Study: Data ethics is a priority for CMOs but half don't know what that truly means

CMOs are keen to address consumer and regulatory concerns around data-driven marketing. However, the complexity of the data and digital ecosystem are making it hard for them to identify the right practical measures to take, said a new WFA research titled "The CMO guide to data ethics and practice."

The vast majority of CMOs (92%) at multinational companies are prioritising an ethical approach to their use of data but half (50%) do not know what this means when it comes to the processes and practices they need to apply both internally and across their marketing supply chains. While 60% says data ethics is a top priority, many are held back by the associated costs (25%) and the need for requirements such as recruiting new expertise, broader staff training, and development of new policy guidance (16%). Around 41% of CMOs say data ethics has become an integral part of their organisation’s culture.

The results are based on 12 responses provided by global CMOs who sit in the WFA’s CMO Forum, which represents brands spending over US$120 billion each year.


Findings also show that  50% of CMOs are very concerned about the level of privacy compliance among their external partners and suppliers. For example, these are publishers, ad tech, online platforms, and data brokers. As such, 83% of CMOs are very concerned about being associated with a service provider or supplier that is investigated for the unethical use of data.

Almost 85% of CMOs are considering using privacy-preserving alternatives to programmatic advertising in response to increased regulatory scrutiny.

Only 16% of CMOs are very confident that their company’s use of AI and machine learning will not create harmful unintended consequences for their consumers such as bias, unfair discrimination, or unfair exclusion. Around 33% of CMOs believe that their marketers are consciously avoiding using data in a way that exploits vulnerabilities. For instance, unfairly excludes certain audiences, fuels unhealthy consumption patterns, or polarises opinions. 

While the challenges this poses are difficult and often beyond a CMO’s direct control, CMOs are in a position of unparalleled importance as the only leaders who can drive bold industry change.

“The widespread unease with the way data is used in advertising is bringing a tidal wave of pressure on brands and the entire data-driven marketing ecosystem. Only an ethics-driven response will adequately address the challenges and meet the legitimate expectations of consumers. However, data ethics is complex and often remains an abstract concept that is not properly understood in practice. This must-read guide helps CMOs unpack the different facets of data ethics and guides them on the path to doing the right thing with data,” said Stephan Loerke, CEO of the WFA.

How should CMOs respond?

There are five key actions that will help CMOs socialise their ethics requirements externally and hold their partners and suppliers to account.

1. Develop and implement your own data ethics principles

Once you have embedded privacy compliance programs which meet regulatory demands, you should implement additional global principles for the collection, use, sharing, and storage of data for marketing purposes. This will act as a model for external partners and enable you to spot unacceptable behaviours.

2. Understand who your providers are and what they do with data

Start by identifying the stakeholders with whom you have a relationship and understand their data practices, how they carry these out, and whether they have suffered any recent data breaches. This will help you benchmark their practices against your own and understand which partners represent a higher risk.

3. Encourage your providers to align with your ethics principles

Encourage your providers to align with your own ethics standards and assess the need for direct agreements with key publishers. Research and collaboration with partners and industry peers will be key to socialising more responsible practices across the supply chain.

4. Crystallise commitments in contractual agreements

Embedding ethics commitments for data capture, use, and sharing in a contractual agreement will help hold partners accountable. These should focus particularly on ensuring that your providers are not systematically selling data to third parties and include suitable indemnities in case of a breach. This agreement should be monitored through regular assessments and audits by an independent body. Evaluating external partners before contracting will also help mitigate any future risks.

5. Understand who is placing third-party trackers on your website

Understand the trackers present on your sites, what data they are collecting, and who they are sharing it with. The objective should be to limit the number of second and third-party trackers to what is truly driving real value to the business.

“It feels like the digital ad market in 2022 is facing an inflection point with the scale of regulatory, consumer, and market pressures. So it’s an opportune moment to take a step back and consider how brands can use data in a more responsible, equitable, and ethical manner. As CMOs, we have a unique responsibility to lead this change. If we don’t, we threaten the entire industry’s license to operate longer term,” said Raja Rajamannar, WFA president and Mastercard chief marketing and communications officer.

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