Gathering audience data once third-party cookies are blocked

Internet browsers are moving away from cookie support, which will end cookie-based targeting

Key points:

• Firefox and Safari already block third-party cookies, with Chrome set to follow before December 2021
• Cookie-based targeting solutions will become obsolete
• Advertisers and agencies will need to innovate to be able to drive effective targeting and audience building

Following the introduction of the European General Data Protection Regulation (GDPR) in May 2018, it has become increasingly hard for asset managers to gather audience data via third-party cookies when they target in the EU. Since the implementation of the ePrivacy Directive back in 2002 it has been incumbent on website owners to obtain consent for the cookies they use. However, the ePrivacy Directive was implemented differently across Europe and a general reliance on a form of implied consent via a cookie banner became the norm. Now it is clear that a more stringent GDPR-level consent is required and companies risk fines and/or claims if they do not comply, although many website owners seem very slow to adjust their policies and platforms, let alone innovate. You might know that internet browsers are moving away from cookie support, resulting in an end to cookie-based targeting. However, no alternative has been confirmed, which makes the future uncertain for many. It is expected that as new targeting solutions are being developed and rolled out, the privacy authorities will critically follow the developments and closely monitor which solutions fall foul of the rules, resulting in continual disruption for some and risk in the absence of consent. We firmly believe that privacy regulation is in the interest of advertisers and the consumer.

Third-party cookies blocked

The GDPR sets out seven principles for the lawful processing of personal data. One of those principles is that you must process personal data lawfully. Since implementation of the GDPR, a number of regulators across Europe have updated their guidance. For example, during the summer of 2019, the Information Commissioner's Office in the UK made it clear that the processing of online identifiers, obtained via cookies or similar technologies, could only lawfully be processed with GDPR-level consent. Firefox and Safari, accounting for approximately 30% of all web traffic, already automatically block third-party cookies. In January 2020, Chrome announced it will do the same within two years. This means that in all likelihood by December 2021 at the latest around 90% of all traffic will block third-party cookies. At the moment, we see roughly three models being utilised to inform users of cookies of which the first one is certainly more in line with the UK and EU regulators' interpretation of the rules. These are:

• Opt in: the visitor is asked to expressly confirm their choices regarding use of their data via a dashboard which stores and is capable of updating their preferences
• Opt out: the visitor is presented with information about the privacy policy and offered an ‘opt out’
• Basic cookie information is presented without an opt in or opt out

Until GDPR was implemented, it had become common practice across much of Europe to obtain consent by using a cookie banner to say 'we use cookies' and for the user having to opt-out. However, since the implementation of GDPR, most regulators across Europe confirmed that, amongst other requirements, express opt-in consent is required. In addition, no cookie should be dropped until consent is confirmed and the users should find it as easy to withdraw that consent as to provide it.

Implementation in the mid term

With internet browsers moving away from cookie support, any cookie-based targeting solution, regardless of having consent, will become obsolete or so restrictive that an alternative solution must be found. Until such time, there are still some options for cookie-based targeting solutions. At Fundamental Media, data is processed in line with our proprietary rules to ensure critical mass so that no users can be directly identified. Meanwhile, data that passes is scrutinised in real-time and users are categorised into 'investor-interest' groups. Audiences are integrated into our programmatic buying technology and into our proprietary reporting system, Digital Intelligence. Audience Alpha, our targeting technology, provides unique asset management audience taxonomy granularity, including by investor type, asset class, geo focus, strategy and propensity to buy. We deliver increased visibility of unknown users, through syndicated, anonymised client targeting and analytics. We are therefore making further improvements to Audience Alpha to create a future-proof targeting solution with minimal impact to future industry changes.

Our future vision

We believe that the future of marketing is outcome-oriented. Fund managers are under enormous pressure to showcase their added value. This is true for active as well as passive managers. A significant part of that pressure stems from new regulation like MIFID II. Fund managers are being challenged about their integrity and their ability to consistently deliver risk-adjusted return, and C-level executives demand measurable results from their portfolio management, sales and marketing professionals.

Our strategy for outcome-oriented marketing is to drive four distinct areas of impact to identify, reach, engage, nurture and convert, and to carry out continuous analysis and optimisation. These four areas are:

• Site design: reducing friction and improving visitor retention
• Analytics & audience management: creating cohorts via taxonomies
• Content creation: research, thought leadership, insights, blogs, interviews, etc
• Promotional activities: advertising and content promotion including social, search, etc

We believe in joining up proven traditional media tools with data and tech-driven proprietary solutions to drive outcome-oriented marketing and optimisation. Finally, we design our solutions to:

• Identify and engage investor audiences;
• Nurture and retarget opportunities;
• Optimise the outcome of campaigns;

• With privacy at the heart of our solutions.

The content of this article should not be construed as legal advice. Independent or internal advice should be sought where required.

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