Bloomberg published a thorough article today on Secret Google/MA Deal and how the data is used in attribution (I wrote about this in May of 2017 Payment Data and Google Attribution). Attribution is big business. Most marketers still grapple with the old adage “Half the money I spend on advertising is wasted; the trouble is, I don’t know which half.”. Accurately closing the loop between advertising and incremental sales allows marketers to know what is working and what is not.  As outlined in Bloomberg,

“Beforehand, the company received $5.70 in revenue for every dollar spent on marketing in the ad campaign with Google, according to an iProspect analysis. With the new transaction feature, the return nearly doubled to $10.60”.

The GREAT news is that cards are an instrumental part of helping retailers improve the marketing! The bad news:  inconsistent controls, “leakage” of payment data, concerns over consumer privacy and the raw “power” google and FB have in gaining further “data advantage” over everyone else.  

Summary

• Attribution and “closing the loop” is a strategic priority for Goog/FB because when you know what’s working, you can optimize spend and double marketing ROI. We have seen the same thing at Commerce Signals as we measure the sales impact of client ads outside of the walled gardens. The economic value created is a tremendous opportunity for banks here.
• Google has “access” to 70% of US transaction data through Mastercard, 1-2 participating processors, a bank data aggregator, and retailers sending data to Google directly (last week’s blog).  However, there are substantial issues with granting Google/FB ad hoc access to payment data. While there are no doubt agreements associated with access and use, the data owner has given up control and thus placed themselves at unnecssary risk.
• Commerce Signals provides this same closing the loop service in a way that allows the data owner to maintain full control and protects re-identifcation of private consumer financial information.
• Trust is the core of both banking and marketing. All parties should be able to report on WHO is using their data and HOW they are using it. This requires transparency (and auditability).
• Building great consumer experiences take collaboration. Collaboration will be the center of all future payment networks (ex Alipay). Commercial networks are transforming – a process which will unlock $2T in value.  (Small Wins and Transformation of Commercial Networks)
• Data has been called the “new oil”, I would posit that it is the “new uranium”. While great power can be unleashed by refining it, you must control how it is disseminated and used… or it will everyone will be at risk

Transparency and the 3 Rules of Data

There are 3 basic rules to consider for any party participating in a data exchange

1. Right to have the data
2. Right to use the data
3. Right to share the data

Transparency is critical to creating trust and enabling data. To be clear we have no relationship or business with either Google or Mastercard and I have no knowledge of the precise architecture, my educated guess on the structure is below a purely “hypothetical” design based upon experience.

Mastercard sees transaction data, but has no consumer information tied to it. In other words they only have the Primary Account Number (PAN) and no nothing else about you. Within 4 party networks only issuers have consumer information. V/MA schemes are designed to protect consumer anonymity through to the POS. However, there are agents that can map a consumer to a PAN, either through seeing things like online transactions (where you put your name and PAN to order goods), credit card bureaus, …etc. These entities can help holders of PANs map to an anonymized ID.  These anonymized IDs in payments are also held by advertisers. Each party has a “unique” anonymized ID and can’t coordinate with each other without the “key pair translator”

DATA “COLLABORATION” WITH WALLED GARDENS

Google and FB. The issues in making payment data work with Google and FB are the data rules set by Google and FB: they do not let data leave their control (ex media exposure files).  Thus data must go INTO GOOGLE. The 3-4 yrs of delay in MA/Google operation would likely be surrounding where the Google Data and MA data would collectively reside. Google is in a place to financially take risk on this, and my guess is that payment partners (like MA) have agreed to a “white room” where their payment data resides which can be accessed in a controlled/structured manner by Google.

Consumer information leaving Mastercard:  Contractually none as they probably maintain “ownership” of the neutral white room (perhaps a separate legal entity). There are also likely controls placed upon the structure of analysis (example cohorts must be greater than 50 matched consumer records) within an operating agreement.

Issues: Google has ad hoc access to payment data within a set of rules. My rule #3 (right to “share” the data) may be broken here as permissions must be granted by either:  the consumer, merchant, or issuer (depending on data).  Standard questions anyone should ask on this architecture:

• Who created the operating agreement?
• Who granted the permissions?
• Who is managing the controls?
• What auditability is granted to the impacted parties?
• Who bears the risk of breach?

Banks and Merchants (the advertisers) must be able to clearly communicate: who used their data for what purpose? For example, while there may be aggregated data controls, what if Google asked the same question for a group of 50 buyers of Joe’s sporting goods, and then changed the cohort by 1 person (Tom). They would know what I bought during the time period.

Federated Data = Controlled Use

At Commerce Signals we do not have any payment data inhouse. We recognized that for data to be controlled it must stay within the premises of the owner, it can only be released if you understand both WHO is requesting the data and HOW it will be used. All data exchanges are tracked and operate within defined terms and agreements. If agreements stop, so does the data flow.  We ask our financial partners a question that like this:

For this group of 1M consumers. What was the total spend of this group during the period before the advertisement and what was the total spend of this group during the media period

Consumer level information leaving financial partner: None. Just the aggregate spend of the group of the 1M. As a neutral party we hold no consumer level payment data, or ad exposure data. We provide all parties with transparent view of both USE and permissions. The only way to make TRUST operaterative in networks is to have a neutral party.

In our Joe’s sporting goods example (above), Commerce Signals monitors ID velocity, and takes actions based upon the direction of the data owner. We work as  the neutral traffic cop that enforces rules of all parties. We enable quality data to play with transparency. For example, we recognize that ID partners must be able to have clarity into how their information was used (example PAN to ID mapping). While ID agents may permission a mapping for the purpose of aggregate measurement, they may choose to defer on others. Enabling ID partners to permission use improves the market for deterministic ID providers (vs probabilistic). Tracking use also allows Commerce Signals to manage opt outs across multiple partners and ID providers consistently.

Data has been called the “new oil”. I would say it is rather the “new uranium”. While great power can be unleashed by refining it, you must control how it is disseminated and used… or everyone will be at risk. This is our business at Commerce Signals.

Industry recommendations:

• Quality data can only play where there is transparency and control.
• Retailers should view measurement and optimization as a core IN HOUSE responsibility. Card Networks and merchant processors are great partners to accomplish this with no work on your side. You can enable the same optimization described in the Bloomberg article across all of your marketing.
• Google and FB must recognize that payment data is of greater sensitivity than ad exposure data. While 3rd party data partners have been curtailed, 1st party data is greatly accelerating. I believe consumers will be shocked to find out that their real time purchase information is made available to Google and FB. While there is an immediate media effectiveness impact in turning this on, there are better ways to accomplish it.   
• Retailers should recognize the double edge sword of data sharing with Google. While it does improve marketing results, and they can write very big checks, it also leaks consumer preferences. 
• We are at a Data Tipping Point (blog) where all parties must be accountable for HOW data plays with WHOM for WHAT use.  Create a mission control for all of your data interactions. Who is using your data today?  It is your data, and it must operate under your rules (more here)
• Banks… must work to ensure transparency of data use, and that the actors participating abide by the rules (see my Bank Recommendations)