The Leader: February edition

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Google targets UK lead gen firms with the business operations verification process

After it was initially rolled out in the US we knew Google’s audit of adwords advertisers was coming (we wrote about it here, back in July 2020) but we didn’t know when, for which products and how severe the process would be.  We now have answers to all of those questions.

The ‘business operations verification program’ is Google's latest attempt to tackle fraud. Its intention appears to have been to close the loopholes that allow fraudulent businesses to mislead consumers about their links to the products but also to create more transparency about who is actually running the adverts.

Contact State phones started ringing in mid December with reports of lead generators and financial brands having their accounts paused for the audit and it appears that life insurance adverts were amongst the first to be targeted.

We’ve chatted to numerous companies who have been through the verification process and most passed first time and allowed to keep bidding. A notable few failed but were then passed at the second time of asking with a more robust response. The average ‘down time’ for live search campaigns appears to be anything from 1-3 days and most people we’ve spoken to think the questions are standard

One of the expectations of the google process would be that it would close glaring loopholes but as yet, that doesn’t seem to be happening. A source of frustration for many legitimate marketing firms is the manner in which Google turns a blind eye to obvious double serving of adverts. If you review the “Life Insurance” search term right now ranked 1 and 2 is a business with slightly different landing pages, the same logo and offering exactly the same lead generation form. It's less than ideal.

Takeaway - What do you need to know?

Right now Google appears only to be collecting data about firms and then only in obvious cases, suspending accounts if a company doesn’t properly fill the form in. The audit so far is not the sweeping away of bad actors, that we all hoped it would be.

There is however a second step coming. Google intends to start displaying information about where a company is based (some good detail here about the problems this is causing in North America) and that's a step we welcome.  If an advert is offering UK consumers a ‘great deal on your mortgage’ but the advertiser is actually a dodgy company in Bermuda, consumers should be able to see this transparently before they click. 

We think Google is simply collecting a lot more information about advertisers now, to make it easier to take them down in the future. 

The ICO steps up enforcement over ‘unlawful’ lead generation

The ICO seems to have turned their attention away from major consumer brand data breaches and towards smaller marketing and financial firms who knowingly misuse consumer data. 

Announced by Andy Curry, the ICO’s Director of Investigation the ICO issues fines totalling 480k to four firms it found to be in breach of its data rules and the language used in the fines makes for interesting reading

The ICO were always going to get to grips with ‘data and lead’ sales and its recruitment of senior technology staff and the way its engaging with particularly the financial services sector means its becoming more knowledgeable.

Takeaway - What do you need to know?

The ICO are focusing on due diligence, and in particular the processes it expects to see from data buyers who work with lead generators and brokers of data.  The language and highlighted quotes from the latest ICO enforcement noticed is the most stark and clear takeaway here. 

If you acquire data to make outbound calls to, the ICO will expect you, the buyer, to know where its come from and what the consumer consented to. This shift in targeting individual firms that acquire data follows a very similar pattern of litigation to what we’ve seen in the US with the enforcement of the Telephone Consumer Protection Act (TCPA).

Life Insurance searches breaks five year record in January 2021

Google trends is a very useful tool if you are looking for top level trends about what is going on with customer intention, in any given market. Particularly if you buy leads, developing a better understanding of the environment your particular product sits in, is good practice. 

I’ve been around financial services marketing and even I was surprised at the level of customer intention, contact and lead volume that seemed to be around last month. A quick look at the five year tracking for the head term “Life Insurance” reveals some fascinating findings.

This is the screenshot for the term ‘Life Insurance’ for the past five years and you can find the exact same data here.

Searches for protection are booming, January represents the most amount of searches for Life Insurance than at any point over the last five years.

Takeaway - What do you need to know?

It is very possible that consumer demand for Life Insurance is overheating. The pandemic, the daily reminder of mortality and extension of the furlough scheme are all factors that are driving consumer demand and intention. These factors are unlikely to be around come the summer.

One life insurance broker told me last week that they are spending almost as much on hiring staff to help them retain the customers they’ve won as they are trying to expand a team to make more sales. That seems like a very sensible course of action; after every boom there is always a bust, and life insurance lead generators and lead buyers should be particularly careful as they plan their business over the next few months.