A case in point is that there seems to be a general industry trend towards first party permissioning. This is not great news for lifestyle data owners or for the programmatic aspect of digital marketing, which it seems may no longer be permissible. If this is the case the implications are huge.
Many thought the ePrivacy Regulation might provide greater clarity on the issue, yet with the EU’s recent decision to put the legislation on the backburner, it really is back to square one.
It is likely that it has been mothballed because there are too many thorny issues and in its current format it would have been rejected. And so it is anyone’s guess when it may get picked up again. As a result, in the short term, none of us are any the wiser on whether programmatic is legal or not.
There is also significant industry change afoot. Over the next 12 months, I believe the way in which data services are supplied will change. It is becoming increasingly hard, as a result of GDPR’s data minimisation principle, and in terms of the commercial risk and reward, for data owners to justify sending out files of, in some cases, almost 100 million suppression records to numerous resellers.
The fact that, under the Pareto Principle, many of these will return very little royalty revenue is also a key consideration. Consequently, the likelihood is that we will see consolidation. Major suppression files are likely to be provided to a few selected providers of software and bureau services and the three major credit reference agencies.
Several data owners have already embarked on this route, however, resellers often have legacy systems which rely on importing the suppression files, so this transition is actually more difficult to make than it might at first appear.
There is also push-back from resellers to contend with, based on their loss of control, including being forced to use third-party systems and matching routines. This is almost a given, although it is more likely to be a slow process as opposed to the desired few months.
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