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Why Marketers Need a Chief Data Ethics Officer Now

The advertising industry is obsessed with data – as it should be. Access to data has enabled improvements in both advertiser performance and customer experience, from targeted insights on consumer behavior and preferences online to customer journey mapping.

But at the same time, consumers and governments have become more concerned with data privacy.

A recent survey shows UK consumers are now even more aware of how their data is collected and used, which in turn can instill an apprehension about sharing their data for fear their personal details may be sold or shared without their consent. On the flip side, increased awareness also brings with it a greater understanding by consumers of the trade-off between sharing their data and receiving tailored, personalized services – one that they’re more likely to accept if they have trust in the brand.

Data access and data privacy are naturally at odds. To address the conflict, many of the big players in the industry have either reduced data collection drastically or kept the same data practices while making the minimum changes to (possibly) meet legal requirements. But somewhere in between data collection being inherently “bad” on one side of the spectrum and completely necessary (within legal limits) on the other side of the spectrum, we should be asking the question: what data collection is ethical?

With recent advances in AI, all signs suggest that technology will continue to move much faster than regulators: marketers cannot wait for governments to repair the massive breach of trust between the tech industry (including ad tech) and consumers. A sustainable way forward will place the ethics of data collection first and foremost. This has left the industry crying out for a new position –

Enter the Chief Data Ethics Officer (CDEO). 

A new social contract for data

Some data collection is obviously unethical – we all know the Cambridge Analytica story. Most data collection, however, falls into a grey area. We can (probably) all agree that data collection should be consented to, but what does consent mean and how should we ask for it?

How often, and how much information is needed to make it informed consent? Should we ask yes or no once and never again, like ATT? Or ask constantly and give consumers choices, like the persistent cookie banners that feel like a multiple-choice test?

Consumers are consenting to a “data contract”: they make their data available trusting that it will be used responsibly to benefit them. It’s time to define data ethics, putting consumers and their experience at the center.

The role of the Chief Data Ethics Officer

This role isn’t completely novel with Chief Data Ethics Officers starting to pop up more often – namely in the banking sector. But it won’t be long before other industries and businesses start taking on the role.

So, what exactly would the role of a data ethics officer look like?

At the core, their role in the business is to ensure that the organization’s use of data is conducted in an ethical and responsible manner, and to be in the consumer’s fighting corner. Duties include educating business and ‘platform’ teams on the importance of data ethics, as well as keeping an eye on emerging technologies and finding solutions for best practices with using data for good. Unlike the Data Protection Officer whose mandate is legal, the Data Ethics Officer’s mandate is ethical.

This can involve managing cookie-based data, hashed identity-based data, PII, and even large anonymous data collected by ad tech platforms and media vendors, website/app analytics and UX design, CRM, CDPs / 1st party data, 3rd party data, and data clean rooms. Beyond data collection, the role must cover data usage by the same parties and even the responsible use of AI.

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Ethics in practice

The Chief Data Ethics Officer should define their business’ approach to data across five dimensions: business impact, transparency, security, sustainability, and representation.

To legitimize the use and consumer experience of data, marketers must be more intentional and thoughtful about the data we collect; asking ourselves questions such as “Are we actually going to use this data?”, and “What’s the business case for it?”

Once there’s a clear use case for collecting the data, brands can be more transparent and specific about asking for consent from consumers and making sure they know what their data will be used for.

The more data is collected and stored the higher the risk of potential breaches which will only further compromise consumer trust and loyalty. Explaining the trade-offs enables consumers to choose and gives them back the power. Prioritise data collection that has a strong business case to significantly improve the user experience, which in turn does not then feel invasive. Instilling ethical data principles across each individual dimension facilitates a more ethical approach across the others – more thoughtful data collection can mean higher customer trust, lower security risk, and even lower carbon emissions.

Initiatives from new tools like Scope3 prove not only that sustainability is increasingly important to marketers but that marketers can actually do something about carbon emissions. Global greenhouse gas emissions from the tech sector are comparable to those of the aviation industry, with data centers accounting for 1% of the tech industry’s emissions and electricity usage, according to Cloud Carbon Footprint. While one percent may sound insignificant, in the big picture of the climate crisis, small changes can make a difference. In addition to looking at the carbon efficiency of programmatic media buying, as Scope3 does, advertisers can reduce emissions by improving their data storage and processing.

The final dimension to consider may be the most topical with the rise of AI: diverse representation. While artificial intelligence represents huge opportunities for businesses and consumers alike, one of its biggest pitfalls is that the outputs are only as good as the inputs, and a lot of data is deeply biased which can have very real consequences.

For example in healthcare, a paper from Imperial College showed that this can look like AI missing skin cancer diagnoses in ethnic minorities. The stakes may not be quite as high in marketing, but the risk must not be ignored. 

Getting started 

Step One for a new Chief Data Ethics Officer?

Data audit.

Measure and reduce carbon emissions in programmatic auctions; minimize data row usage by implementing new storage tools or processes; evaluate active 3rd party pixels or data vendors and remove those with data that’s not driving the business forward. Regular audits and conducting privacy impact assessments should further become the norm.

Having a data ethics officer in place is also a great starting point for conversations about ad tech bloat: the CDEO should inherently be asking the questions that make clear which ad tech is the real deal, and which is snake oil.

Over time, businesses should think about getting ethical guidelines and policies in place as standard practice – with the CDEO responsible for developing and maintaining a set of ethical guidelines and policies that outline how the organization should collect, store, process, and use data. These guidelines should align with legal regulations, industry standards, and the organization’s values.

Finally, we mustn’t forget the consumer who is at the heart of all this. Ultimately, a good CDEO will be responsible for ethical compliance – someone who fights battles on the consumer’s behalf fostering an atmosphere of trust in and outside the business for all data-driven decision-making.

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