Advertisers:  Entire Media Supply Chain Should Be Subject to Audience Data Guidelines

Advertisers: Entire Media Supply Chain Should Be Subject to Audience Data Guidelines

As the working group led by the Media Ratings Council continues with its initiative to fashion voluntary standards for media auditors, we at MMi wanted to further the dialogue with our clients on this initiative. We have raised questions within the working group and publicly regarding the scope of the project (media audits vs. the entire paid media ecosystem) as well as the very genesis and composition of the working group itself. As such, we hoped to learn where advertisers – and specifically our clients – stand on these issues.

In a recent client survey conducted by MMi, only 25% of respondents were aware of the media auditor guidelines working group. This is not entirely surprising, since there has been little publicity around the initiative to date, and the guidelines have not yet entered their “public comment” phase. The Association of National Advertisers has been involved in the initiative, and so some clients have learned about it through their participation in the ANA.

The vast majority of survey participants (nearly 90%) believe that any initiative to promote and ensure the responsible use of measurement data should be expended to the entire media supply chain (agencies, buying platforms, sellers) and not just to media auditors.

This makes perfect sense, given the inconsistency with which measurement data is treated throughout the media ecosystem, and is something which we have pointed out repeatedly throughout the process since the very beginning – both publicly and in feedback directly to the MRC and the working group. 

In other cases, feedback from our clients was not as closely aligned with our own position. We have argued that it is inappropriate for the subjects of media audits (i.e. media agencies and media sellers) to participate in a process establishing ground rules for auditing their own performance. However, a little more than two thirds of our client survey respondents believe that these entities should play a part in drafting the guidelines.

An overwhelming majority of client survey respondents (90%) believe that if voluntary guidelines are instituted, there should be some kind of compliance process to validate stated adherence. Just over half of respondents believe that responsibility for administration of any compliance process should fall to individual clients, while another 15% believe that this process should be administered through the Association of National Advertisers.

So, coupling “Individual Clients” and “ANA”, a full two thirds of respondents believe that any compliance should be administered by advertisers. A quarter did respond that compliance should be overseen by the Media Rating Council, but as we have argued in the past, this really would extend beyond the charter of that organization.

MMI’s advertiser clients were equally split (50/50) as to whether they would require that their audit firm comply with the voluntary guidelines regardless of the finished document, or whether that requirement would be dependent on the specifics of the eventual guidelines themselves.

There are two key takeaways from the survey. First, guidelines for responsible use of measurement data should be extended to the entire media supply chain, including agencies, third party processors, and sellers. Singling out media audit firms makes no sense, and advertisers clearly agree (90% of our survey respondents said as much). Second, advertisers are generally supportive of some kind of compliance process, but they believe that they should be responsible for administration of that process (68% of respondents said that either individual clients or the ANA should drive compliance). This compliance process, whatever it is, should be extended to the entire media ecosystem as should the guidelines.


MMi conducted an anonymous, online survey of our clients (representing many of the largest advertisers in the U.S. across categories including automotive, retail, dining, telecommunications, financial services, pharmaceutical and consumer packaged goods – with a combined Total US ad spend of more than $32 billion in 2016, according to Ad Age Data Center). Communication regarding the survey and the survey questions themselves were impartial in tone. The survey was conducted from 10/19-11/3/17, and a total of 40 individual MMi client representatives participated.


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