Logo for Magniventris, a yellow geometric shape outlined in angular black lines.

Ethics in PPC Advertising

Hey y’all! Thanks so much, Jyll for having me here at PPC Zone and Sarah for the presentation!

First presentation slide, with text on the left side reading, 'Hi! I'm Doug! 13 years of digital marketing experience. Ethically-focused digital marketing strategy and implementation.' and the Magniventris logo on the right side.

I’m Doug Thomas. My pronouns are he and him. I’ve been in the digital marketing world for 13 years, doing almost everything under the digital sun, including search, social, and video advertising.

Now, I’m the lead strategist at Magniventris, an ethical digital marketing company that helps organizations make their digital marketing more inclusive, accessible, safe, ethical and effective.

Second presentation slide, reading '3 Ethical Areas. Inclusivity, Accessibility, Privacy.'

Today, I’m super-excited to show y’all some ways to make your PPC Advertising more ethical. We’re gonna go over one thing from each of the three different ways that ethics comes up in PPC advertising: inclusion, accessibility, and privacy.

And while we do that, I want y’all to think about – and if you’re comfortable, share in chat — what ethical issues keep you up at night.


Third presentation side, quoting the Fair Housing ADvertising regulation: '§ 109.25 (c) Selective use of human models when conducting an advertising campaign. Selective advertising may involve an advertising campaign using human models primarily in media that cater to one racial or national origin segment of the population…'

Inclusivity is maybe the first step to making our ads ethical. It’s ultimately an important goal: we want to make sure all of our clients’ customers feel like they’re welcome to buy the thing we’re advertising.

This isn’t just a moral imperative – it’s part of over three decades of law for industries like the financial world.

In 1989, the regulations for Fair Housing Advertising were published, providing FHA lenders with guidance on how to create advertising that doesn’t exclude people. Among advice around media placements, translation, and copy, the regulations have a section about what they call “Selective Use of Human Models.”

This section instructs that when you’re using stock photos, you have to actually represent the people that are in your audience. This seems simple, but there are thousands of times when you’ve seen this just not happen.

Fourth presentation slide, showing a screenshot from Shein's dresses page. There are 5 columns and two rows of various dresses showing. All of the dresses use the same model, a thin blonde white woman.

As an example, let’s look at one of the most successful DTC companies – Shein. If you look for a dress, you see literally just one model, a thin white woman. Their regular sizing goes from size 4 to size 12. Customers might wonder: how do these clothes fit on different bodies?

If Shein provided even just one other model, showing how the dress fits on a different body type, their sales would increase, their returns would decrease, and overall the retailer’s profitability would be even higher.

This is just one example of how someone might use inclusivity to make their ads more effective, but I think it’s the most obvious. For every business, showing your audience how your product helps the real them will always be more effective than showing someone who’s only kind of like them.


Fifth presentation slide, with a title at the top and two separate columns that read: 'Accessibility. Disability does not equal Personal Health Condition. Disability equals Mismatched Human Interactions.

But it’s not enough to just look like you help people like them. July is Disability Pride Month, bringing awareness and visibility to the disability community. The next step to making your PPC advertising more ethical is supporting folks who might use the web differently than the majority of users.

One definition of “disability” is key to how we can approach accessibility. Microsoft’s Inclusive Toolkit defines disability not as a personal health condition, but a mismatch between expected and actual human interactions.

Using this definition, we can think of accessibility as not an attempt to design for some unknowable edge case, but as improving the usability of the site for everyone.

And usability is no more important than on the most important part of a lead-generating landing page: the form.

Sixth presentation slide, showing a partially-filled-out form. The form has 5 fields. The first 4 fields are in two columns, with the textarea field spanning both columns. The first two fields are filled in, hiding the field labels because the form only used placeholders. The third field, labeled 'Email,' is in an error state and bordered and filled with red.

So let’s look at a form I recently redesigned, from a Wix site. This form has some great points for accessibility, notably the size of the inputs and the clearly-delineated input areas. But there’s two big issues we can solve.

The first issue is the basic layout: two columns, then one. This creates a moment of hesitation for the user, because the zig-zag eye motion adds to the cognitive load required to complete the form.

The next issue is easily seen in the first two fields. There are no labels! They only use placeholders. This creates a few problems.

On longer forms, this can make people lose their place. In addition, labels act as click targets, increasing the area where people can click to activate the field. And for people who use screen readers, using just placeholders can affect how the screen reader reads the form.

Seventh presentation slide, showing a different partially-filled-out form. The form has 4 fields. All the fields are wide and in one column. The form has a header that reads 'Contact Us.' The first row is filled in, but the field label of 'Name' is still visible. The third field, labeled 'Email' is in an error state and bordered in thick red.

So here’s the redesigned form. One column, with labels.

By focusing on the usability of your landing pages, you’ll increase the accessibility for all your customers.


Eighth presentation slide, quoting the GDPR: 'Art. 12 Transparent information, communication and modalities for the exercise of the rights of the data subject. The controller shall take appropriate measures to provide any information… in a concise, transparent, intelligible and easily accessible form, using clear and plain language….'

Now, representing your customers and doing the work to support their needs is great. But there’s one final thing to do to help your PPC campaigns be more ethical. Actually informing our clients’ customers’ of how we use their data is a vastly under-represented way to be ethical about our PPC advertising.

So many times, when we drive ads to a website, we see a privacy policy that quickly devolves into 10-cent words like “herein” and vague phrases like “trusted third parties.”

What’s funny is that there’s a legal requirement against this – GDPR’s Article 12 requires that data controllers provide information about data processing “in a concise, transparent, intelligible and easily accessible form, using clear and plain language”

Ninth presentation slide, quoting the WordPress privacy policy template: 'What personal data we collect and why we collect it. In this section you should note what personal data you collect from users and site visitors. This may include personal data, such as name, email address, personal account preferences….'

The good news is that one of the best privacy policy templates comes built in to the most widely-used CMS on the web – WordPress.

The first thing you’ll notice is that the WordPress privacy policy asks you to state exactly what personal data you collect. If you’ve been keeping up with the news, you’ll know that IP Addresses, locations, and even device types are all considered personal data. Tell your customers everything that you collect.

Ninth presentation slide, again quoting the WordPress privacy policy template: 'Comments. In this subsection you should note what information is captured through comments. We have noted the data which WordPress collects by default.'

The second great thing is that it separates out your data collection by action, so you can structure your privacy policy like your data audit. This helps you organize your privacy policy in a way that helps customers see where their data’s going based on what they do on the site.

Tenth presentation slide, yet again quoting the WordPress privacy policy template: 'Who we share your data with. In this section you should name and list all third party providers with whom you share site data, including partners, cloud-based services, payment processors, and third party service providers, and note what data you share with them and why.'

Finally, the WordPress template provides sections for other data partners. Your hosting company logs personal information, your web analytics collects personal information, and if you’re using an email service to collect newsletter signups, you’re sending then personal information. Your customers deserve to know specifically who else gets their data.

Privacy policies communicate how advertising actually works to the public. We as advertisers have to help our clients and their customers protect their data online.

Eleventh and final presentation slide, reading 'Ethical PPC Advertising. Use models that reflect all of your audience. Focus on usability of your landing pages. Use a descriptive plain-language privacy policy.'

So that’s a quick overview of ethical considerations in PPC.

Promote inclusivity by using models that reflect all of your audience.

Focus on usability for all of your users to help increase accessibility.

And use a descriptive plain-language privacy policy to explain to your clients’ customers how you use their personal information.

I hope y’all have gotten out of the time we’ve have together the same feeling that I have about doing marketing ethically: that every thing that makes our marketing more ethical also makes it more effective.

Thanks for having me, and stay tuned for Armina.