WFA response to Adalytics report on Google Search advertising

Useful context, but industry debate continues over the prevalence and scale of the issues highlighted and WFA does not believe there is ever likely to be full consensus. Stepping aside from the details of the ongoing debate, WFA believes this highlights a need for improved media environments which are legal, safe, transparent and fit for purpose. Greater education around the environments brands feature in, and ultimately stronger governance of media campaigns, is a necessity for advertisers.

Which advertisers were affected?

No full list of potentially affected advertisers is currently available and we do not expect this to change. The Adalytics report names some US and UK advertisers, but does not claim this as a full and complete list. Note, these claims have not been independently verified.

A simple rule of thumb is that advertisers who were opted-in to the Google Search Partner Network (including Pmax) were potentially exposed, which is straightforward to check.

Considerations for advertisers:

• As first port of call, Google has provided simple steps for advertisers to check if Search Partners is enabled and how they can opt-out.
• Consider the pros and cons of utilising Google’s Search Partner Network in future campaigns through discussion with media teams and agencies.
• Longer term, as we say verbatim in the WFA Global Media Charter, advertisers should:
  • Carry out a thorough audit of your media buying: understand how many sites you’re running across, to what extent you are funding quality content, whether you are featuring on ‘made for advertising’ and misinformation sites;
  • Consider establishing direct relationships with supply partners, ensuring that ad tech providers and publishers grant access to log level, URL level data and focus on sites, networks and seller IDs to appropriately route ad placements;
  • Evolve from brand safety to more conscious media choices, with the adoption of an ‘inclusion’ mindset. Consider directing spend towards high quality and high attention placements rather than relying on ‘exclusion’ of low quality, low attention placements (noting that each brand should operate in check with its own needs);
  • Consider establishing limits for where advertiser consent is required related to inventory changes within services or contract fulfilment;
  • Consider supporting calls for greater measurement and accountability in dialogue with media agencies, ad tech providers and publishers;
  • Consider joining WFA’s Global Alliance for Responsible Media (GARM): GARM is a focal point for the brand safety conversation, though has been concentrated on social (not search) to date.

Many of these recommendations are also well made in the full results of the ANA’s extensive programmatic media supply-chain study, released December 5. There is a clear call for “more active stewardship of media investments” and a push for quality inventory (or better balancing of quality and price). We recommend that you read the report in full.

WFA is in dialogue with Adalytics and Google, and many other partners, to further investigate this issue and the potential implications for brands. WFA will continue to support brands’ efforts towards ensuring that the media environment in which their ads appear is legal, safe and fit for purpose.

Please find below the article as published on November 29:

A new report published on November 28th, based on data from Adalytics (an ‘Ad quality and transparency platform’), reveals a number of potential transparency and brand safety concerns with regards to Google Search advertising, and in particular, Google Search Partner network.

WFA’s understanding of claims from the Adalytics report include:

1. All new Google search campaigns and Google Performance Max campaigns are automatically opted into the Google Search Partner Network (a group of Google partner websites where search ads may be displayed).
2. Google does not provide transparency regarding which websites form part of the Search Partner Network, it does not provide transparency to advertisers regarding where their search ads were shown on the Partner Search Network and Google Search is not Media Rating Council (MRC) accredited for brand safety.
3. Adalytics claims that there are at least 36,612 Google Search Partner websites; of which over 2,200 were found to be potentially engaging in copyright violations or piracy, 390 appeared to be ‘potentially pornographic in nature’ and four appeared to be websites which are specifically listen on the US Treasury Office of Foreign Assets Specially Designated Nationals list (entities placed under sanctions).
4. Major brands’ search ads by Adalytics were found to be served on (and monetising) pirated, pornographic, far-right extremist websites, government-sanctioned domains and “hundreds of putative Iranian websites”.
5. Google is in violation of its own policies because under its Publisher policy, Google explicitly states that it will remove websites from its Search Partner Network if they are found to be containing content which is sexually explicit, that infringes copyright law, or violates sanctions and export controls.

Brand owners are committed to ensuring their ad spend does not inadvertently appear next to or fund illegal and harmful content online. This is why in 2019 WFA set up voluntary industry initiatives such as the Global Alliance for Responsible Media, and advertiser-led initiatives aimed at working towards preventing advertising revenues from acting as a financial incentive for the monetisation of harmful user-generated content on social media.

More to be done to provide transparency & control

The findings from the latest Adalytics report suggests that more work needs to be done to provide brands transparency and control over where their ads are placed across all digital media formats. In particular, this new report reaffirms that we need:

1. Transparency from ad sellers on the ad inventory being sold, with clear information as to whether they are opted-in by default to certain products and clear options to opt-out of these.
2. Clear disclosures on the parameters ad sellers use to decide inventory selection and how often these are reviewed. There may be a need for a clear governance model in place which ensures ad inventory adheres to ad seller policies as well as government regulation.
3. Independent verification and measurement of ad placements by an accredited third party such as the MRC so that advertisers can make more informed media buying decisions.

These steps could be considered key from an industry perspective to help advertisers identify whether the environment is legal, safe and fit for purpose for their brand, a fit with their responsibility agenda and in-step with their communication objectives.

The urgent need to address the lack of media supply chain transparency is called out in the recently published Global Media Charter. The Charter outlines an industry call for better Measurement and Accountability of audiences across media and platforms, and the tracking of spend throughout the programmatic supply-chain. We believe that these improvements may foster an environment that will promote competition and potentially lead to a more sustainable media ecosystem over time.

Safeguards for brands

From a wider industry perspective, WFA therefore notes that brands may want to consider the following to enhance transparency in media supply chains:

• Consider ensuring that contracts with media agencies, ad tech providers and publishers grant access to log level, URL level data and focus on sites, networks and seller IDs to appropriately route ad placements.
• Consider fostering an ‘inclusion’ mindset to potentially direct spend towards high quality and high attention placements rather than relying on ‘exclusion’ of low quality, low attention placements (noting that each brand should operate in check with its own needs).
• Consider establishing limits for where advertiser consent is required related to inventory changes within services or contract fulfilment.
• Consider supporting calls for greater measurement and accountability in dialogue with media agencies, ad tech providers and publishers.

This latest Adalytics report follows two others from earlier this year. The first noted that about 80% of YouTube's video-ad placements on third-party sites violated its standards. The second that YouTube is serving ads from many advertisers on channels that are labelled as “made for kids”, potentially causing them to inadvertently harvest data from millions of children. Google disputes these claims.

WFA is aware that some members are working directly with Adalytics to help them understand their level of exposure to the issues described in the various reports. This is an individual and independent decision to be taken by each advertiser.