Our companies collect consumer data on behalf of clients, and use it to study attitudes (including purchasing habits) and to create targeted digital and direct marketing campaigns.

Privacy is a high-profile topic and one that we take very seriously. Our agencies comply with privacy and data protection requirements and participate in efforts to standardise practices and provide clear information to consumers.

Some consumers and interest groups are concerned about the collection and use of personal data for marketing purposes, including practices such as behavioural targeting. We work with trade organisations and others in our industry to address these issues.

Principles and guidance
Our approach is guided by four priorities: maintaining consumer trust; reducing legal and financial risks to WPP; educating our people and the people we work with and improving our own knowledge base; and enabling our clients to use consumer data appropriately to enhance their marketing.

The parent company provides guidance and advice to our companies on privacy and data security issues. To ensure that all our people have an understanding of the basic issues, we have added privacy and data security to our revised ethics training which is being rolled out to all employees in 2013. We also held a training event on the EU Cookies Directive for employees in the UK during 2012.

A briefing document is available on our Group intranet to help employees understand their legal responsibilities and the need to balance commercial objectives with privacy obligations. It defines basic privacy-related terms and includes guidance on privacy clauses in client contracts, data privacy expectations and what to do if a breach occurs.

In 2012 we reviewed and updated all WPP’s data protection, data security and privacy policies, and introduced new policies covering social media, IT and Security. We developed a ‘Data Code of Conduct’ – a simple one-page set of principles for how WPP uses and protects data. This is intended to help employees understand our approach and to make decisions that reflect our principles. The Data Code of Conduct and revised policies was launched in early 2013.

We will also launch the WPP Data Health Checker, an interactive survey that will be completed by management teams in every WPP company worldwide. Results will help them assess how their current policies and practices compare to best practice, and will provide valuable information to help our Group digital, legal, IT and audit teams to target support where it is needed most.

Company approaches
Our key digital marketing and research companies nominate senior executives to provide leadership on privacy, and to work with other companies in the Group and clients. In addition, many of our companies have specific policies and procedures relevant to their businesses covering how data should be handled, and some have developed their own technology and tools to improve transparency. See ‘In our companies’ section of this years Sustainability Report for examples.

Working with others We continue to review our contractual arrangements with suppliers and clients, to clarify respective roles and responsibilities for privacy, to make sure these are appropriate and consistent and to ensure that they continue to meet the requirements of evolving laws and regulations.

Our companies work closely with trade associations and industry partners to develop constructive positions on data protection and privacy. One example of this is the development and roll-out of the Digital Advertising Alliance ‘icon’, which aims to give consumers clear information about how their personal data is used online and to update their tracking preferences. A number of our companies are also involved in updating the Network Advertising Initiatives code of best practices for online behavioural advertising, and are taking part in discussions on policies regarding online tracking.

WPP people are active members of a host of organisations working on privacy issues. Examples include:

- Brooks Dobbs, chief privacy officer of KBM Group, is an invited expert member of the W3C (Worldwide Web Consortium) Tracking Protection Working Group;

- Ruud Wanck, head of Interaction EMEA, is on the Board of IAB (Interactive Advertising Bureau) Europe.

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