Digital advertising for the public sector: your questions answered
The world of online advertising involves complex interactions between the user and often many different digital platforms and intermediary technology services. These collect, store and use data in order to deliver a large proportion of the adverts you see online and on social media.
At CAN, we are excited by the possibilities to have opened up through digital technology – especially for the public sector – as long as it is used for the right reasons and with the correct controls in place.
Below are some myth-busting answers to the most frequently asked questions from the people we work with as partners on our Council Advertising Network.
Contact us if you have any other queries.
Is advertising technology compatible with all council websites?
The tech we’ve developed for the Council Advertising Network is simple to install and the ads have no impact on the time it takes to load content.
All modern desktop and mobile browsers are supported by our technology which is compatible with all content management systems (CMS) we know are currently being used by local councils in the UK. (If your council is thinking about a new CMS, take a look at how our Gold Partner, Placecube, is refreshing the whole idea of how digital systems within an organisation can be built to integrate with each other instead of operating in silos.)
Does advertising on council websites detract from council business?
The digital landscape has changed. People are used to seeing ads on websites – it looks odd when they’re not there! With our advertising on council websites, there is no ‘screen takeover’, no Flash animation, and no annoying sounds. It is all in standard formats and integrates subtly.
Over 70% of those who responded to a survey of our CAN Council Advertising Network partners received no negative feedback at all from residents after introducing website ads. Over half the remaining councils had just a single complaint. None of our partners had negative feedback from more than ten residents in total.
Read more in our blog on how residents feel about ads on council websites.
Will inappropriate ads appear next to content about council services?
There are categories of adverts that we automatically block – political, adult content, gambling, alcohol, fast food and payday loans among them – and we continually monitor the ads being served to make sure they comply.
Organisations on our advertising network get to choose which advertising categories they do and don’t want to see on their website from our ‘Category Approval List’. This can be tailored to fit the priorities of any organisation: for example, for clashes with commercial or cultural concerns.
They can also choose to remove ‘programmatic’ advertising from sensitive webpages (see below). Partners can get in touch to request an ad is removed at any time.
What if council teams don’t have the resources to set up this new adtech?
With the digital landscape changing all the time, we understand that council teams can’t keep up with all the latest developments. It can be a full-time job. And that’s our job.
On average, it takes the equivalent of one day’s effort on the part of a council to start running our advertising technology on a website. CAN does the rest. A council website is a powerful asset and an attractive proposition to quality advertisers who want their brand associated with public sector values.
The Council Advertising Network can generate income for councils at no cost and no extra effort using an asset they already own.
What are the regulations that cover website advertising in the UK?
Collection, use and storage relating to the third party “cookies” that need to be served from a website in order to deliver some types of advertising are controlled by the General Data Protection Regulation (GDPR) and the Privacy and Electronic Communications Regulations (PECR or ‘E-privacy Directive’).
In addition, the industry bodies for advertising, the Interactive Advertising Bureau in Europe and the Internet Advertising Bureau in the UK (both shortened to IAB) have their own standards which members sign up to voluntarily but which there is an expectation that buyers and sellers of digital advertising follow. These are collected together in the Transparency and Consent Framework (TCF) – with IAB Europe’s TCFv2.0 in force on 15 August 2020 and the IAB UK’s Gold Standard 2.0 in force in September 2020.
They are designed to give individuals control of their online data and make sure companies who intend to collect and use it have permission from every individual before they do so.
The GDPR states that consent is required before using personal data. The definition of personal data is broad and includes IP addresses issued on a per-session basis by a user’s Internet Service Provider. Website advertising uses this IP address to determine roughly where the user is located so as not to deliver ads that are not relevant for their geographic location.
The E-privacy Directive goes further than the GDPR, requiring consent before any non-essential cookie is downloaded on the user’s browser. Cookies are used widely by internet technologies for analytics, performance, functionality and, of course, advertising.
Advertising cookies perform a range of functions, such as capping the number of ads that are delivered to a user, measuring whether the user has interacted with an ad and tracking which websites the user visited while the ad was showing.
CAN’s data consent management tool covers all these regulations. Powered by the well-used Quantcast solution, and with added tech that wraps code around all non-essential cookies, it ensures that if a user does not give explicit consent for cookies, they are withheld indefinitely. So, no non-essential cookies – and no personalised ads – are served at all.
It’s available free of charge to all UK local councils. Just contact us here for your own version and implementation instructions.
Do advertising cookies on council websites compromise data privacy?
Not if they are legitimately there, permission to serve advertising cookies is sought and any data subsequently collected is only used for the stated purpose (to deliver personalised ads). These are ads based on browsing interests plus the ‘geo-location’ data collected by a tracker that will serve ads relevant to them.
When a local council – or other local government organisation – joins the CAN network, we offer to put our consent management solution in place (see above for more detail). This ensures permission is sought from individuals before placing any non-essential cookies on their web browser. And that this data is only used by contracted advertising companies solely for the purpose of delivering ads.
How does an individual opt out of personalised advertising?
Any visitor to a website on our network can say they do not want any data stored for the purpose of delivering personalised ads.
They can opt out at the point when they first visit the website, by clicking on the option to choose how data is collected and following the instructions. In this case, they will only see non-personalised ads on that website. Or they can decide to use an ad blocker to see no advertising at all.
Does CAN sell personal data to marketing companies?
No. The advertising technology we run on council websites is there for one purpose: to sell the ad space on a website (known as ‘inventory’). Some of this ad space is sold directly (‘premium’ advertising). Some of it is sold through a bidding process (‘programmatic’ advertising). There’s more on the terms used in online advertising here.
Advertising companies CAN has contracted to sell programmatic ad space collect and use the limited data described above only for advertising. They are not permitted to sell data to companies to market users directly (if this were even possible given the limited data available) nor to prejudice users’ other online transactions like applying for insurance.
We audit the companies contracted to make sure they are complying.
Problems arise only when companies involved in this chain break a contract, and their obligations to the user, by selling data on to a third party. This is not acceptable, and the industry and regulators are working hard to stop it happening.
Could the data collected be used to exploit individual circumstances?
There is no intention to do this. In all forms of advertising, companies want to appear in front of the people most likely to buy their products or services.
Just as an advertiser will choose an ad space in a publication because of its readership and relevant editorial content, so an advertiser online will use data from cookies to target their ads to people who would be most interested.
So, a user browsing for information on a benefits webpage might be shown ads relevant for people on a budget, like for reduced cost travel or supermarket price cuts on everyday items or for a comparison website to find the best tariff on gas and electricity.
In the context of all the browsing data gathered from individuals via, say, a Google search or from any website, using a council website does not increase anyone’s risk. Council websites do not operate in a vacuum. People are unlikely to go directly and only to a council website for information.
However, in the case of the GDPR definition of “special category data”, following advice from the UK data privacy regulator, the Information Commissioner’s Office (ICO), we have removed “programmatic” advertising (where ad space is subject to a real-time bidding process) from partners’ webpages where potentially sensitive health matters are reflected in the URL. This includes mental health, alcohol dependency and other addictions, disability, and sexual health.
In addition, there are other webpages where the subject matter, although not “special category”, could be considered “sensitive” because it contains information for individuals who may be considered vulnerable.
CAN has always believed inclusivity extends to advertising so everyone is given the choice to make informed purchasing decisions (although we’ve always blocked inappropriate ads – see above).
But because of a theoretical risk that data from a visitors to a council website could be shared with third parties in ways that could disadvantage them (through the URL being passed on so an ad of interest to the user can be delivered), we mitigate the risk to councils’ reputations by also excluding programmatic ads from sensitive pages, like those with information on benefits.
These pages still show ads from quality brands that CAN sells space to directly, plus ads for council, national government and NHS campaigns and for local businesses.