Facebook® and Data Privacy
What You Need to Know
Engaging Educators? Learn How Facebook Updates Affect Your Marketing Campaigns
MDR has been paying close attention to the Facebook landscape. While there has certainly been some confusion over recent privacy policy changes, data breaches, and how this may affect Facebook users and advertisers alike, we have been working closely with Facebook and our legal team to ensure that our products are in a strong position moving forward in this uncertain climate.
We Ensure Data Compliance, So You Don't Need To
We take pride in being able to review and react to changes in the market in a manner that is consistent with our commitment to customer service and data quality.
FAQ's (Sourced from Facebook's FAQ)
Custom Audiences & Managed Custom Audiences
Q: What is happening to Facebook Custom Audiences and can advertisers still use 3rd party data like MDR’s to create a custom audience?
Facebook advertisers will be able to create Custom Audiences from MDR data that they have the rights, permissions, and lawful basis to use. Facebook will be updating their Custom Audiences Terms of Service and may add additional requirements to ensure the protection of people’s privacy over time. As a Facebook advertiser you will need to represent that you have the right to use the data you upload to Facebook. Your MDR data license agreement for Internet use will provide you with the rights for usage.
Q: I want to work directly with a data partner like MDR to create a Custom Audience using their data. How do I verify that I am allowed to use that data and what is the process for uploading that data?
Advertisers should consult with legal counsel to ensure they have appropriate rights to use the data, and should understand the source of the data as well as the source of permission/right for the data to be shared and used for advertising purposes. Facebook is building a new tool for uploading data for Custom Audiences onto Facebook. While all the details are not yet determined, Facebook’s intent is to enable advertisers to both directly upload data files themselves and represent/warrant that they have the rights and permissions to use the data, and to provide permission for certain service providers like MDR or other agencies to upload and manage their data for them. In either case, advertisers must agree and take responsibility for any data they obtain from others.
Q: Will data providers be considered 'service providers' and be allowed to upload and manage audiences on behalf of an advertiser when the new Custom Audiences permissions tool is launched?
Yes, but advertisers will only be able to use data that they can represent and warrant that they have adequate rights to use. Facebook is working to enable agency and FMP-support for managing Custom Audiences, but no specifics are available to share at this time. Specifics of the Custom Audiences permissions tool will be shared with more details over time.
Q: What are managed Custom Audiences (versus first-party Custom Audiences)?
Managed Custom Audiences are Custom Audiences from an advertiser that are uploaded by a third-party data provider and shared to the advertiser.
Q: What will happen to managed Custom Audiences moving forward?
In the form they exist in today, managed Custom Audiences will be deprecated on July 1st. However, advertisers will be able to continue using any audiences they can attest that they have adequate rights to use, so long as they either upload it to their account and/or grant permission to a service provider to upload to their account on their behalf. Even when working with another party, advertisers must still attest that they have adequate rights to use the audiences. Over time, Facebook may introduce additional safeguards and provide stronger accountability for how people's data is used on our platform, and notification of any changes will be announced.
Q: If the 3rd party data provider, like MDR, isn't able to upload their audience directly to Facebook and then share it with the advertiser - then how would an advertiser get access to the 3rd party audience? Is the data provider expected to pass PII to the advertiser which the advertiser then uploads to our CA tool? Or will we enable the Data Provider to share an anonymous key of some kind (hashed ID) with the advertiser - which Facebook is then able to match to a FB ID?
Managed Custom Audiences are available until July 1. Facebook is currently working on accounting for these concerns with the upcoming Custom Audiences permissions tool, which will be available before July 1. They plan on enabling workflows that will allow for audience uploading and sharing without passing along personally identifiable information. They will share more details in the coming weeks.
Q: Are we considering "Advertiser" to in some cases also mean agencies or FMPs? In many instances, agencies/FMPs run all aspects of the buying process (ad account creation, custom audience management, etc.) and the advertiser isn't involved with the heavy lifting at all.
Facebook is working to enable agency and FMP-support for managing Custom Audiences, but they don't have specifics to share at this time. They are working on specifics of the Custom Audiences permissions tool and will share more details over time.
Q: I am an advertiser that uses a third party to manage my data. Will I still be able to use my first-party data that they are managing for me? Can they still upload it directly for me using a secure TPID? How exactly will the process change from today?
Facebook is currently evaluating specifics, but plan to support third-party ID matching. With the new Custom Audiences permissions tool, a service provider will be able to upload data on an advertiser's behalf, but advertisers must attest to having proper legal rights to use the data in accordance with custom audience terms.
