Institute of Practitioners in Advertising (IPA) – written evidence (DAD0026)


About the Institute of Practitioners in Advertising (IPA)

  1. The IPA, incorporated by Royal Charter, is widely recognised as the world’s most influential professional body for practitioners in advertising, media and marketing communications. It has a well-earned reputation for thought leadership, best practice and continuous professional development and also provides core support and advisory services for its corporate members which handle over 80% of the UK’s advertising spend. IPA programmes can be found in more than 87countries worldwide. Its membership primarily comprises advertising and media agencies.


  1. The IPA progresses media policy issues through its Media Futures’ Group which meets every month and which is made up of representatives from the UK’s media agencies. IPA media agencies handle the planning and buying of ~85% of UK display advertising spend.


  1. The IPA is one of the tripartite stakeholders that make up The Advertising Association which represents advertisers, agencies and media owners. The other stakeholders are the Incorporated Society of British Advertisers and a cluster of media owners.


Why UK agencies matter

  1. UK advertising, media and marketing communication agencies sit at the heart of a much larger UK creative industries ecosystem. We employ 35,000 people (27,000 of whom work in IPA member agencies). . Because of the nature of our work we also directly impact other companies growth prospects: for example, advertisers (domestic and global) and other creative businesses eg production companies.


  1. The advertising industry is seen as a bellwether for the wider economy – the IPA Bellwether Report in particular is the only indicator that has accurately anticipated both the last downturn and upturn. It is a quarterly survey of client spending intentions. The 2Q 2019 Report (published 17th July 2019) reports that spend on internet advertising continues to be the strongest category and has grown consistently since 2000 highlighting the continuing shift to and development within the digital space.


  1. The Advertising Association/Warc expenditure 2018 report shows that the internet accounts for more than half of advertising spend (~£12b out of £23.6b) and is forecast to grow nearly 12% in 2019.


The UK Digital Economy


  1. The UK has one of the most advanced digital economies in the world. It was ranked as one of the world’s “digital elite” in research published by Mastercard and The Fletcher School at Tufts University. The UK is identified as one of the so-called “Stand Out” economies, characterised by high levels of digital development and a fast rate of digital evolution.


  1. The UK is a global leader in e-commerce and has arguably the most advanced digital media market of any major national economy. UK digital adspend is greater than Germany, France and Italy combined.


  1. We note the Government’s commitment that “the UK should lead the world in innovation-friendly regulation” and to “create the foundations for the UK digital economy to thrive”.


  1. A distinction needs to be drawn between the UK Digital Economy and the impact on UK democracy of digital technologies.



The IPA submission:


  1. The IPA believes that the internet has proved itself to be a powerfully influential and potent business and personal tool. As with all things, with great power comes great responsibility. The pace of its growth has meant its influence and effects on society are still not fully-known. It is also apparent that in the last ten years, with the rise of social media particularly, it is a complex and ever-evolving channel that needs to be understood and moderated as appropriate. 


  1. Use and abuse of the internet, and especially social media, are having a profound effect on political systems around the world, including western liberal democracies like the UK.


  1. We feel compelled by our recent submissions to the DCMS Select Committee, Cabinet Office and Centre for Digital Ethics and Innovation consultations, to respond again on the subject of online political advertising


  1. Online political advertising, underpinned by online targeting, presents a unique and profound challenge.




Specific Questions and Answers


Online campaigning


4. Would greater transparency in the online spending and campaigning of political groups improve the electoral process in the UK by ensuring accountability, and if so what should this transparency look like?


Yes. Transparency in online campaigning is especially important because this opaque and unaccountable form of political communication is vulnerable to abuse. There is no oversight or regulation of political advertising messaging.


Individual online platforms have made some progress in providing platform-specific political advertising archives. However, it is insufficient, unwieldy and prone to obsolescence to rely on these disconnected unilateral archives.


The IPA calls for each online platform to be responsible for populating an independent platform-neutral register by providing all their political ad campaign data and metadata as feeds. Furthermore, echoing Full Fact, the UK’s Independent fact checking Charity, the IPA calls for the register to be in real time, machine-readable, and with full details of content, targeting and spend.


To fund this registering, the IPA moots the idea of online platforms charging a fixed fee for each individual political ad creative used, irrespective of the scale of use. This would correlate registry funding to the workload of political messaging it would have to handle.


We support the Electoral Commission’s call for digital political advertising imprints to clearly show who paid for the adverts.


5. What effect does online targeted advertising have on the political process, and what effects could it have in the future? Should there be additional regulation of political advertising?


Politics relies on the public sphere - on open, collective debate.


We believe micro-targeted political ads circumvent this. Very small numbers of voters can be targeted with specific messages that exist online only briefly. In the absence of regulation, we believe this opaque and unaccountable form of political communication is vulnerable to abuse.


We support additional regulation of political advertising but remain unconvinced this will take place with sufficient urgency, if at all.


In the interim we call for a ban on micro-targeted political advertising online. As per our submission to the Centre for Data Ethics and Innovation (CDEI)’s Review of Online Targeting:


In his paper Manipulating Citizens: How Political Campaigns’ Use of Behavioral Social Science Harms Democracy, Professor William Gorton warns that microtargeting ‘turns citizens into objects of manipulation and undermines the public sphere by thwarting public deliberation, aggravating political polarisation, and facilitating the spread of misinformation’.


In Online Political Microtargeting: Promises and Threats for Democracy, the authors note:

Politicians could use microtargeting to manipulate voters. For instance, a party could target particular voters with tailored information that maximises, or minimises, voter engagement. A party could use social media to expose xenophobic voters to information about the high crime rates amongst immigrants. The targeted information does not even need to be true to maximise its impact.


Political parties could also use microtargeting to suppress voter turnout for their opponents. For example, in 2016, the Donald Trump campaign reportedly targeted African-American voters with advertisements reminding voters of Hillary Clinton’s earlier remarks of calling African-American males ‘super predators’ to suppress African-American votes.


A political party could also misleadingly present itself as a one-issue party to each individual. A party may highlight a different issue for each voter, so each voter sees a different one-issue party. In this way, microtargeting could lead to a biased perception regarding the priorities of that party. Moreover, online political microtargeting could lead to a lack of transparency about the party’s promises. Voters may not even know a party’s views on many topics.”



We have not set a fixed threshold under which targeting would be defined as microtargeting. We volunteer to help create a mechanism for calculating thresholds (for example minimum percentage of electorate in a geographical region).



Democratic debate


8. To what extent does social media negatively shape public debate, either through encouraging polarisation or through abuse deterring individuals from engaging in public life?


Again referencing our submission to the CDEI’s Review of Online Targeting, this review defines autonomy as “our ability to make choices freely and based on information that is as full and complete as reasonably possible”. The challenge to this, especially with regard to political discourse, is The Law of Group Polarisation. Exert:  “In a striking empirical regularity, deliberation tends to move groups, and the individuals who compose them, toward a more extreme point in the direction indicated by their own predeliberation judgments.


As Cass R. Sunstein (Robert Walmsley University Professor, Harvard) the author of this paper subsequently noted in 2007 “… as a result of the Internet, we live increasingly in an era of enclaves and niches -- much of it voluntary, much of it produced by those who think they know, and often do know, what we're likely to like. This raises some obvious questions. If people are sorted into enclaves and niches, what will happen to their views? What are the eventual effects on democracy?


We would argue online enclaves and niches relating to products, services and cultural groups (imagine classic car owners, airline executive club members, fans of a particular football club or pop band) pose little threat to individuals, organisations or to society. Within the bounds of the law, online targeting in these spaces is largely innocuous.


The contrast with regard to political online targeting and the potential for its abuse could not be starker,