What's Simply Legal

GroupM and Mindshare partnered with Unilever to take consumer perspective on data privacy

Erik Oster

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Erik Oster