In a recent New York Times op-ed article: Your Cells. Their Research. Your Permission? Rebecca Skloot addresses the debate on updating the Common Rule. What’s the Common Rule you ask? It’s a Federal Policy for Protection of Human Subjects. Again you ask, WHAT is the Common Rule? And what lessons can marketers heed from this groundswell in the scientific medical research community? Patience…I’ll get to that.
The policy, which was written decades ago, governs scientific research on humans, tissues and genetic material. The debate on updating the policy centers around requiring inform and consent by Americans for the use of their “clinical specimens” that as the author states “are leftovers from blood tests, biopsies, and surgeries.”
I think most of us would be in favor of scientists making use of our biospecimens to more effectively study and eradicate diseases. But with inform and consent, Americans would be made aware that their genetic material is being used, given the choice to provide consent, and provide governance around the privacy of your genetic material. The latter is incredibly important, because the downside to a practice that has tremendous upside, is the opportunity to link genetic information on a person or perhaps their family that could lead to discrimination, e.g. what if that information was exposed to insurance carriers that applied it to cultural groups in harmful ways?
As a marketer I found several parallels to the use of consumer’s personal information for marketing purposes. To be clear, as a marketer and consumer I’m in favor of brands leveraging my preferences to provide me relevant offers and services. But as consumer’s data footprint is on track to expand exponentially with the advent of the IoTs, it’s critical for brands to collect this data, and integrate it with existing data sets on customers in a privacy compliant manner.
INFORM & CONSENT
Let’s consider a few examples. Say you’ve recently bought an internet-enabled vehicle. The in-vehicle data being collected ranges from your location, your emails and calls if say you’re using Ford Sync to dictate, and even your level of energy. Often that data is being shared with several third parties, unbeknownst to you. Equally as personal, a consumer’s wearable is collecting vast amounts of potentially sensitive data on sleep habits, diet, level of fitness, and if you are a power user it extends to emails, daily schedules etc., that in the wrong hands could lead to discrimination.
Just as the collection of biospecimens offers tremendous opportunity to make groundbreaking scientific discoveries, the collection of data from wearables and internet-enabled vehicles can contribute to advancements (respectively) in health sciences and auto safety. But it’s paramount that brand’s do so in a permissible way, offering customers the opportunity to consent to how their data is being collected and used. In-fact, for both biospecimens and consumer data, individuals are often more inclined to share information on themselves if they understand how it’s being used and the increased value it will provide to them as an individual and in the case of biospecimens, for humanity.
In short, as marketers we should be actively engaging consumers in inform and consent, as it ensures we retain and strengthen brand affinity, while avoiding the increasing potential for marketing to consumers in a way that feels invasive and nefarious.
PRECISION MARKETING…while protecting anonymity
So WHAT does this have to do with consumer marketing, in particular onboarding my invaluable offline PII customer data to the digital world? Just as the advances in scientific research have ushered us into the world of precision medicine, which allows for the development of individualized treatments, the explosion of consumer data sources has ushered us into the era of precision marketing. With much opportunity comes much responsibility. In precision medicine it’s now possible to “re-identify” anonymous biospecimen samples. Something that raises a red flag in terms of personal medical data a patient never consented to having identified and integrated with known data on themselves.
The same goes for consumer marketing, marketers have the ability to match anonymous data gleaned from the digital world back to personally identifiable information on a consumer collected (and protected) in the offline world. This is a good thing when done in a privacy compliant environment, one that ensures that anonymous data matched against Personally Identifiable Information (PII) is never re-identified with an individual consumer, and used for other purposes.
As marketers the opportunity to identify and better understand our audiences has never been greater, but the risk of integrating these various data sets on customers has also never been greater. What are the risks? There are many, so begin with your foundation of data collection and integration practices. Establish strong governance around permissibility of combining data sets, as individual data sets may be permissible, but when combined can create a profile that is highly sensitive, and thus violates the consumer’s trust. Protecting consumer’s anonymity should always be top-of-mind. As Jennifer Glasgow, Acxiom’s Chief Privacy Officer Emeritus says “just because you can, doesn’t mean you should.”
TRUST & TRANSPARENCY
With the increasing call for inform and consent and the safeguarding of anonymous data in the digital sphere becoming paramount to consumers, so is the need for transparency in how this data is used. In the field of scientific medical research there is an increasing call for transparency as to how a patients tissue samples is used in study, e.g. to be applied to research of a specific disease.
The same goes for consumer marketing. Consumers are increasingly seeking accountability in how their personal data is used and for what purpose, demanding a value exchange akin to a partnership built on trust. Marketers will not retain customers or bring new ones into the fold if they violate the trust of consumers that is the bedrock of brand affinity. Consider mobile devices, where privacy concerns initially lagged due to failure of third party cookies on mobile devices.
Concerns about mobile are fast changing with the advent of unique identifiers that will raise red flags on collecting data on mobile, arguably the most personal, contextual and sensitive in nature. This should be a call to action for marketers. If you want to capitalize on the explosion of channels, devices, and technologies that offer unprecedented opportunities to know your customer, and in way that delights them, you must be vigilant in your efforts to be transparent with consumers to gain and retain the trust essential for your brand to grow and thrive.
For brands to capitalize in this new era its imperative marketers put consumer trust and choice as the core of their business strategy. Begin by developing a process for inform and consent, ensuring anonymity is protected when and where it is expected, and provide consumers the transparency they’re demanding. This will create a more fortified customer relationship built on engagement that delights without violating the privacy individual’s cherish and strive to protect.