Welcome to the Fall 2018 Edition of Harte Hanks Quarterly.
The zeitgeist of the marketing world is data privacy and usage. Whether it’s the advent of General Data Protection Regulation (GDPR) in Europe, the Facebook breaches or the recent legislation in California and Vermont, we are surrounded by the topic and its implications. It strikes me though that, despite historical evidence that demonstrates how legislation develops in the wake of unanswered consumer concerns, the conversations have not gone deep enough yet to catalyze the right changes in our marketing practices. Unless we as marketers drive these conversations forward and to the required depths, we may lose control of how we can use data to drive our marketing.
We are all certainly focused on the legal and ethical components of data usage. Whether it’s buried in our terms of usage or legislated, we tend to have a clear understanding of what we can and can’t do within legal limits. The ethical conversation is a newer one still being shaped. It differentiates between what we can do legally within the four corners of the law and what we should do in the protection of an individual’s or an entity’s data. There is no doubt that these are important conversations that need to continue.
The emerging question that I don’t hear discussed often enough is the following: what did the customer or entity intend for us to do with his or her data? I believe it strikes at the heart of our perception and understanding of the data we use. We need to fully accept that the data we hold on any individual or entity does not belong to us—it is theirs.
Emerging rights to be forgotten around the world make that eminently clear. These rights tell us that an entity’s data is entirely their possession, and it is not sufficient to simply restrict our use of the data; in some cases, we are not even entitled to know about or possess the data without notifying them and giving them the opportunity to object. In a world where the ownership of data is now completely flipped on its head from what we’re accustomed to, we now need to hold ourselves to a radically higher standard of data stewardship.
The data we have is gifted to us by its actual owner, to be used on their behalf as they intend, not as we want. That might require a reread—it’s their data, not ours, and our job as marketers is to use it as they want us to. By that standard, I’d assert that most of us are badly failing today. It might not be too dramatic to say that we are risking the future of personalization and data-driven marketing. GDPR has already started this calamity with the “right to be forgotten” and the obligations to obtain consent; a member of our advisory board recently prognosticated that GDPR had the potential to put marketing in Europe into the dark ages. The tide of global mandates of offering individuals complete transparency into the use of their data across its lifecycle and control over how it is used internally and for advertising and marketing has arrived. From GDPR to California and Vermont, we are facing the prospect of not having the data we need to market effectively—or maybe the even crazier prospect that we would have to pay the rightful owners of the data, the people or individuals, for the right to use it.
It might not be too late. We as an industry might still be able to prove that we are capable of being good stewards of the data we’re entrusted with and that we can use it in a way that benefits its owners and still helps us get the job of marketing done. It will mean big thinking and big changes. The opportunity is in front of us to act or to be acted upon. What will we do?
Frank M. Grillo
CMO, Harte Hanks