German competition authority draws consumer privacy conclusions for IOT.
Privacy and your TV shows privacy is everywhere.
Smart about history
Making a humdrum object exciting by prefixing the adjective ’smart’ started in the late 1960s with the inventions of the smart bomb. To smart = to hurt, the original literal meaning of sharp and cutting was starting to shift to a description of a quick, active and clever person in the 13th century.
By the late 19th Century, the exploits of Alec Hoag, the New York pimp, thief, and original ‘smart Alec’ gave smart a negative twist – being ‘too smart for your own good’.
Today, the German regulator finds that Smart TVs are too smart for their own good, and the same goes for the wider IOT category. The competition regulator believes the sector has ignored a simple fact – the GDPR requires greater customer centricity.
For PEA, the report foregrounds the importance of both privacy and television to the home. It raises two questions, how has the Smart TV ecosystem been slow to;
- Recognise products born of the “homes hearth” come with privacy baggage, which must be unpacked to prevent consequences of audience trust?
- Apply the lessons of the Smartphone. Accusations of opacity about data use and straight up surveillance have plagued the device.
New TV services need to make processing personal data an act of pride. Smart TV is too important to lead with a weak data and privacy proposition. “Water cooler” moments are about great programs and not privacy harms.
Key Takeaways
- Recognise you can’t stay hidden in a data ecosystem when every regulator is shouting about increased transparency.
- Create data and privacy propositions which align with brand expectations and give meaning to customer communications about data use.
- Look at the buying process and identify the earliest point to start the privacy conversation.
- Look at data supply chain and signal it is actively managed
- Make the Smart TV privacy experience for consent the new best practice. Set expectations prior, communicate benefits and design a choice architecture with clear choices.
IoT and Privacy is a growing problem area for OEMs and consumers. There is a competitive advantage to be gained for a forward looking brand.
”Consumers subjective perceptions will ultimately determine how information is sought and ultimately processed.
SECTOR INQUIRY SMART TV (AZ. V-22/17)BUNDESKARTELLAMT, JULY 2020
Pointing the finger
The regulator does not pull its punches in its opinion of the sector – “violations”, “detriment” or “unsatisfactory” are the descriptions of the sector poor conduct. They focus specifically on data collection technologies, such as ACR (Automatic Content Recognition), and the flows of data across the supply chain.
ACR is currently used to support platform agnostic addressable TV advertising market. Addressable advertising must be bullet proof from an audience perspective.
To the seasoned reader none of their findings seem unique to the TV sector – consumers faced with limited or no transparency and limited or no control – their suggested remedies are clear, interesting and simply put. A sign of the poor regard for “consent banners” online, the regulator makes no mention of them as a practice to emulate.
Focus Areas
The report echo’s specific points PEA has been making about the need for the tools of marketing to be used to solve privacy problems
- The data processing transparency principle must be applied earlier and across the entire buying process. Brands must communicate to shoppers as well as consumers about privacy. This means understanding how this fraught topic can be introduced as an opportunity and not a threat.
- All touchpoint and occasions must be looked as a moment of potential privacy engagement. This means weaving privacy into advertising, in store, on box and thru install.
- Messaging requires a radical overhaul – privacy policies add rather than reduce confusion if they are read at all. They may be a mandatory but need not be the only way a brand communicates bout data and privacy. And, more pictures less word.
- Get consent right by focusing on the consumer decision making. Learn from the mistakes made online and mobile. If you communicate value, you will get the “yes”
