Privacy and data protection are important issues for all our companies and we aim to meet best practice standards. Our companies collect consumer data via a number of traditional channels such as consumer research, direct marketing and PR but also via the growing number of digital channels. For example, some companies use consumer data to study attitudes and purchasing habits to create targeted digital and direct marketing campaigns.

Privacy is a complex issue to manage. Regulation and standard practices vary significantly between the many different markets we operate in and depending on the type of data collected. Changes in technology have significant implications for how data is collected, processed, used and stored. In many markets there is growing awareness of privacy issues and some consumers and interest groups are concerned about the collection and use of personal data for marketing purposes, including practices such as behavioural targeting and the use of social media.

Our approach to privacy is guided by four priorities: maintaining consumer trust, reducing legal and financial risks to WPP, educating our people and improving our own knowledge base, and enabling our clients to use consumer data appropriately to enhance their marketing.

Our approach

We expect our agencies to comply with all applicable privacy and data protection laws and marketing codes of practice. Many of our companies have policies and procedures covering how data (including protected types of personal data) should be handled, and some have developed their own technology and tools to improve transparency.

Our key digital marketing and research agencies have nominated senior executives to provide leadership on privacy and to work with other agencies in the Group.

Internal communication

During 2009, our internal audit function assessed privacy practices as part of its reviews of Group companies. This identified a need for more education and awareness raising on privacy issues.

We held a series of privacy road shows for employees around the Group during 2010 to improve their understanding of privacy issues and changes in regulation.

We have produced a series of briefing documents on the privacy obligations relevant to employees in different functions. These will be available on the Group intranet.

In 2011 we will be introducing a global training module for privacy to be completed by all WPP employees, building on the global training platform established in 2010 for ethics and anti-bribery.

Clients and suppliers

We communicate regularly with clients on privacy issues to explain our approach and to help them keep abreast of current thinking and best practice. We are reviewing the privacy and data protection clauses (and related IT clauses where appropriate) in our supplier and client contracts to clarify our respective roles and responsibilities and to make sure these are appropriate and consistent.

Engagement and lobbying

We collaborate with others in our industry to improve privacy standards and ensure that information is accessible to consumers. A number of our companies are members of the online Behavioural Advertising Self Regulation Coalition (BASRC) and many of our people are active participants in organisations such as the Interactive Advertising Bureau (IAB), Network Advertising Initiative (NAI) and Association of National Advertisers (ANA). John Montgomery, COO at GroupM Interaction, has been appointed chair of the 4A’s new Privacy Committee to help direct the trade association’s work in this area.

A number of countries have introduced or plan to introduce strengthened regulation on privacy and data protection that could impact the use of consumer data for marketing purposes. These include the EU, Japan, Singapore and the US. Our digital and research companies meet with regulators and participate in consultation exercises to give their views on proposed regulation. In 2010, John Montgomery testified at the Senate Commerce Committee as an expert witness on self-regulation in behavioural advertising.

Our companies are involved in efforts to find new solutions that increase transparency for consumers on how their data is obtained and used. For example, in 2010 a number of companies continued to collaborate with the Future Privacy Forum and others to enhance consumer information on privacy through use of the privacy icon in the US. This appears on adverts that are served based on behavioural data, and enables consumers to click to find out more information and/or to opt out of having behavioural data collected online.

In April 2011, the Interactive Advertising Bureau of Europe (IAB Europe) unveiled the Online Behavioural Advertising Framework. This new self-regulatory framework was developed with support from major online advertising and publishing companies, including WPP company 24/7 Real Media. It will introduce a privacy icon, similar to that used in the US. When users see the icon appearing on an online ad, they can click to learn how and why their data is being collected, and to opt out. This will give European consumers greater choice about how their data is collected, and used in online advertising.