An Introduction to PRAM

September 15, 2020    

Representatives of the ANA and Venable discussed the Partnership for Responsible Addressable Media (PRAM), which was launched in August 2020 as a collaborative effort of the leading advertising trade associations and companies representing every sector of the global advertising industry.

N

ew solutions and approaches are necessary to fuel the next generation of addressable media. Apple and Google (which control more than 90 percent of mobile app traffic and more than 80 percent of browser traffic) are removing advertising identifiers which attribute ad spend. Safari blocks cookies by default, with Chrome to follow suit in 2022. Apple's identifier for advertisers (IDFA), used for tracking and identifying a user without revealing personal information, will require an opt-in in January 2021.

The situation has required an industry response to create new solutions to drive growth and continued transformation. This response is all the more necessary as recent privacy-based policy changes are leading to a constriction of marketing and advertising use cases and the ad-supported publishing ecosystem. This challenge will be exacerbated for other mediums (voice, CTV, digital out-of-home advertising, etc). Without uniform standards, severe complexity is likely, with different addressability models for marketing across each browser and device and in each country and region.

To address this concerning issue, the Partnership for Responsible Addressable Media (PRAM) was established to develop principles, standards, and guidelines that will safely and effectively address today's changing global media landscape. This cross-functional consortium represents all voices in the advertising and marketing industry, including marketers and agencies, martech and adtech companies, publishers and platforms, and trade, policy, and legal associations.

The launch of the PRAM partnership in August 2020 received publicity in more than 20 media outlets, including such publications as The Wall Street Journal, The New York Times, Adweek, Ad Age, and AdExchanger. The coverage was positive and focused on how the major industry players are all collaborating in this effort.

The PRAM's goal is to ensure consumers and businesses can continue to connect responsibly and enjoy the benefits of the digital economy in a safe and effective cross-media environment where privacy is fundamental.

Its mission is to develop privacy-preserving principles, standards, and infrastructure for addressable communications that:

• Safely leverage data to improve campaign optimization and attribution.
• Increase transparency among partners.
• Support funding for content and services.
• Operate across channels.

The PRAM released a draft of six initial principles that will guide its work.

1. Consumer privacy should be a foundational pillar of the solution by providing consumers with meaningful transparency and controls, giving the marketplace the tools to understand consumer preferences and the ability to abide by those preferences.
2. Consumers should have access to diverse and competitive content offerings, supported by their choices to engage with digital advertising in exchange for content and services.
3. Business operations, including ad targeting, ad delivery, frequency capping, campaign management, analytics, cross-channel deployment, optimization, and attribution should be sufficiently supported and improved upon through better technological and policy standards for all critical use cases.
4. Solutions should be standardized and interoperable for consumers and businesses across browsers, devices, and platforms, subject to applicable privacy laws and guidelines and to the extent that it is reasonably technically feasible, efficient, and effective and that it marks an improvement over existing technology.
5. All browsers, devices, and platforms should allow equal access, free from unreasonable interference, to the new solutions.
6. Companies that utilize the resulting solutions should follow industry and legal privacy standards, with strong accountability and enforcement for those that violate the standards.

The PRAM's Composition

Governing Body
Bob Liodice — Association of National Advertisers (ANA)
Randall Rothenberg — Interactive Advertising Bureau (IAB)
Marla Kaplowitz — 4A's
Catherine Armitage — World Federation of Advertisers (WFA)
Leigh Freund — Network Advertising Initiative (NAI)
Michelle Peluso — IBM
Raja Rajamannar — Mastercard
Joe Mazeika — General Motors
Matt Van Dyke — Ford
Gerry D'Angelo — Procter & Gamble (P&G)
Luis Di Como — Unilever
Joe Zawadzki — Media Math
Dave Pickles — Trade Desk
Anneka Gupta — LiveRamp
Eileen Kiernan — IPG Media
Helen Lin — Publicis Media
Alisa Bergman — Adobe
Krishan Bhatia — NBCUniversal (NBCU)

Management
Bill Tucker — Group EVP, ANA/Executive Director, The PRAM
Michael Donnelly — MD Lighthouse Labs LLC
Dennis Buchheim — President, IAB Tech Lab
Stu Ingis — Chairman, Venable LLC
Andrew Weinstein — CEO, Ridge Back Communications

Working groups comprised of approximately 100 participants, address:

• Business practices
• Technical standards
• Privacy, policy, and legal considerations
• Communications and education

Two immediate priorities of PRAM are:

1) Apple Engagement

• Clarify the IDFA policy and discuss impacts to marketer/app/publisher use cases.
• Present a unified industry position.
• Secure Apple's participation in future partnership initiatives.

2) Activate the Working Groups to deliver industry principles, standards, and guidelines

• Deliver IDFA policy.
• Promote third-party cookie deprecation (a phasing out of third-party cookies).

With regard to Apple's IDFA policy, PRAM is deeply concerned about the following issues:

• What mechanism, if any, can advertisers use in the future to cap the frequency of their ads, so users don't face a blizzard of the same repeating ads?
• Can apps that depend on advertising revenue require IDFA activation from their users or will they be forced to shut down and/or limit their distribution to non-Apple devices?
• If privacy is the reason for the change, why can't the IDFA be used for non-targeting purposes, such as campaign measurement, attribution, and ad fraud detection?
• What other privacy-protective systems or tools can a marketer use in the future to reach groups of users with common interests on Apple devices?
• Will Apple require an opt-in with the same language before it collects any user information for its own marketing purposes?

Working Groups

The Working Groups are setting out to deliver their work through a three-step process.

Step 1: Curate, challenge, and align: Each group meets regularly to create a draft.

Step 2: Extend, improve, and enhance: The draft is shared with the broader industry community for additions, edits, and improvements.

Step 3: Publish and iterate: Documents are published and updated quarterly or as needed.

Business Practices Working Group (BP WG)
Consumer-focused, privacy-conscious, and globally represented, the BP WG will assemble a comprehensive compendium of addressable media business use cases to guide the other working groups in the creation of principles and solutions.

Co-chairs and approximately 50 participants (marketers, agencies, publishers, and data and technology partners) will meet for several hours four times in the next 12 weeks.

They will form teams focused on specific industry use cases such as media channel planning investment and optimization (audience building, targeting/retargeting, analytics) and campaign analysis (measurement, attribution).

Privacy, Policy and Legal Working Group (PPL WG)
This group will advise on privacy, legal, policy, and other related areas relevant to developing new standards for addressable communications across the internet ecosystem. The PPL WG will identify and recommend data privacy, security, and accountability uses and functionalities to be supported by the new addressability solutions. The group will identify areas where the use of solutions for addressability through this effort can address privacy considerations. The PPL WG will also engage in various channels including legislative and self-regulatory to ensure new addressability solutions are permitted.

Participants in the PPL WG will include privacy, government affairs, and legal professionals from participating organizations.

Technical Standards Working Groups (TS WGs)
Informed by business and policy stakeholders, these groups — comprised of IAB Tech Lab's Accountability Working Group and Addressability Working Group and the recently-formed Tech Lab Privacy and Rearc Commit Group — will define:

• Standards for a range of addressability solutions to be applied to prioritized business use cases
• Accountability programs and mechanisms to ensure adherence to privacy considerations and addressability standards

Communications and Education Working Group (CE WG)
Collaborating with the other Working Groups, the CE WG will manage the PRAM's unified narrative and provide learning materials to help brands understand the challenging landscape, enabling them to efficiently optimize their use of data before, during, and after the evolution that is taking place.

Participants in the CE WG will include:

• Trade group communication teams
• Marketers and agencies
• Measurement partners, martech partners, and adtech partners
• Curriculum and adult learning platform partners

The following is a timeline for the PRAM's work throughout the remainder of 2020 and into 2021.

Q3 and Q4 2020: Initiate and Activate

• Launch and form Working Groups.
• Begin cross-functional working sessions.
• Broadly share early work for additional input and feedback.
• Publish Use Case Compendium.
• Review and discuss technical standards proposals and draft guidance.
• Finalize accountability program and technical mechanisms design.

Q1 and Early Q2 2021: Develop and Deploy

• Create principles, policy, and standards recommendations in support of use cases.
• Finalize and deploy standards and accountability program.

Q2 and Early Q3 2021: Launch and Transition

• Begin phased implementation and adoption.

Q4 2021: Iterate and Scale

• Communicate with and educate the advertising and marketing community on the PRAM's initiatives.
• Refine standards, practices, and programs based on learnings and ongoing changes to browser and operating system platforms and privacy laws and regulations.

Source

"An Introduction to PRAM." Bill Tucker, Group Executive Vice President at ANA; Stuart P. Ingis, Partner and Chairman at Venable LLP. ANA 1-Day Conference, Law and Public Policy, 9/15/20.