The Ad Transparency Triple-Decker

15th Apr 2019 | Share:

Over the past couple of years, we’ve written and contributed to thinking about increasing political ad transparency, from a self-regulatory and regulatory perspective, but also from a technical perspective, where a precise description of what can help voters read and interpret political advertising is now significantly clearer.

Gradually, in response to negative media coverage and public pressure on these issues, Facebook has launched new transparency tools and verification processes. Other companies have promised and/or partially delivered similar programmes. We’re not there yet, but the norm has moved from no transparency to some transparency, and those of us who wish to monitor paid political material online and hold it accountable have an easier job of it as a result.

However, transparency as it stands is insufficient as a global response. Different conditions demand different solutions, so we therefore propose two further layers transparency, one radically transparent, the other almost opaque, to sit alongside the existing, emerging transparency we see today. The two layers we outline below are new, and serve to fix weaknesses in the ideas defined by the companies so far.

The first layer offers almost no transparency at all. In fact, it’s almost the opposite – near total anonymity. A small and vulnerable group of advertisers should be the only ones who qualify for this protection, on the basis of the likelihood of their freedom of expression being curtailed by transparency requirements. It might apply to campaigners in repressive regimes or from marginalised groups. It should offer these organisations protection from the prying eyes of the state, or the intimidation of an attacking group. It should be managed by an independent body, capable of making the decision to permit anonymity in a balanced, risk-sensitive and judicious way. They should make sure it isn’t abused or misused. All platforms above a certain size could contribute a small sum to the operation of this body, but would hold no role in its decision making.

The second layer is the ‘normal’ transparency we see emerging today. This should be required of almost all political advertisers who don’t qualify for the first category. This ‘normal’ transparency should allow voters to fully understand the political advertising targeted at them, and include storing ads in a public database. It should include basic disclosure about an advertiser, some active contact details and a sense of why you saw an ad, and the ads that others saw. Facebook’s current advertising transparency policies are close to, but below this level. Other platforms have work to do.

The third layer is an ‘enhanced’ level of transparency for political advertisers to participate in. It would be useful for candidates and parties running in election campaigns because it clearly distinguishes your activities from those of less trustworthy and transparent organisations. It exposes a large quantity of information about the ads and campaign you’re running, allowing for greater scrutiny and accountability. This would include detailed information about the organisation, content, placement, targeting, use of data for targeting (e.g. in Custom Audiences) and spending.

In return for this scrutiny, it could confer direct benefits, for example discounted or flat-rate political advertising. It might allow advertisers to work directly with platforms to optimise the performance of their programmes. It would likely label participating advertisers as being highly transparent and trustworthy. The larger (and therefore the more meaningful) a political advertiser you are, the more likely you are to get some benefit from participation. For a platform, the benefit would be pushing accountability onto these newly transparent advertisers and playing a fairer and more balanced role in campaigns (i.e. reducing the strength of the charge that the platforms’ ad auctions favour big spending on outrageous claims) and helping this material become a better understood and more trusted part of modern political campaigns.

This ‘transparency triple-decker’ approach is more subtle than the policies hereto introduced by the platforms, allowing for political advertising to exist, while respecting the risks and benefits it can bring to campaigners.

As always, please get in touch if you have comments, challenges and ideas about this or other proposals.

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