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ACCC bangs the drum of change: The Digital Platform Inquiry and its implications for financial services CMOs

By Danielle Stitt | Aug 21, 2019 4:57:20 PM
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With the resounding thump of a 623-page report, the Australian Competition and Consumer Commission’s (ACCC) released last month the results of its inquiry into digital platforms and ad-tech giants, with real implications for CMOs and our marketing practices.

The Digital Platforms Inquiry assessed the likes of Google and Facebook’s market power, competitive harm and privacy. The 23 recommendations offered in the report called for more transparency in how businesses and digital platforms collect and use data, compete in the industry and offer advertising. Here we summarise the top recommendations and their impact on financial services CMOs.


Lack of transparency for advertisers

The lack of transparency created by Google and Facebook’s dominance of Australia’s advertising space means businesses and advertisers are unable to determine ‘where their advertising dollar goes’ and what the ‘true value of their advertising inventory really is’. In other words, advertisers cannot be sure where their ads are placed and whether the much-promised ‘clicks’ are accurate. The ACCC has labelled current practices ‘opaque’.



Conduct an inquiry into specific AdTech services, such as programmatic and automated advertising, offered through advertising and media agencies.


If you have used programmatic advertising in the past, you may well have noticed website traffic that appears to come from ‘odd’ sources, let’s say, and also marks poorly in terms of time-on-site and bounce rates. Make sure you have tracking codes on all links you promote and assess whether the traffic from your AdTech advertising is delivering the results you really want.



Consumer and business trust in data is being undermined as AdTech organisations exploit personal information by providing users with zero-priced services and policies that are ‘long, complex, vague and difficult to navigate’. In the 2019 Deloitte Privacy Index, 65% of consumers surveyed said their level of trust in a company was essential when deciding whether to grant permissions to access personal information. This shows that maintaining consumer trust in data-driven technologies will help enable the free-flow of information, benefitting businesses and consumers alike.


Strengthen the Privacy Act.


A strengthened Privacy Act would see CMOs required to implement greater disclosures about what personal information is collected and how consumer data is used. It seems inevitable that Australia will follow the lead of the GDPR legislation introduced in Europe last year. We encourage all CMOs to review their privacy policies and make plans to incorporate privacy protection measures and disclosure.


Data Protection

As a result of increased data collection, digital platforms are able to offer ‘highly targeted audience segments to advertisers’ to assist in maximising buying opportunities. However, consumers are at high risk of experiencing discriminatory or exclusionary harm such as price discrimination (businesses setting higher prices for one group relative to another). Segmenting target audiences into demographics defined by age, gender, marital status or income has become increasingly associated with psychological profiling. The ACCC states that minimising the risk of abuse is important, especially relating to excluding audiences based on attributes such as ethnicity or religion.


A proactive investigation into anti-competitive conducts, including bias caused by advertising algorithms.


We’re likely to see a requirement that users can give consent to the use of their data, have the freedom to withdraw this consent, and to obtain a disclosure of any personal information used for targeted advertising purposes. We suggest CMOs get ahead now by modifying marketing collection mechanics, such as lead generation forms and privacy policies, and offering clients the ability to give and withdraw consent.


Disruption in Australian media and underinvestment in journalism

The growth of digital platforms has meant that online advertising has also spiked, just as commercial media businesses (particularly traditional print media) undergo a ‘significant reduction in advertising revenue’. Between 2008 and 2018, 106 local and regional newspaper titles closed, representing a 15% fall in the number of publications. News content creators are increasingly struggling to monetise their content due to tighter regulation for media companies, while digital platforms are left unregulated.


Introduce a new ACMA code to govern platform-to-business relationships and implement a harmonised media regulatory framework to ensure effective and consistent regulatory oversight and a level playing field for news media, journalism and digital platforms.



The concentration of media titles presents a real challenge for brands’ PR plans. That said, traditional media continues to be a trusted source of news and information. The opportunity is for CMOs to ensure their brand, when found on digital platforms, is seen as reputable, expert and insightful.


What next?

As with any regulatory change, it’s vital to pay attention not just to the letter of the text, but to its spirit. While the technical wording of inquiry results and recommendations are certainly worth heeding, the most resilient businesses will be those that remain one step ahead by identifying the general direction of industry sentiment, and what changes abroad are likely to spread here, and acting early. Forecasting the weather on the horizon will help take the sting out of regulatory hailstones.


If executed strategically, PR has the ability to drive revenue growth and increase ROI on your marketing costs. This = profit. In our recent webinar, BlueChip MD Carden Calder and Chief Executive Danielle Stitt explained 10 simple tips to turn your PR into a profit centre. You can download the recording now.



Topics: social media, public relations, financial services industry, fintech