TotallyAwesome’s chief operations officer and youth safety advocate, Marcus Herrmann, explores the new Privacy Act Review.
The Australian Privacy Act Review has moved to the next stage, with revisions drafted and one last consultation in place before it moves to the legislator. It has received mixed reviews from marketers with conflicting voices about how much or how little it may affect current targeting approaches.
One area that has been broadly overlooked by marketers is how the proposed amendments will affect advertising to the under 18 audience. The key changes in relation to this demographic are that profile targeting will no longer be possible, leaving contextual advertising as the only option.
At first glance, marketers might assume that it does not affect them. After all, most brands and agencies who engage with a youth audience already use contextual targeting for this demographic. However, failing to take real notice of the detail within the changes could have consequences.
With that in mind, here are the four questions that every brand who wants to reach an under 18 audience needs to be asking the organisation as well as media partners and digital agencies.
Are you using any third-party tags or attribution models?
Even with contextual targeting, ads can still have ad verification tags on them. These tags can collect personal information like device IDs and locations to ascertain its human vs. bot traffic. As a result, you might be in breach of the proposed rules. The same goes for attribution models or retargeting tactics which also use device IDs and are likely to become a hard no.
Are you using programmatic media buys?
Programmatic is great for reaching audiences at scale. Most programmatic platforms, however, pass on personal information in the bid request. If you are using it to reach the under-18 demographic then it is time to rethink. At Totally Awesome, we invented the world’s first programmatic platform that uses zero personal data – so scale is still possible but you need to choose your partners carefully.
What creative formats are you using?
VPAID and MRAID creative formats potentially read personal data from the device. This may steer you into compliance choppy waters and leave you in breach of the proposed regulations. I’d suggest making sure you choose a creative agency that has experience in creating compliant and safe ad units or if you’re doing it in-house, use clean and safe formats like VAST videos.
Do you regularly run competitions for your brand?
Competitions aimed at Under 18s will still be possible but will need a robust mechanism in place to get verifiable guardian consent for their kids to sign up and submit their names and contact details. Moving forward you will need a mechanism in place that contacts guardians and verifies their identity to then ensure they grant consent to the collection of their kids’ personal data.
Our Youth Matter
While the proposed changes to the Privacy Act may mean adjustments to your current media strategy, it is good news for our industry and our youth.
It doesn’t mean brands should not be marketing to Under 18s. What it does mean is rethinking the approach to how you market to this audience. It means finding ways to build meaningful connections with a Gen Z and Gen Alpha audience that shape future behaviours and long-term loyalty.
The key is doing it responsibly and, in a brand safe manner.
Our company was set up with the founding principle of using zero data for marketing to a youth audience so we know it’s both possible and highly effective, as well as the right thing to do.
I am excited for what the proposed changes mean for the youth of Australia and how, as marketers, we can show up in the best way for this audience.