Branded Content: The Fateful Merging of Media and Marketing 113819042X, 9781138190429

This is a critical study of the changing relationship between media and marketing communications in the digital age. It

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Table of contents :
Cover
Half Title
Title Page
Copyright Page
Table of Contents
List of tables
Acknowledgements
PART I:
Practices
1. Advertising and media: Separation and integration
2. News media and marketing
3. Branded entertainment and product integration
4. Brand content direct to you: Marketers’ ‘owned’ media
5. Going native in digital media
6. Media as marketers
PART II:
Policies and problems
7. Regulating convergent media and marketing communications
8. Lobbying, liberalisation, normalisation, and contestation
9. Communication gains and losses: Economic, cultural, and societal
10. Media and marketing critiques: Renewing the radical tradition
11. Advertising and media (reprise): Contesting normalisation
Index
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BRANDED CONTENT

This is a critical study of the changing relationship between media and marketing communications in the digital age. It examines the growth of content funded by brands, including brands’ own media, native advertising, and the integration of branded content across film, television, journalism and publishing, online, mobile, and social media. This ambitious historical, empirical, and theoretical study examines industry practices, policies, and ‘problems’, advancing a framework for analysis of communications governance. Featuring examples from the UK, US, EU, Asia, and other regions, it illustrates and explains industry practices, forms, and formats and their relationship with changing market conditions, policies, and regulation. The book provides a wide-ranging and incisive guide to contemporary advertising and media practices, to different arguments and perspectives on these practices arising in industry, policy, and academic contexts, and to the contribution made by critical scholarship, past and present. It also offers a critical review of industry, regulatory, societal, and academic literatures. Jonathan Hardy examines the erosion of the principle of separating advertising and media and calls for a new framework for distinguishing marketing communications across 21st-century communications. With a focus on key issues in industry, policy, and academic contexts, this is essential reading for students of media industries, advertising, marketing, and digital media. Jonathan Hardy is Professor of Communications and Media at the University of the Arts London. He writes and comments on media industries, media and advertising, communications regulation, and international media systems. His books include Critical Political Economy of the Media (2014), Cross-Media Promotion (2010), and Western Media Systems (2008). He is coeditor of The Advertising Handbook (2018) and is series editor of Routledge Critical Advertising Studies. He is a member of the editorial boards of Digital Journalism, Political Economy of Communication, Mediterranean Journal of Communication, and TripleC: Communication, Capitalism & Critique.

BRANDED CONTENT The Fateful Merging of Media and Marketing

Jonathan Hardy

First published 2022 by Routledge 2 Park Square, Milton Park, Abingdon, Oxon OX14 4RN and by Routledge 605 Third Avenue, New York, NY 10158 Routledge is an imprint of the Taylor & Francis Group, an informa business © 2022 Jonathan Hardy The right of Jonathan Hardy to be identified as author of this work has been asserted by them in accordance with sections 77 and 78 of the Copyright, Designs and Patents Act 1988. All rights reserved. No part of this book may be reprinted or reproduced or utilised in any form or by any electronic, mechanical, or other means, now known or hereafter invented, including photocopying and recording, or in any information storage or retrieval system, without permission in writing from the publishers. Trademark notice: Product or corporate names may be trademarks or registered trademarks, and are used only for identification and explanation without intent to infringe. British Library Cataloguing-in-Publication Data A catalogue record for this book is available from the British Library Library of Congress Cataloging-in-Publication Data Names: Hardy, Jonathan, 1963- author. Title: Branded content : the fateful merging of media and marketing / Jonathan Hardy. Description: Abingdon, Oxon ; New York, NY : Routledge, 2022. | Includes bibliographical references and index. Identifiers: LCCN 2021008966 (print) | LCCN 2021008967 (ebook) | ISBN 9781138190412 (hardback) | ISBN 9781138190429 (paperback) | ISBN 9781315641065 (ebook) Subjects: LCSH: Product placement in mass media. | Branding (Marketing) | Internet marketing. | Internet advertising. | Marketing–Technological innovations. | Advertising–Technological innovations. | Marketing–Moral and ethical aspects. | Advertising–Moral and ethical aspects. Classification: LCC HF6146.P78 H39 2022 (print) | LCC HF6146.P78 (ebook) | DDC 658.8/27–dc23 LC record available at https://lccn.loc.gov/2021008966 LC ebook record available at https://lccn.loc.gov/2021008967 ISBN: 978-1-138-19041-2 (hbk) ISBN: 978-1-138-19042-9 (pbk) ISBN: 978-1-315-64106-5 (ebk) DOI: 10.4324/9781315641065 Typeset in Bembo by Taylor & Francis Books

CONTENTS

List of tables Acknowledgements

vi vii

PART I

Practices 1 Advertising and media: Separation and integration

1 3

2 News media and marketing

35

3 Branded entertainment and product integration

68

4 Brand content direct to you: Marketers’ ‘owned’ media

85

5 Going native in digital media

100

6 Media as marketers

125

PART II

Policies and problems

141

7 Regulating convergent media and marketing communications

143

8 Lobbying, liberalisation, normalisation, and contestation

169

9 Communication gains and losses: Economic, cultural, and societal

206

10 Media and marketing critiques: Renewing the radical tradition

229

11 Advertising and media (reprise): Contesting normalisation

242

Index

272

TABLES

8.1 UK newspaper labelling 8.2 The antimonies of branded content

181 191

ACKNOWLEDGEMENTS

This book is the outcome of discussions dating from 2012, and so there are many people, not all named below, I wish to thank. In 2016–17, I was Principal Investigator for the Branded Content Research Network, funded by the Arts and Humanities Research Council, which ran seminars in London, at the University of Bournemouth, and held an international conference at the University of East London (UEL). This work has benefited from funding and other support from UEL and the UBEL ESRC Doctoral Training Partnership, Business Boost Funding. I am very grateful for the welcome and support I have received since I joined the University of the Arts London (UAL) in 2020, from Steve Cross, Pratap Rughani, Zoetanya Sujon, and all my new colleagues. I am the co-ordinator for the newly created Branded Content Research Hub at UAL, which I hope will provide valuable resources and support for interested readers of this book and build on the Branded Content Research Network. That network grew to bring together academic researchers from the UK and Europe, developing a partnership with the then Temporary Advertising Working Group in the European Communication Research and Education Association (ECREA), and researchers from across six continents. The network, and research hub, have brought together industry practitioners and trade bodies, academics at all stages of careers, students, regulators and policy actors, media trade unions, and other civil society interests. This book explores and advances critical perspectives, yet seeks to do so through understanding and appreciation of the expertise, practices, and perspectives of practitioners. The tensions between celebrants and critics of branded content have been ever-present, but I have learnt two key things. First, the domains of knowledge interact dynamically, and academics should resist retreating to haughty hierarchies of knowledge and instead engage with all sources of knowledge production to try to understand these phenomena. Second, ‘knowledge exchange’ needs precious (and hard to achieve) skills in listening to needs and interests, and responding, to build mutual trust and value. While few of the

viii Acknowledgements

marketing practitioners listed below would agree with all of my recommendations, and no one listed has in any way endorsed the arguments made, the willingness to engage, reflect, debate, and so generously support my own work, and the wider research initiative, has been a source of great comfort and encouragement for which I am immensely grateful. There is an ever-present debate on remedying policy problems by ‘piecemeal’ versus deeper structural reform, by self-regulation versus publicly accountable, enforceable regulation. This book argues for both, but I want to acknowledge how much I have learned through this collaborative project about the potential to advance better industry self-governance through advocacy and exchange. While self-governance is insufficient to address the problems this book examines, it is nevertheless a necessary component, on which much can be built. For industry, I wish to thank Andrew Canter, Global CEO of the Branded Content Marketing Association, and Vince Medeiros, Chair of the Content Marketing Association, both of whom have been committed to expanding research and education to benefit students and industry. Through the BCMA, CMA, and wider networks, I wish to thank Neil Boorman, Lazar Dzamic, Pete Fergusson, Gordon Glenister, David Gray, Scott Guthrie, Matt Hay, Justin Kirby, Catherine Maskell, Luke Southern, Greg Turzynski, and Stephen Whelan. For policy and civil society, I wish to thank Mary Fitzgerald, Adam Ramsey, and James Cusick at openDemocracy, Michelle Stanistreet and Sarah Kavanagh at the NUJ, Bernie Corbett, WGGB, Paul Evans and Morag Livingstone at Bectu, all my colleagues in the Media Reform Coalition, and the Campaign for Press and Broadcasting Freedom. I thank Jonathan Heawood, Impress, and Julian Coles, Internet Commission. All UK regulators (Ofcom, ASA, CMA, IPSO, Impress) have participated in BCRN events and activities. I thank Peter Jukes at Byline for inviting me to contribute to the annual Bad Press Award, to help select the worst sponsored content. Having chosen articles read out by John Cleese, Joanna Scanlan, and others was the most terrifying and exhilarating taste of being a comedy writer. For academia, I want to thank my co-researchers on branded content governance, Iain MacRury and Patricia Núñez-Gómez, and Gloria Dagnino who helped develop this nascent project. I thank, merely by listing but with deep appreciation, the following. UK: Rula M. Al Abdulrazak, Bjoern Asmussen, Anne Cronin, Nick Couldry, Des Freedman, Chris Frost, Christian Fuchs, Paul Grainge, Chris Hackley, Dan Jackson, Stephanie Janes, Catherine Johnson, Sonia Livingstone, Dario Lolli, Liz McFall, Stephen Maddison, Leslie Meier, Martin Moore, Andrew McStay, Helen Powell, Agnes Rocamorra, Paul Springer, Damian Tambini, and Hyunsun Yoon. Europe: Sandra Arrivé, Petra Audyova, Nils Borchers, Ágnes Buvar, Jose FernándezCavia, Simone Krouwer, Lluis Mas Manchón, Neil O’Boyd, Steve Paulussen, Karolien Poels, Tim Smits, Kirsten Sparre, Niina Uusitalo, and Guido Zurstiege. North America and rest of the world: Ilhem Allagui, Michelle Amazeen, Arturo Arriagada, Anat Balint, Mara Einstein, James Hamilton, Susie Khamis, Matthew McAllister, John Sinclair, Joseph Turow, Anne Waade, Janet Wasko, and Bartosz Wojdynski. I thank my fellow officers and colleagues in Meccsa Policy Network, Phil Ramsey, Maria Michalis, and Paul Reilly; the editorial board and all the

Acknowledgements ix

authors of the Routledge book series I edit (Critical Advertising Studies), Wayne Hope, Peter Thompson, and Benedetta Brevini at Political Economy of Communication, and Oscar Westlund, editorial board and reviewers at Digital Journalism. This book includes material fully revised from previous articles and chapters: ‘Meeting the Challenges of Media and Marketing Convergence’ in Paul McDonald (ed.) The Routledge Companion to Media Industries (2021); ‘Branded Content: Practices and Governance’ in Lluis Mas Manchón (ed.) Current Issues in Advertising and Branding Research, Routledge (2020); ‘Marketers’ Influence on Media: Renewing the radical tradition for the digital age’ in James F. Hamilton, Robert Bodle, and Ezequiel Korin (eds) Explorations in Critical Studies of Advertising, Routledge (2019); chapters on branded content and advertising regulation in Hardy, Powell, and MacRury (eds) The Advertising Handbook, 4th Edition, Routledge (2018); ‘Commentary: Branded Content and Media-Marketing Convergence’, The Political Economy of Communication, 5 (1) 81– 7 (2017). The research for this book includes documentation analysis of policy, industry, trade media, general media, and civil society documents. This includes analysis of daily Google alerts for reporting on branded content, native advertising, and cross-media promotion from 2010, analysis using Nexis, ProQuest, Ebsco, and other databases, analysis of all academic journal outputs relating to brand sponsored content, and analysis of branded content and other search terms across publishers’ and general academic research databases. This book is informed by extensive discussions with all those listed above, but I want to thank all those who were formally interviewed for the book: Andrew Canter, BCMA; Jo Farmer, Cliff Fluet, Lewis Silkin; Catherine Maskell, Vince Medeiros, CMA; Luke Southern, DRUM; and Jonathan Heawood, Lexie Kirkconnell-Kawana, Impress. This book would not exist without the support and guidance of Margaret Farrelly and Priscille Biehlmann at Routledge, and earlier encouragement from Mary Savigar. I am deeply grateful to my partner Gill and all my family for support. I want to dedicate this book, and pledge to support, everyone who is motivated to investigate, discuss, share, promote, and create a better co-existence between advertising and communications.

PART I

Practices

1 ADVERTISING AND MEDIA Separation and integration

Your Facebook feed says ‘Sponsored’. Your online magazine says, ‘Paid content’, another in BuzzFeed (2015) lists KFC as ‘Brand Publisher’ for an article, ‘11 Things All Busy Families Should Make Time For’, including KFC’s Popcorn Nuggets. You read a powerful series of articles on hunger in America, but it is labelled ‘paid programme’, produced by the Wall Street Journal (2016) Custom Studios in collaboration with Mini, and includes such branded wisdom as ‘Mini owners are all different. There’s no one person that Mini drivers look like. It’s the same with food insecurity. It’s all walks of life.’ You see an Instagram post for Cocoa Brown tan with the hashtag #brandambassador (ASA, 2019). From product placement in films and TV to mobile news feeds and social media influencer endorsements, brands are burrowing into media content. The relationships between media and advertising are changing profoundly as they converge across digital platforms. Increasingly, brands are involved in the production of media content. This branded content takes various forms, from material that is selfpublished by brands, through to ‘publisher-hosted’ content, where brands supply or fund material carried by third-party publishers. Some of this is so-called native advertising, advertising that blends into the editorial or content environment in which it appears, merging brand messages with entertainment or informational content. Taken together, such non-traditional advertising, which blends brand messages with entertainment or information, grew at twice the rate of traditional advertising worldwide in 2017, surpassing $100 billion (PQ Media, 2018). Branded content has grown rapidly, becoming a major focus for marketers during the last decade. In the UK, content and native advertising grew to £509m. in 2014, accounting for 22 per cent of all display ad spending (Internet Advertising Bureau [IAB UK], 2015). Spending on non-traditional, native advertising has been rising in recent years and is expected to occupy an important, if not central, position in advertising strategy and expenditure into the future. DOI: 10.4324/9781315641065-2

4 Practices

Eight million signed into YouTube in 2012 to watch an event called Stratos in which Felix Baumgartner fell from high altitude space to earth in eight minutes (Swatman, 2015). Viewers watched the Red Bull logo throughout, on Baumgartner’s space suit, on the space pod, and on the clothing of crew and spectators below, although ‘the camera never lingers on these symbols’ (Einstein, 2016: 2). Welcome to the world of branded content. Red Bull’s promotions illustrate the expansion of a brand’s use of its own media, so-called ‘owned media’, using its websites, and social and mobile apps to communicate directly with audiences. Red Bull’s Media House produces TV shows, including Baumgartner’s jump, for its Red Bull TV channel, and licensed to the Discovery Channel, Netflix, and others, while Stratos also secured worldwide publicity in news coverage as ‘earned’ media. Red Bull is now a fully functioning media company, whose Media House also creates art and photography books, a lifestyle magazine, Red Bulletin, amongst a host of music and extreme sports content that features branding but rarely includes the energy drink itself. In keeping with much so-called content marketing, the benefits or attributes of the product are not mentioned in Stratos. Baumgartner’s successful jump did, though, fit perfectly with the brand’s tagline: ‘Red Bull gives you wings’. The integration of media and advertising is not new but it is intensifying. Branded content is occurring in different forms across news media, entertainment and social media. The creation of entertaining or informational media content controlled by brand owners (‘owned media’) is one kind of branded content. Another is brand communications that appear within independently owned, ‘third-party’ media publications, channels, platforms, and social media spaces that are subject to control by parties other than brands. Increasingly brands are sponsoring, co-creating, sharing control, or exercising full control over content in these media. In fact, marketer control over the content, timing, publication, and dissemination of communications is key to understanding the shift to branded content and the forms and practices favoured in ever-changing environments. Media and marketing communications are merging. Marketers like Red Bull and action camera tech company GoPro are becoming broadcasters and publishers, while media increasingly incorporate brand-created or brand-sponsored content. In entertainment media, marketing integration includes advertiser-financed television, product placement, virtual advertising, and advergames. Boundaries between media and advertising are being tested, crossed, redefined, and erased. Pressures on marketers to find effective ways to reach prospective purchasers and pressures on media to attract advertising finance and accommodate marketers are occurring in contexts of disruption and change in markets, in policy, and in creative communications practices and use. Within the overall convergence of media and communications industries and cultures, the convergence of media and marketing is gathering pace across the various dimensions of ownership, work practices and values, cultural forms, and user engagements. The emergence of new forms and practices of integrated advertising raise a host of issues ranging from consumer awareness and acceptance of advertising to the consequences for the media’s editorial independence and creative autonomy.

Advertising and media 5

Branded Content advances the critical study of the changing relationship between media and marketing communications in the digital age. This book examines the forms, evolution, and implications of branded content practices, ranging from brands’ own media to sponsored content and programmatic native advertising. The ways in which marketers are adopting branded content is explored in the context of the ongoing convergence of paid, owned, earned, and shared media. While it focuses on forms of integration (native advertising, product placement), the book also examines how these have developed alongside the disaggregation of media and advertising and the growth of online behavioural advertising and marketers’ ‘owned’ media. This book considers: (i) what is happening; (ii) what the problems are; and (iii) what the prospects are for those problems being addressed. It describes industry practices and their relationship with changing policies. It considers how emergent practices have been ‘normalised’ and it examines where and how problems have been articulated and critiques developed. Before proceeding further, it is important to justify the book’s focus, in the context of a broad-ranging debate, and much scepticism, about what branded content encompasses and what significance it has within existing and emergent marketing communications practice. One response when branded content is discussed is to say that this is nothing new. It is now nearly two decades since Scott Donaton (2004) described the merging of advertising and entertainment in his book Madison & Vine, based on an Advertising Age newsletter that ran from 2002. I like it when people say this since they are inviting us to pay attention to the history of branded content; but, of course, I don’t agree that this subject has been fully discussed, that the cartographers have safely mapped the terrain. Instead, I want to contribute to the excavation and re-evaluation of the historical formations through which branded content has developed and been understood. And, as we will see, branded content can be traced back far beyond the last two decades to the early formation of public communications, if not the birth of human symbolic communication. The integration of paid advertising and publishers’ ‘editorial’ content includes 19th-century ‘reading notices’, and 20th-century advertorials in print publishing. Product placement is coterminous with the birth of cinema, while now extending across entertainment, news, games, post-production virtual placement (Dagnino, 2020), and on to influencer marketing by (micro)celebrities and AI-assistants (Yesiloglu and Costello, 2020). As well as being long-standing, another, contrary, charge is that branded content represents relatively fleeting and ephemeral phenomena. Branded content, native advertising, and associated terms tend to be overhyped, presented by interested parties as solutions to problems marketers face, where the framing of problems and solutions is partial and contestable. Another line of argument acknowledges the growth of branded content but argues it is a short-lived, transitional stage, indicative of more profound changes underway that a focus on ‘branded content’ is apt to misrecognise and misread. By 2007, Scott Donaton (2007) cautioned, ‘We’ve moved past the age of interruption, and even past the age of embedded content and into a model of engagement’. One way to resolve these contradictions is to acknowledge that there are

6 Practices

different temporalities relevant to the discussion and analysis of branded content, across myriad diverse practices. A 2014 review of how far ‘Madison Avenue’ (the New York avenue synonymous with advertising) and ‘Vine Street’ (in Hollywood, representing media and entertainment) had actually merged reported a mixed picture, in which ‘the partnership between advertising and entertainment has become just as imperative and pervasive […] But in other ways, it’s shocking how little has changed’ (Sebastian, 2014). These are important sets of debates that demand clarity, support, and reflexivity in considering the status and significance of branded content practices. Put another way, the debate demands resources from key domains of knowledge, from industry analysis and expertise, from the qualities and resources of academic scholarship and, as this book will emphasise, from a wider range of voices and perspectives across civil society. For now, I offer the reassurance that this book aims to consider how branded content is constituted and constructed across discourses and practices, not assume the status of the object a priori. Yet, it is the argument of this book that a profound convergence is underway between media and marketing. How to understand and assess that convergence is the challenge and focus of this work. Donaton (2004) asserts that the alliance of advertising and entertainment media is a means to repair the damaged business models of both. Branded entertainment is vital to save the media and marketing communication industries. We are witnessing, says Donaton, a fundamental transformation of the business of marketing communications from an intrusion-based marketing economy to an invitation-based model. This represents a shift of power from communicators to consumers. Empowered consumers can bypass advertising messages. The central claim is of a power shift from producers to consumers as the driver of innovation. Donaton (2004: 3–4) writes: ‘innovators who respect the transfer of control and invite consumers to interact with brands on their own terms will survive. Resisters will be trampled.’ I invite you to keep in mind that set of claims throughout, as this book is, in part, an extended review of their merits. Whether we are indeed witnessing a profound shift of power from communication producers to users is among the critical issues this book seeks to assess.

Branded content: Main forms Branded content covers three main areas. The first is brands’ own content (so-called ‘owned’ media) appearing on marketers’ websites, Instagram, Facebook pages, YouTube channels, publications, podcasts, apps, and so on. Some restrict the term content marketing to refer only to brands’ owned media content ‘posted on your own or other unpaid platform’ (Pulizzi, 2015). Next is the ‘native’ distribution of marketers’ paid content: ads integrated into web pages, apps, and news feeds in social media. Much of this is programmatic, part of the increasing automation of advertising buying, selling, and placement (see Chapter 6). One way we encounter this is the sponsored stories on publishers’ websites, assembled by content recommendation companies like Outbrain and Taboola. Native Distribution Ad Units refer to the automated assembling of advertising in online media that is ‘native’ to the environment in which it

Advertising and media 7

appears, such as promoted posts that appear alongside regular posts. There are various types of native formats, including in-app and in-feed advertising; ‘These are ad formats which receive content components such as headlines, images, videos, body texts etc., which are usually formed into real-time within ad units designed to fit within a publisher’s overall style and layout’ (IAB [Interactive Advertising Bureau], 2013). The third kind of branded content is material hosted by, or made by, publishers. This includes advertorials in news media and magazines, advertising-funded programming (AFP) on broadcast or non-linear TV, and promoted or sponsored posts on social media like Facebook, Twitter, TikTok, and Instagram. The term ‘native advertising’ is used to cover both the second and third types of branded content and has been defined as ‘paid advertising where the ad matches the form, feel and function of the content of the media on which it appears’ (Native Advertising Institute, 2015). More broadly, ‘“native” advertising is content that has been designed so it doesn’t look out of place in the habitat within which it’s being viewed’ (ASA, 2020). That term captures the increasing variety of ways in which advertising is intermingled with content in online, mobile, and social media. The aim is to get users to engage with advertiser-sponsored content as readily as they would non-sponsored editorial content. Of these three main types, the first is brands’ own media; the second and third are forms of paid advertising. However, while native is increasingly used to describe digital advertising formats where the marketer exercises control over the communications, in type three, marketers may pay for content without exercising full editorial control. This is then closer to practices, and regulatory definitions, of sponsorship than advertising. For both type two and three, it is the blurring of advertising with editorial, and the confusion about where control over content lies, that generated much of the controversies surrounding branded content.

The changing relationship between advertising and media Digital media is at the apex of two key trends: towards the disaggregation of advertising and media and towards their integration. The characteristic relationship of media and advertising in mid-20th-century media was integration with separation. Advertising was integrated in the sense that it was physically combined with the media product. In newspapers and magazines, adverts appeared alongside editorial; in linear television, spot (or block) advertising appeared in designated breaks within or between programmes. While advertisers controlled their commercial communications, media firms controlled the packaging and distribution of the ad-carrying media. Media and advertising were kept separate on the whole. It may be argued, as we will consider further, that this was, in fact, a short-lived period, between the advertiser-sponsored broadcasting of the early 20th century and the growth of integrated content, such as ad-financed television, from the 1990s. Yet integration with separation reflected norms that ‘advertising – as the major funding system of the mass media – should not unduly influence the non-advertising content’ (McAllister, 2000: 101). There have always been opportunities and pressures to integrate, but the principles of separation were generally upheld by journalists, and by creative

8 Practices

professionals in television, supported by managers, underpinned by self-regulatory codes of conduct in both media and advertising, and subject to stronger statutory regulation in some sectors, such as UK broadcasting. In both ad-dependent print media and television, there was an institutionalised effort to capture the benefits of ad finance while protecting the quality, integrity, and independence of media speech. This drew on a combination of values derived from democratic, consumer welfare, artistic, and cultural concerns. Media and advertising should be separated to ensure that consumers know when they are in a selling environment and to ensure that advertisers should not be the principal arbiters of media content and provision. Media and advertising integration is by no means a new phenomenon and has a long history across all media forms. Yet, arguably the most profound change in the 21st century is that the commercial digital environment has brought increased pressures from marketers met with increased accommodation by media. The emergent relationship is integration without separation. The integration of media and advertising takes various forms, many with long histories, such as product placement, coterminous with the birth of cinema. However, the opportunities and challenges of convergence and digitalisation, not least the struggles to finance an enormous expansion of media, has brought increased pressures from marketers and increased accommodation by media. Product placement, branded entertainment, advergames and infomercials are the most familiar outcomes (Lehu, 2007; Hardy, 2010; 2013). The emergent forms, then, are integration without separation, but this co-exists with trends towards disaggregation of media and advertising. Like integration, disaggregation of media and advertising takes various forms with different consequences. The most challenging feature is that advertising is much less dependent on media vehicles as in traditional models. Advertisers can link advertising to search and users’ activity online so that advertising follows people’s profiles rather than being bundled with media content. The greater range of opportunities to profile, track, and target consumers also diminishes the value and exclusivity of mass media vehicles. Content matters, since it attracts the consumers whom advertisers seek to reach. However, marketers have much greater opportunity to reach consumers without subsidising or accommodating media content providers. The intermediary role of media creating an audience to sell to advertisers is being undermined, in part because the production and distribution of physical goods are expensive ways to reach audiences, and in part because of the advantages of new ways to reach target consumers. When brands can track valued users across their web browsing to whatever pages they load, those marketers have less need and less incentive to consider the editorial context and may instead see benefits in reaching those users in the cheapest spaces on offer, which may be those of clickbait providers rather than prestige publications. As search illustrates, advertising can be connected to media content but flow to search engines. This highlights the decoupling of media production and distribution and the fragmented way in which content is accessed. As Turow (2011: 117) states ‘consumers no longer typically confront media products as unified branded products or programming flows. Many read individual newspapers articles, listen to individual

Advertising and media 9

songs and view individual program episodes unmoored from a “channel” that has been constructed by the content-creating firms.’ So, marketers are less dependent on the intermediary role of media. The affordances of digital communications and targeting are driving marketers to demand that they pay only the actual costs of delivering an advert onto a selected platform (Turow, 2011). The traditional subsidy supporting the news, information, or entertainment surrounding advertisements is diminishing, with profound consequences for communication resources, public media, and cultural pluralism (Couldry and Turow, 2014). While these trends are in some senses diametrically opposed, they both reflect a new shift towards marketer power in an era of increased competition for and dependence on advertising finance. Marketers speak of four main ways organisations communicate and present themselves. PESO stands for paid, earned, shared, and owned media. Traditional advertising means paying to insert advertisements into media vehicles or other advertising spaces (paid). Earned media describes public relations activities to generate editorial coverage. The third area, owned media, refers to marketers’ own content, and here exponential growth has occurred across digital publishing and the production of branded content for online and mobile platforms, which has the effect of also increasing pressures on media for greater accommodation in paid and earned media. Finally, shared media refers to the circulation of marketing communications across social media and online as messages are created, shared, and adapted between users of various kinds, from professional to amateur, including ‘influencers’ like vloggers who can be encouraged to act on behalf of brands along a spectrum overlapping with paid media. The PESO model originates in the work of Don Bartholomew, vice president of digital research at Fleishman Hillard, who developed a metrics matrix for the agency (Yaxley, 2020). PESO was further developed in a blog post by Gini Dietrich (2013) and gained wider recognition through her book Spin Sucks in 2014, with an updated model adding more contemporary media channels and marketing practices (SpinSucks, 2020). PESO is displayed as four overlapping circles, showing the separation, and integration, of paid (advertising), earned (public relations), shared (social media), and owned media (Dietrich, 2013). The model is useful in considering the features of payment, ownership, and control that distinguish each mode, as well as the blurring and convergence occurring between them. Branded content occurs in each PESO circle as well as in converged, hybrid forms where they overlap, and occurs, too, within different gradations of brand control over content, form, dissemination, and context of display. A key limitation of PESO, however, is that it lacks a historical dimension, presenting the modes as a perpetual present. We need to reincorporate history, and consider changes in the rules and regulations governing marketing communications, in order to grasp why the expansion of branded content generates a host of critical concerns from some, as well as enthusiastic support from others.

Media and marketing integration in historical perspective Branded content is old, not new, but it has intensified in the digital era. The phenomena explored in this book have become more significant in scope, reach,

10 Practices

and impact in recent years, and many practices originated only in digital media, but all can be traced to practices with much longer histories. Neither the production of media by brands nor the integration of brands into media are new in themselves. In 1895, the agricultural hardware manufacturer John Deere published The Furrow, ‘a journal for the American farmer’, lauded as a pioneer in brand magazine production a century before content marketing became a buzzword (Gardiner, 2013). In 1900, French tyre company Michelin produced the first Michelin Guide, providing instructions and travel information for motorists: branded content. Expanding its restaurant guide section in the 1920s, Michelin’s three-star rating system has grown to become one of the most highly prized international awards in the industry. Brands associated with specific products have often created, or licensed, other branded products, which in more contemporary terminology is branded content. For instance, the drinks company Guinness launched The Guinness Book of Records in 1955, a Christmas bestselling annual publication for decades afterwards. The tobacco brand Marlboro extended the brand into clothing, shortly before tobacco commercials in US broadcast media were banned in 1971, when the Public Health Cigarette Smoking Act came into effect. Brands have also sponsored media and paid or bartered to feature within or around programmes. Procter & Gamble and Colgate Palmolive sponsored radio shows (from which the term ‘soap operas’ is derived) from the late 1920s as radio became America’s mass audience medium, and then sponsored television shows (Smulyan, 1994). For the TV shows in the 1950s, the soap brand names were announced prominently at the start and end of episodes, accompanied by regular airings of advertising spots negotiated as part of the sponsorship arrangements. Branded content has been described as the ‘re-initiation of long-standing practices such as advertiser-funded programming and product placement’ (Grainge and Johnson, 2015: 38). US radio and TV shows were made by ad agencies such as J. Walter Thompson, which produced 60 hours of programming per week by the 1930s (Kretchmer, 2004: 41). Gillan (2015) examines what she calls ‘content promotion hybrids’ in mid-20th century American television involving product integration and sponsored content. Product placement in movies can be traced back to the Lumière films of the 1890s and was well established in the Hollywood studio system by the 1920s (Newell et al., 2006). The Hollywood studios extracted commercial fees for product promotion and endorsement in movies from the early years of the 20th century. This intensified from the 1930s when studios sent scripts and identified potential promotional opportunities for marketers (Grainge and Johnson, 2015: 38). Donaton (2007) identified the merging of entertainment media and advertising in the 2000s as ‘a return to the product placements and program sponsorships that in fact were the hallmarks of the earliest days of American radio and television’. By the 1930s top advertising agencies produced national radio shows such as Kraft Music Hall (1933–49) by J. Walter Thompson, Show Boat (1932–37) sponsored by Maxwell House Coffee; and The Jack Benny Show (1935– 44) produced by Young & Rubicam for General Foods (Meyers, 2011). With increasing academic attention to promotional industries, the rich histories of

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promotional communications continue to be recovered and re-appraised. One example from the UK is the promotional films made by the GPO (General Post Office) film unit, most famously Night Mail (1936), the only GPO film to be sold for release in commercial cinemas. This 24-minute film ends with a verse commentary written by the poet W.H. Auden to an accompanying score by the composer Benjamin Britten (Grainge and Johnson, 2015: 49).

History and development of branded content: 1990s–2010s So, branded content is old, not new, and subsequent chapters discuss in more detail the antecedent forms and arrangements with traceable lineage to contemporary formats. Yet here the phase of growth of ‘contemporary’ branded content, from the late 20th century, is traced in broad outline, before examining in more detail the key explanatory factors. Branded content sits within the broader histories of modern and especially digital communications. The first online advert appeared in 1993 (Oberoi, 2013). Sponsored search dates from 1998 (Jansen, 2008). An oft-cited originary moment is BMW’s web series of eight ‘mini’ feature films, The Hire, in 2001 and 2002 (Lehu, 2007: 213). Developed by Fallon advertising agency, the series was produced by David Fincher’s production company Anonymous Content at an estimated cost of $25 million (Leibowitz, 2020). With separate directors for each short film, around ten minutes each, the series engaged leading directors and producers, including Ridley and Tony Scott, Ang Lee, John Woo, and Guy Richie, with star actors such as Clive Owen, Gary Oldman, Madonna, Mickey Rourke, Forest Whitaker, and Don Cheadle. The Hire has been described as ‘the first modern branded content campaign’ (Derda, cited in Dzamic and Kirby, 2018: 115) and the ‘first venture in branded entertainment to make concerted use of mobile video technology’ (Grainge and Johnson, 2015: 49). For Donaton (2007), this ‘groundbreaking’ partnership: flipped the traditional marketing model upside down, with the automaker spending the bulk of its budget on production and a fraction of it on the media buy. It also created a form of advertising that consumers would actually have to seek out and download, and then spend 10 minutes or more with. Imagine the boldness of that! Viewed an estimated 45 million times by June 2003, this content strategy required a marketing effort to encourage users to locate and view the films on BMW’s website, and download them, usually overnight on dial-up modems, as broadband access was generally restricted to the affluent in advanced economies and streaming was not yet available (Sebastian, 2014). The return on investment for the strategy is unpublished and, as Donaton (2007) notes, ‘There have always been those who doubted the return on the investment of that deal, but it was a brilliantly bold move and it did happen to coincide with a record sales year for BMW’. Andrew Canter, Global CEO of the Branded Content Marketing Association, describes how he and others saw the opportunities ahead but also the threats. With the rise of the internet, ad-skipping technologies such as TiVo, the commercial television

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industry, and TV ads with it, appeared set to follow the music industry into crisis. As Holt (2016) comments, ‘The rise of new technologies that allowed audiences to opt out of ads – from cable networks to DVRs and then the internet – made it much harder for brands to buy fame. Now they had to compete directly with real entertainment.’ BMW’s The Hire was not only a strategic response to ad-skipping but one of the first brand partnerships with TiVo as part of an innovative distribution strategy that included the BMW Channel on DirectTV (Leibowitz, 2020). In 1999, then an advertising executive, Canter (2017; 2018) describes how television production companies began to pitch ideas and seek to work with agency clients. He worked on what became a series of four threeminute films funded by Microsoft called Living in an E World with branding (‘brought to you by Microsoft’) at the beginning and end. Made in 2000, the films were pitched to publisher-broadcaster Channel Four who featured them in The Slot, a short primetime segment, during National Science Week. Costing £100,000, far below the prevailing costs for TV ad campaigns, Canter was encouraged to offer further content solutions to brands, such as a series of films highlighting the visitor-advice role of concierges for Intercontinental hotels (Canter, 2017). New types of communicators started to appear: content marketers. These emerged from positions within advertising agencies, public relations, media production companies, and from brands’ own marketing departments and services. Such origins shaped practices and identities, as different domains of knowledge vied for ascendency in the rapidly converging space of brand marketing and storytelling. This included what critical figures within marketing saw as hype-generation, rebadging (video producers becoming ‘rich content creators’), re-presentation, and stretching out beyond existing expertise and practices (Dzamic and Kirby, 2018: 5–6; Velocity Partners, 2013). Nevertheless, new practices reshaped businesses. Media production companies, such as the independent Somethin’ Else (2020), moved from radio and TV into branded content. Public relations practitioners, skilled in corporate communications, writing news releases, features, and other storytelling, now vied with others to manage brands’ communication channels and offer creative content production and marketing solutions. Both PR and advertising disciplines were already competing in the emerging space of digital media and social media communications, where blatant promotional content and ‘push’ marketing was seen as increasingly ineffective. Reorganisation to facilitate branded content was occurring across marketer clients, agencies, and media from the early 2000s. For instance, in 2004, Channel Five television (UK) created a ‘specialist, client-facing commercial development division, within the overall sales department … to explore revenue opportunities outside traditional spot advertising’ (Channel Five n.d.). Set up in response to an increasingly fragmented and diversified broadcasting marketplace, this was developed to explore the emerging markets of sponsorship and mobile to integrate into Five’s core business. We will examine definitions further below but the rise of buzzwords associated with ‘content’ takes off from the 2000s, and by the 2010s ‘content’ was ‘becoming the industry descriptor of choice’ (Bryant, cited in Grainge and Johnson, 2015: 23) and ‘the dreaded buzzword’ (Weise, 2011). The UK branch of Mindshare held its annual meeting on ‘the future of content’ in November 2012. The ‘institutional’ organisation

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of branded content occurs from the early 2000s. The Branded Content Marketing Association (BCMA) was established in 2002 in the UK. The Content Marketing Association (UK) was created in 2012 as a rebranding of the Association of Publishing Agencies. In 2013 the New York Times ran its first native ad. Alongside the practices (e.g. industrial organisation), discursive (e.g. trade media), and wider institutional (e.g. trade and professional body) formation of branded content was the role of competition and award ceremonies. The most prestigious international award event for advertising, Cannes Lions, introduced its ‘Branded Content & Entertainment’ category in 2012. By 2016, the growth of that award category led to its replacement by an entire sub-festival, Cannes Lions Entertainment. In 2015, the first Brand Film Festival was held in New York. Now an annual event, the festival showcases branded content films, from YouTube videos to long-form documentaries, and is organised by the publisher Haymarket Media. The Interactive Advertising Bureau (IAB), a US-headquartered organisation with national and regional subsidiaries, published the Native Advertising Playbook in 2013 and a revised version in May 2019 (IAB [Interactive Advertising Bureau], 2013; 2019). As well as updating native ad format classifications, the 2019 report took stock of changes. In 2013 only a ‘few dozen’ publishers invested in native while in 2019 ‘nearly every publisher’ had a dedicated content studio for native advertising. In 2013 there were no industry specifications and only a handful of operators involved in programmatic native advertising. Paid advertising on social media was a mere 10 per cent of total digital ad revenues, with most brands producing for their own organic (non-paid) posts: ‘Publishers could distribute content for free and garner significant engagement’ (IAB [Interactive Advertising Bureau], 2019: 4). By 2019, paid social was 25 per cent.

Definitions Branded content has been hailed as the future for marketing communications. More accurately, branded content is one of a multiplying number of terms associated with a set of claims about the future for marketing and media. These include content marketing, native advertising, programmatic native, brand journalism, sponsored content, paid content, and other terms whose definition and usage we will examine. All these buzzwords refer to informational and/or entertainment content that is sponsored by marketers. Yet these terms lack precision; they have been used in a variety of ways amid ongoing debates about their meaning and usefulness, with some deriding the term ‘content’ as hopelessly vague and all-encompassing. Nevertheless, content marketing was voted word of the year for 2015 by the US National Association of Advertisers (ANA, 2015), followed by programmatic and storytelling. Content marketing is ‘the discipline of creating quality branded editorial content across all media channels and platforms to deliver engaging relationships, consumer value and measurable success for brands’ (Content Marketing Association, 2017). It has also been described as ‘a straightforward sounding – yet truly vague – way to describe the means through which advertisers get people to spend time watching or reading “content” that has been paid for by an advertiser’ (Einstein, 2016: 2). Let us start with some definitions.

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Branded content A research initiative by the Branded Content Marketing Association, IPSOS Mori, and academics (Asmussen et al., 2016: 34) led to this definition: From a managerial perspective, branded content is any output fully/partly funded or at least endorsed by the legal owner of the brand which promotes the owner’s brand values, and makes audiences choose to engage with the brand based on a pull logic due to its entertainment, information and/or education value. A simple definition is content that is produced or funded by brands. Branded content is a broad and encompassing term covering activities including advertiserfunded programmes, advertorials, advergames, branded entertainment, custom publishing, events, experience, native advertising, product placement, and sponsorship. Branded content encompasses all types of media: audio, audiovisual, visual arts, music, theatre, and performance.

Content marketing The Content Marketing Institute (CMI) defines content marketing as: ‘a strategic marketing technique of creating and distributing valuable, relevant, and consistent content to attract and acquire a clearly defined audience – with the objective of driving profitable customer action by changing or enhancing consumer behaviour’ (Pulizzi, 2015). A key distinction is made between content on brands’ owned media (content marketing) and content that is paid communication in third-party media (native advertising). ‘With content marketing, [your] stories are found on your owned media properties. With native advertising, you pay vendors to distribute your stories across channels they own and manage’ (Shiao, 2019). CMI founder Joe Pulizzi (2015) describes content marketing as the provision of content that ‘is valuable and relevant, designed to attract a clearly defined audience, and posted on your own or other unpaid platform’. However, having distinguished this from paid advertising [including native advertising], Pulizzi then reincorporates payment within content marketing: ‘Now, this doesn’t mean you shouldn’t pay to promote your content as part of your content marketing strategy. If you don’t have an audience that is subscribed to receive your content, you should look into paid media as a way to reach a targeted audience’. So payment can occur within a content marketing strategy, rendering the demarcation indistinct. The main effort is to associate content marketing with owned media and native with paid: ‘Content marketing is an ongoing process that is best integrated into an overall marketing strategy. It focuses on owning media, not renting it. In content marketing, the brand owns the media’. Despite the CMI’s efforts, content marketing is widely used to cover both brands’ own and paid communications, with definitions offered that are indistinguishable for other terms such as native advertising. For instance, consumer content marketing is defined by PQ Media (2018) as ‘Paid marketing messages developed to

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simulate a news story or entertainment program that is cohesive with the media’s content structure, including assimilated design that is consistent with the media platform’.

Native advertising A core definition of native advertising is as follows (IAB [Interactive Advertising Bureau], 2019): Native advertising is a concept encompassing both an aspiration as well as a suite of ad products. It is clear that most advertisers and publishers aspire to deliver paid ads that are:   

so cohesive with the page content, assimilated into the design, and consistent with the platform behavior … that the viewer feels the ads belong there.

The description itself is identical to the 2013 version apart from a subtle but significant change. The 2013 version reads ‘[so] that the viewer simply feels that they belong’ (IAB [Interactive Advertising Bureau], 2013: 3). The 2019 version emphasizes viewer recognition and acknowledgement of the ad status of native ‘feels the ads belong there’. This reflects an overhaul of the approach to demonstrate full compliance with Federal Trade Commission (FTC) requirements on the disclosure of native advertising (Chapter 7). Sharethrough (n.d.) defines native advertising as ‘a form of paid media where the ad experience follows the natural form and function of the user experience in which it is placed’. The definition combines form (‘Native ads match the visual design of the experience they live within, and look and feel like natural content’) and function (‘Native ads must behave consistently with the native user experience, and function just like natural content’). The IAB [Interactive Advertising Bureau] (2019: 14, 5) now presents ‘Branded/Native Content’ as the category term for ‘a core native ad type’, incorporating ‘brand content’, ‘sponsored content’, and ‘custom content’: Branded/Native Content is paid content from a brand that is published in the same format as full editorial on a publisher’s site, generally in conjunction with the publisher’s content teams themselves. The content itself is, therefore, part of the native ad buy and should be considered as a native ad type. Around these core terms are myriad other terms, some adding specialisms, others competing terms for the same or overlapping practices. Branded entertainment is defined by PQ Media (2018) as ‘Non-traditional marketing that blends brand messages with entertainment or information to engage consumers, build brand awareness and create positive brand associations to drive consumer sales’. A more recent addition is the term unbranded

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content, used to describe paid communications by brands that are devoid of any apparent branding. Advertising with little or no evident branding can take ‘many different forms, including putting out unbranded content that has no discernible link back to the advertiser, to “prime” online and consumer conversations’ (Roxburgh, 2016). Branded content is associated with advertising and para-advertising communications, and that is the main focus of this book, but we will also identify the breadth of practices that are or can be encompassed, not least as these affect the understanding and evaluation of branded content. Forrester Research (2016) identifies two types of approaches in content marketing: one that supports brand advertising goals (media-led), and one that supports direct-response goals (customer-led). For Dzamic and Kirby (2018: 44) this approach risks undervaluing the enormity of a ‘client-driven shift from marketing to customer experience’. They emphasise connections between ‘content’ and strategies of Consumer Experience Management (CEM or CXM) defined by Gartner (n.d.) as: ‘the practice of designing and reacting to customer interactions to meet or exceed customer expectations and, thus, increase customer satisfaction, loyalty and advocacy’. Drawing upon concepts of user-experience (UX) and ‘attention economy’ (Davenport and Beck, 2002), as well as CEM strategies, they highlight the development of a ‘more human-centered experience design “mindset” based around time that helps distinguish Content as an approach from more interruptive marketing communications such as advertising’. Dzamic and Kirby (2018) discuss the evolution of brands’ own content, from postsales brand publishing, such as loyalty magazines published directly by brands or contract publishers, to brand communications right across customers’ ‘journeys’, including pre-purchase engagements, and with the product experience no longer the required focus in such engagements. This perspective is vital, not least to expand the historical account of branded content to encompass the breadth of brand marketing and communications. Print was a relatively cost-effective way to deliver a post-sales experience to an audience marketers knew how to reach, with permission. In the digital era, ‘brands can now reach, engage and subscribe audiences pre-purchase too’ (Dzamic and Kirby, 2018: 52). However, this is a broader focus on brand marketing and the communication dimension inherent across all forms of marketing. It is the intersection of brand communications with non-brand communication channels that is the distinctive feature of branded content that raises critical concerns, and is the focus of this book. However, while communications is always a dimension, branded content encompasses brands’ association with events and experiences. The phenomena of branded content cannot be fully understood through a media-centric account alone, and this book addresses event and experiential content strategies that have their own range of definitions (PQ Media, 2018).

Definitional debates Changing definitions of the emerging forms of branded content reflect not only the technological development of new forms but also the reconfiguration of

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industry practices, cultures, and values, and, crucially, sensitivities about the presentation of practices and values to stakeholders. Usually, definitions are developed to serve industry stakeholders, in particular the sellers and buyers of services, although which industry sectors and identifications are addressed always matters. Definitions can also reflect the influence of other stakeholders and seek to promote to or assuage concerns from other industry sectors and actors, those with influence over governance, and directly or indirectly consumers/users. Definitional debates show competitive struggles for definitional advantage; promotion of valued knowledge and capabilities by individuals, firms, professional bodies, and other groupings; tensions and antagonisms between different actors, values and professional arrangements; exasperation, including at imprecision, misuse, serviceability, influence, and usage of definitions. For example, Joe Pulizzi (2015), founder of the Content Marketing Institute, describes branded content as ‘a word created by the world of paid media … by advertisers, agencies and media planners … Simply put, branded content looks and feels like advertising. If it looks like a duck and walks like a duck, well …’ (cited in Dzamic and Kirby, 2018: 44) The most contentious term of all in this context is probably ‘content’. Critics argue variously that the term is vague, vacuous, empty of, well, content. It is considered as a term that disguises the persistence of older marketing practices (hype 1). For one marketer, ‘Today we are buried in the broadest possible interpretation of “content” with little clue to the motivation behind its creation. Much of it is nothing more than thinly-veiled traditional market messaging delivered through a new channel’ (Conticchio, 2017). It is associated with being ‘dressed up’, making more grandiose claims than are warranted (hype 2). One analyst warns, ‘Some marketers avoid – even loathe – the term “branded content” because it “gives agencies permission to keep talking about themselves, adding a bit of storytelling to product pitches”’ (Johnston, 2018). Another key charge is that it is an effort to transfer to marketing communications the higher value qualities associated with media (hype 3). It is an effort to present advertising as something grander, more relevant and appealing, with the same qualities as entertainment or news and information associated with media. Donaton (2007) considered the phrase ‘branded entertainment’ began to be used from around 2002 but subsequently ‘has been ill-defined and abused beyond recognition’, either unduly narrow and referring only to product placement, or broadened to encompass any form of entertainment marketing, including promotional tie-in merchandising. However, he argues the lack of clear boundaries has helped to provide the necessary flexibility for rapidly evolving media and marketing conditions, even while giving ‘ammunition to those skeptical of its legitimacy, its accountability and its role in the marketing mix’. For PQ Media (2018), ‘Branded entertainment aims to capture the consumer’s attention and elevate a brand’s image by associating it with popular personalities, media brands, organizations or events, such as TV characters, news outlets, sports teams, and activation. All branded entertainment is aimed at consumers, not business-to-business end users.’ So, it is not surprising there have been efforts to foster greater definitional precision by naming and differentiating specific practices. Ogilvy CEO Miles Young

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in 2011 divided branded content into four main categories (cited in Grainge and Johnson, 2015: 39): Leveraged content; Sponsored content; Partnered content; Originated content. The BCMA (Canter, 2012) identified six variants: Branded entertainment; Advertiser-funded programming; Short or long form branded vignettes; Brand storytelling; Branded content partnerships; Brand integration. Alternatively, there are strong defences made for terms that can encompass the range and fluidity of practices and can be used to refer to qualities and values over fixed forms. Native is a philosophy, not just format, argues Verizon (2019: 4), US telecoms company and online content publisher in its State of Native report: It’s a philosophy. A belief that ads shouldn’t sit still. There’s no single definition of native advertising, and that’s what makes it so unique. Native is fluid, taking many forms from sponsored articles and videos to in-feed posts to more dynamic ad experiences. Native has the ability to transform your existing assets into thousands of unique ads – perfectly adapted for the way we experience content. Its versatility allows it to change and adapt over time to match what people want in specific moments of intention. The report does, however, offer a standard definition, too: ‘the biggest differentiator between native ads and standard ads is the ability of native to follow the natural form and function of the environment in which it is placed’ (Verizon, 2019: 4). Against that expansive and positive gloss, it can be argued that ‘native’ serves as a more palatable substitute for advertising. Even though this is predominantly located in inter-industry discourse, the account offered also serves messaging aimed at users, policy networks, and/or non-industry stakeholders. ‘Native’ suggests an industry that is repositioned to be fitting, responsive, and welcomed by consumers. The term ‘native advertising’ has expanded to the point that it has become a substitute for ‘display advertising’. It is used to describe (and calculate) advertising formats on mobile and social media. In such usage, the ad formats that share space on digital apps and platforms are regarded as ‘native’ by type. This indicates how the label native has become a more palatable, in some contexts essential, way to signal noninterruptive advertising. It also erases differences in the form and quality of adverting and so displaces the characteristics of ‘interruption’ that remain all too present across mobile and social advertising. The massive growth attributed to native includes online ad formats, the vast majority of which have more ‘ad-like’ features than ones that are genuinely ‘native’ and blended into the format. There is a claim that ads appearing in mobile are intrinsically native, fitting the flow of dynamic content. Yet, included in this much more overarching label native are numerous varieties of ‘push’ advertising (Chapter 5). These may lead to further content being pulled, but they are as pushed, placed, and uninvited as the advertising formats they are hailed as replacing. In this context, there is a useful definitional delimiting offered by the IAB in their distinction between items that promote content, which they describe as ‘native’, and the content itself, which they describe as ‘sponsored content’ (Adshead et al., 2019).

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Accordingly, the various forms of advertising that direct users are ‘native’, defined as ‘Advertising integrated into the surrounding content, predominantly in-feed advertising such as promoted posts in social feeds or paid-for recommendations on webpages’ (Adshead et al., 2019: 6). Such ads direct users to sponsored content which is defined as ‘Advertiser-sponsored content on a webpage or app such as in ad-features/advertorials’ (Adshead et al., 2019: 6).

The rise of branded content: Factors and explanations Like most complex phenomena, branded content practices are multifactorial. Further, although there are commonalities, branded content is the umbrella term for highly diverse relationships between marketing finance and marketing purposes with communications and activities that themselves take diverse forms. Different practices occurring across different platforms, different market conditions, and different histories of institutional arrangements mean that in each instance there are multiple, common, and specific factors influencing outcomes. Yet, underlying the growth of branded content are the opportunities and challenges arising from transformations in digital communications. The migration of users from legacy media to new digital sites and activities has continued to disrupt all marketing communications and pose a rapidly shifting mix of challenges and opportunities. The opportunities have included the cost efficiencies and marketing effectiveness associated with the creation and dissemination of both owned and paid (native) media and the associated user data. The key challenge, and a driver for brands shifting spending to branded content, has been the increased opportunities for users to avoid traditional advertising formats. The fear of ad avoidance for television viewers began long before digitalisation, with the TV remote control allowing zapping and channel-hopping, and videocassette players allowing viewers greater control (McAllister, 1996). In the 1990s the creation of set-top boxes such as TiVo and the rising use of digital video recorders (DVRs) stoked fears of more far-reaching ad-skipping, prompting greater attention to product placement and embedding ads in content, advertiser-financed productions, and audiovisual branded content. Yet, the subsequent shift from the 2000s to online viewing reduced opportunities for interruptive ads in programme breaks. In the pre-digital world, the model for much media publishing and commercial free-to-air (FTA) television and radio was one in which media offered content that could attract audiences, with access to those audiences sold to advertisers via advertising agencies (Sinclair, 2015: 43). What has occurred is a series of pressures on those traditional, ‘legacy’ media as vehicles to carry advertisements. In each case, there are different pressures and responses but the common feature is weakening of the pre-digital advertising carriage model. In television, there has been a deeper shift of revenue from advertiser-funded freeto-air TV towards pay subscription. In most advanced economies, pay TV revenues are now greater than advertising revenue for FTA channels. In Spain, for example, pay TV revenue (including advertising) is now just ahead: Pay TV brought in €564 million, with free-to air TV earning €560 million in the fourth quarter of 2017

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(Advanced Television, 2018). This shift has been accompanied by a further rise in brand presence within programmes, notably product placement (PP). Consumers increasingly expect to view video without adverts when they pay for video services like Netflix and Amazon Prime Video, but marketers can use product placements. Research shows that 100 per cent of Amazon’s original programming contains brand integrations, 91 per cent of Hulu originals, and 74 per cent of Netflix originals (Tran, 2018). For filmed entertainment, the rise of home entertainment cut into profits from cinema exhibition while film production and marketing costs soared. Donaton (2007) writes: the ad business and the entertainment business, which decades ago established outposts on separate coasts of the U.S. and mostly operated independently of each other since then were suddenly compelled towards each other. They realized that they had the potential to help each other out. If nothing else, the advertisers had the money and the entertainment companies had the creativity and the attention of audiences. According to PQ Media president Patrick Quinn (PQ Media, 2018): The continued growth of branded entertainment marketing is in sharp contrast to the weaker growth of traditional advertising and marketing platforms, such as live television, newspapers and direct marketing. […] younger demographics are moving away from traditional media platforms, while major brands are proactively seeking alternative media channels to engage these more mobile, tech-savvy younger audiences. PQ Media (2018) predicts that ‘strong desire to gain brand awareness among target consumers, create positive brand associations and, ultimately, produce sales lift will continue to favor branded entertainment marketing worldwide over the next five years’. Television remains the dominant market for advertising in most national markets, but ad-funded linear TV, as opposed to on-demand, is slowing or declining in most advanced economies. As well as driving integrated PP advertising, there has been a more recent rise in over-the-top (OTT) advertising, usually short 30-second-or-less ads inserted into video content (Swan, 2020). Overall, the share of advertising is shifting to the internet and mobile platforms and the advertising types with strongest growth are branded content: mobile and online programmatic native advertising, and video. Integrating advertising is also integral to the business models of the major social media platforms (Fuchs, 2014). Social media allows brands to have direct communication with consumers, often at a fraction of the costs associated with TV campaigns, and in formats that are much more immediate to produce, test, amend, and publish to encourage engagement and sharing. Native is suitable for mobile, social media, and video contexts. The latter includes short and longer form content for

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brands’ owned media and for in-stream video ad formats. Nick Hugh, vice president of EMEA, Yahoo contends native advertising is ‘a creative and measurable format which works effectively on smaller screens […] a scalable solution for publishers and importantly provides a contextual and relevant experience for consumers’ (Hammett, 2016). In publishing, the decline in print readership, especially among the young, has reduced the value and effectiveness of display advertising. With digital advertising required to subsidise commercial journalism, the poor performance of some ad formats has been a problem for both publishers and marketers alike. Declining click-through rates and ‘banner blindness’ encouraged advertisers to test other formats, such as pop-ups and interstitials, and then animated advertisements, pre-roll, and other video formats. These formats, though, have also generated negative responses from consumers and ad avoidance strategies, most notably ad-blocking. This has been amongst the factors leading to a rise in advertising integrated into content and ‘disguised’ or ‘camouflaged’ to blend into editorial environments. In digital media, so-called banner blindness and the notoriously low click-through rates for banner ads prompted efforts to develop more attractive and effective ad formats. These were also responses to the practices and implications of the growing adoption of ad-blocking. According to the Internet Advertising Bureau [IAB UK] (2019: 4), the topic of ad-blocking ‘exploded in 2015–16’, leading to investment in ‘ad formats that put the consumer experience first, including LEAN/DEAL ads and more emphasis on nonintrusive storytelling experiences (native)’. In publishing, ad-blocking contributed to already well-established patterns of decline in advertising revenue. As the managing director of the Association for Online Publishers (AOP), Richard Reeves notes: ‘As the loss of publisher revenue continues to increase due to ad blocking, there has been a growing demand for engaging and interactive ads that don’t disrupt the user experience, which content marketing and native formats can provide’ (Internet Advertising Bureau [IAB UK], 2018). Branded content, in its contemporary digital forms, also originates in brands’ owned media, from the publishing and page model of the early internet from 1994, and dubbed Web 1.0, through to the more interactive architecture associated with Web 2.0 and beyond. As Conticchio (2017) writes, ‘A great deal of what we now call “content marketing” can be traced back to basic business blogging where a brand built audiences by attracting informed search to valuable, relevant content. It created a limited, but specialized and highly-engaged inbound market where relationships were built based on trust and shared interest.’ So, branded content is a response to problems of reaching target audiences. It is also a response to changing audience behaviour. And here Donaton (2004) and others are right to describe growing user resistance to advertising and in particular interruption advertising. A survey by branded content marketing firm the McCarthy Group (2014) found that 84 per cent of millennials don’t like or trust traditional marketing. Verizon (2019) conducted survey research in 2017 which found that 86 per cent of respondents found digital advertising intrusive. The report goes on (Verizon, 2019: 2):

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There is one ad experience that continues to break the mold: native. Designed for change, native has the unique ability to evolve at the pace of the internet and redefine the ad experience while matching the look and feel of its surrounding content. We will investigate these claims further but the presentation of consumer resistance to traditional advertising as the driver for more effective strategies including branded content is broadly shared by industry and academics alike. Industry commentators expressed, as fear and then increasingly as common sense, that the era of ‘interruption’ advertising was becoming unviable. Users had greater control over their communications than ever before, and ever-increasing choice of content and activity online, so that the power of advertisers to ‘interrupt’ media consumers was evaporating. For instance, research by IPG Mediabrands found 65 per cent of US consumers skip online video advertisements, of whom 76 per cent skip out if habit, with people, on average, watching 5.5 seconds of a 15-second ad (Handley, 2017). Such fears only increased with the seemingly ready adoption of ad-blocking software solutions. Branded content has developed in response to an actual, and perceived, crisis of effectiveness in advertising, as established forms fail to hold people’s attention, with skipping, blocking, banner-blindness, cynicism, and resistance to persuasion, and the relocation of audiences to communication spaces where ad formats are eschewed in various ways (Sullivan, 2013; Donaton, 2004). ‘Branded content has emerged as an effective means for marketers to reach audiences not only at scale but also while they are in an engaged state of mind and more receptive to brand messages’ (Fulgoni et al., 2017: 363). So, branded content has developed, in part, in response to changes in user behaviour, attitudes, and media consumption affecting advertising effectiveness. The attractions of branded content for marketers include providing relevant, valued messages, increasing consumer engagement, building awareness, and generating buzz. For the US Association of National Advertisers (ANA, 2015): The main benefit of native adverting is the ability to create extremely relevant associations between the brand and consumer via content. Given today’s media landscape, where consumers can avoid ads more than ever, advertisers are looking for new ways to get their messages noticed and acted upon. Disarming resistance underpins, and is used to explain, strategies to win consent, either by being welcomed and valued, or by being embedded or disguised. This is the focus of Serazio’s (2013) groundbreaking study of the turn towards guerrilla marketing and other critical academic work we will examine, as well as the invocations of an immense volume of affirmative business literature, including Donaton, which can be summarised as follows. Marketers must learn to be invited. A variety of terms signal this shift from ‘push’ to ‘pull’ marketing, and from outbound to inbound. For Donaton, we are moving into ‘a world where the audience will determine what, whether and where they will interact with any form of content’ (Dzamic and Kirby, 2018: 118). According to this widely endorsed view, the

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power to control access to advertising has shifted from content providers to content receivers. The latter are increasingly impatient of or alienated by ‘interruptive’ advertising, and future success depends on providing content and services in forms that people will willingly select and engage with. In industry jargon, ‘Inbound marketing is a marketing methodology that is designed to draw visitors and potential customers in, rather than outwardly pushing a brand, product or service onto prospects in the hope of generating leads or customers’ (Optimizely, n.d.). ‘Often the growth in native advertising is negatively depicted solely as a consequence of the rapid decline in effectiveness of traditional banner ads’, argues Chris Payne of the World Federation of Advertisers. What is often forgotten is that this is itself a consequence of a shift in consumer demand from advertisers, driven by the proliferation of social media and other online platforms. It is this change in demand which the industry is reacting to; in the future minimal disruption and maximum engagement will be key. (International Chamber of Commerce, 2014) For Donaton (2007), ‘branded entertainment’ was born out of fear of ad avoidance, but has subsequently developed ‘a more confident and more creative position’, which he dubs ‘Branded Entertainment 2.0’: ‘one based on the concept that consumers will accept good content from any source so long as it is transparent, entertaining or informative, and relevant’. According to Andrew Mole (2016), strategy director at native advertising firm Platform 360: Audiences these days, especially younger Millennials, are super adept at seeing through cheap efforts to sell to them. If brands want to engage they need to be authentic and subtle. […] Bespoke native allows brands to create a positive, informative and interesting experience for the consumer without being forceful. When people see that a brand has given them credibility by creating a great experience, they repay that trust with their attention. For the US Association of National Advertisers, ‘The main benefit of native adverting is the ability to create extremely relevant associations between the brand and consumer via content. Given today’s media landscape, where consumers can avoid ads more than ever, advertisers are looking for new ways to get their messages noticed and acted upon’ (ANA, 2015). In social media, brands seek to connect in similar ways to the way users connect and share with friends – one way in which brands seek incorporation into daily life (Serazio, 2013). User-generated content and social media usage contributed to the declining audiences for and effectiveness of traditional advertising. In various ways, these were spaces that could reflect, amplify, and benefit from the distrust of advertising that was part of their appeal. Yet, like the internet overall, they were colonised by commercial forces and became vehicles for both digital advertising and branded content. Here, the rise of branded content in the communications of social media

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influencers follows core insights from public relations on the value of trusted ‘thirdparty’ endorsement over brands’ direct claims (advertising). People are more likely to take recommendations from someone they trust – a friend, celebrity, thought leader, or anyone perceived to be able to offer valued experience, knowledge, or expertise. As one marketer describes: Users are far less likely to follow a product on social media than they are to follow a celebrity. But if an influencer just so happens to be using my product in his/her feed, then you’ve skipped the middleman altogether. Fans trust their idols, so seeing stars aligning themselves with a particular brand is the ultimate in product placement success. (Pfund, 2018) The use of third-party endorsement to inform and persuade, a classic definition of public relations (Tench and Yeomans, 2017: 272), has been turbo-charged as the vehicle for brand communications by social media influencers. Influencers can offer the most persuasive, personable endorsement for brands and do so across the blurred lines from paid promotions and product placement, to so-called organic mentions, opinions, or image endorsements that are ‘freely’ given. Just as brand spending to reach younger demographics has shifted from legacy media vehicles to social, so too the orientation of branded content practitioners. The embedding of brand talk and image with influencer communications that have qualities of trust, authenticity, and independence engages all the problems outlined above, with added features. Not only is the nature of the communication less clear, but so too are the responsibilities. In professional ‘mass communication’ environments, there are expectations and cultures of compliance with relevant rules. In the pro-am world of influencers such arrangements are less assured. The relative confusion over rule adherence, compliance, and accountability is also exploited for strategic purposes in an emergent sector that ranges from professional influencers supported by staff team, agents, and advisers, to individual vloggers, building up the followers to attract platform and marketers’ attention. A key challenge and tension, which runs throughout branded content, is when paid communications risks undermining trusted communications. ‘If a consumer knows the influencer’s motivation for endorsing a product is at least partially motivated by cash or getting free stuff, the consumer may not take a recommendation the same way as if it was given out of the endorser’s pure adoration of the product’ (Mathes, 2018). Yet as we will examine, there is plenty to reassure marketers as well as their critics. There are technological factors and their related institutional and practice-based aspects. It is now much easier to assemble marketing content, test it, and respond and adapt it. Formatting ‘native’ ads to match the surrounding content, or reassembling programmatic native ads based on response data, is increasingly easy, inexpensive, and automated. Marketers can manage processes through programmatic advertising, real-time billing, and automated market transactions, aiding both

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in-house marketing teams and agencies. This is advertising that allows interaction with users in real time. Native ad formats can also evade the increasingly mainstream use of adblocking software used to block banner ads, pre-roll video, and other formats. Adblocking software has proved particularly popular with mobile users annoyed by advertising slowing page load times and affecting charges for those on fixed data tariffs, as well as those objecting to being tracked for marketing purposes (Fuchs, 2014). A final key factor has been shifts in governance, occurring across formal regulation and professional norms (Chapters 7, 8). The expansion of branded content, then, is multifactorial, within and across diverse communication sectors, and these factors mutually interact in dynamic ways to influence specific practices. To provide a full explanation of branded content, we need a political economic analysis. So far, some of the economic dimensions have been outlined, namely the reorganisation of businesses and institutional arrangements in response to market pressures and imperatives of capitalist growth. The political dimensions are also vital. What are often perceived as ‘natural’ market forces are the outcome of decisions and arrangements that enable and constrain how market actors behave and interact. Branded content is conducted within a regulatory environment that is subject to political control and influence. The critical political economy approaches on which this book draws, does not see the economic and political as separate spheres but as intertwined and mutually constitutive.

Digitalisation and internetisation The development of branded content can only be understood in the context of the interface and dynamic interaction of technological innovation and affordances with the conditions in which they developed and their co-development. Those conditions are powerfully shaped, if never solely determined, by the political economy, understood as the organisation and influence of political and economic forces. These political and economic forces are always influential and involved in social, cultural, institutional, regulatory arrangements and processes, but the latter are not reducible to explanations derived from political and economic forces alone. From the expansion of the commercial internet, browser interfaces and domestic access after 1993, the main features of digitalisation and internetisation have been the growth of digital advertising; shifts of ad spending and ad formats from traditional advertising formats; marketers seeking to follow (or lead) users to new ad-carrying channels; the evolution of new kinds of automated advertising production and placement; the erosion of ad revenues for legacy media; and the shifts of ad revenue to platforms. The shifts in the production of advertising online is rightly a major focus. However, arguably the greater impact of internetisation has arisen from the expansion of marketer-controlled media, of brands’ ‘owned’ media. Here, the patterns of growth of branded content map onto broader changes in internet architecture and services identified, and espoused, in the nomenclature of Web 1.0, 2.0, 3.0, and beyond. In Web 1.0 from the early to late 1990s, brands started to

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develop a web presence of owned media. The push content of Web 1.0 ‘pages’ then incorporated the interactivity of wikis and early social media in Web 2.0, a term devised by a marketing practitioner seeking to reboot confidence in web investment after the dot.com stock crisis (Hardy, 2014: 131–2).

Industry (re)organisation Branded content needs to be understood in the context of evolving political economies affecting relations between advertisers, marketing agencies, media publishers, and platforms (Sinclair, 2020). Later chapters examine changing industrial arrangements in greater detail, but here some broader features can be identified. A core triad of actor types remain: marketers, marketing agencies, and media, around which an expanding range of intermediary actors provide specialised services, and where activities from the triad are combined. Marketers are conducting more marketing in-house and connecting with the advertising networks and services provided by increasingly dominant platforms, both of which are squeezing and reshaping the activities of marketing agencies, alongside a host of competitive pressures. Creative content production, and its interconnections with brands, agencies, and media, is now carried out by an everincreasing range of actors, from Instagram influencers to brands’ own content studios. Further, the core actors themselves incorporate hybridity by offering services historically associated with other institutionally constituted actors. Finally, all processes are affected by automation so that there is a proliferation of actor-types, services, and interactions. This includes the rise of adtech and the firms involved in programmatic advertising buying, selling, creation, distribution, and promotion. The rise of automation, algorithms, and other computer-based processes require that deeply entrenched ways of identifying and discussing actors need to be questioned and reconsidered. The challenge of mapping the emerging media–marketing ecology is to trace what has replaced the more settled relationships between marketers, agencies, and media today. The integration of media and marketing is occurring across corporate ownership and networks, operations and practices, forms and formats, and user engagements. The interaction and competition between creative advertising agencies, media agencies, PR and various digital agencies is a key locus for the birth and development of branded content (Chapter 6). Yet, while these battles churned up the sedimented institutional identities, histories, and practices of different actor-groups, there has been mounting disruption from new digital actors – the platforms. This is most starkly demonstrated by the dominance of Google and Facebook across digital advertising, taking an enormous share of revenue from the fastest-growing advertising forms. Together, Google and Facebook took more than half of the total global internet advertising revenue in 2018 (Sinclair, 2020). These companies now control and manage the marketplace itself. They control the architecture and provide the services for the market to function; they own the advertising exchanges that control ad buying and selling (Chapter 5). Moreover, they are expanding into all parts of the value chain, from creation of communications to user purchase. They control the data that drive targeting and monetisation. They control the ratings systems. They each offer rival

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proprietary standards but oversee an oligopolistic market so far ahead of rivals that for more than half of the total market they rule as duopolists.

Summary So, the rise of branded content is multifactorial. There are multiple drivers, as seismic shifts towards digital communications, and ad-avoidance, have created opportunities and obligations for marketers and media alike. Marketers have sought to offer ‘non-interruptive’, engaging content that users will spend time with and share, influencing brand recommendations. The prevailing view across communications industries is that branded content is a necessary response to ad evasion that, ‘done well’, can provide targeted and valued content to consumers. It is certainly on the rise. According to PQ Media (2015), content marketing worldwide grew by 13 per cent in 2014 to $26.5 billion. For the broader category of branded entertainment, the global market increased by 8 per cent in 2017 to $106 billion, growing at twice the overall rate of advertising and marketing revenues (PQ Media, 2018). The rate of growth has also been remarkable. There was a 50 per cent growth in native advertising spending in the US between 2016 and 2017 (Sterling, 2018). However, it is important to distinguish the varieties of marketer spending carefully. Sponsored content accounted for £124 million out of total digital display expenditure of £4.1 billion in the UK in 2017 – 3 per cent (Adshead et al., 2019: 38). The common explanatory factors, suitable at least approximately across EuroAmerica, can be summarised as follows.

Media and marketing businesses ‘Crisis’ for ad-financed publishing; increased dependency on advertising opportunities for marketers; reorganisation of marketing services to platform management and control. Publishers: way to distinguish their ad offering in highly competitive internet ad markets; finance media; monetise users. Advertisers and agencies: ‘more bang for their buck’ – native seen as more effective than traditional ad formats (and can evade ad-blocking). Consumers/users: Changing media habits and attitudes, communication consumption/use, and ad avoidance create challenges (and opportunities) for marketers; response to changes in media consumption affecting advertising effectiveness. Technical: increasingly easy and inexpensive to format ads to match the surrounding content. Regulation and professional norms: more permissive (Chapters 3, 7–11).

Media and marketing convergence Media and marketing communications are merging and converging. Branded content in all its forms is part of that ongoing convergence and it is a reconfiguration with enormous significance for communications. Yet even this is very far from the totality of

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media or marketing communications, as the linked trends towards disaggregation and integration of media and marketing illustrate. Branded content, as outlined, has a long history. Moreover, attention to historical origins and developments, and to continuities and discontinuities, is vital both for understanding and for assessing the scope for effective policy action. Such a long-range historical approach is espoused within critical political economy of media approaches, against tendencies to presentism within both academic and industry discourses. The common formula in business books provides highly truncated histories as part of a narrative arc to show those operating old ways are hopelessly ill-equipped to tackle new conditions, and must change fast or face decline. Yet, while some digital marketing discourse fits this description, it is far from uncommon for the long history of branded content to be acknowledged (Dzamic and Kirby, 2018). And here what can occur is an ideological mobilisation that does not rely on either presentism or truncated historical perspectives but instead reaches back over a longer historical span to find continuities that normalise the novel. Branded content is positioned as continuity. The historical appropriation of branded content forms part of a complex and contradictory set of readings and mobilisations in which any analysis is unavoidably implicated. The route forward, which this book will attempt, is to engage reflexively with the selectivity and mobilisations that inform all accounts, including this one, but which can provide a basis for critical evaluation. There is a choice of narratives, which offer different temporalities and different topic selections to situate branded content. Such differences can be illuminating, as they put into question what arrangements are regarded as the stasis from which change and disruption occur. Discourses that normalise branded content as a continuity of reciprocal brand and media engagements displace or downplay the periods in which formal and informal regulation upheld norms of separation between advertising and media content. We need to trace both the range of historical connections between brand promotions and media communications, and the ways in which these have been subject to regulation, normativity, and debate. That can provide a means to better understand both historical legacies and potential mobilisations going forward.

Approach of this book The book is organised around three main interlinked topics: practices, policies, and problems. It describes industry practices and their relationship with changing policies. It considers how emergent practices have been ‘normalised’, and it examines where and how problems have been articulated and critiques developed. Part I examines the changing practices of branded content across publishing, audiovisual, mobile, and social media. Part II examines policies, and the broader governance of branded content, and develops the discussion of problems. The book’s arrangement fits and serves core arguments. We need to evaluate and critique aspects of branded content but do so from a perspective that seeks to understand practices and practitioner attitudes. Any such critique needs to engage with the adequacy of existing mechanisms and resources of governance and build proposals for reform out of that analysis and engagement with

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stakeholders, all those affected by and engaged in shaping how media and marketing communications are conducted. The relationship between media and advertising is overlaid by a deeper set of divisions between art, culture, and creativity on the one hand, and commerce and commercialisation on the other. Following Hesmondhalgh (2019: 465), I consider that the ‘protection’ for culture was never complete, that commodification and culture were and remain entwined, that as ‘the opportunities for profiting from culture have grown, the lines drawn around culture have been pushed back’. The argument of this book is not to mourn, ahistorically, or advocate a ‘pure’ cultural space unsullied by commercialism, but instead to embrace and seek to understand the dynamics of those tensions in the changing practices, values, motivations of participants, and the structures built up around them across media and marketing industries and institutions of governance. This book does not advocate either the integration or removal of advertising but rather the importance of understanding, evaluating, and then advocating for ways of balancing media and advertising in the 21st century so that the values of democratic, diverse, and accountable communications can be realised. This book seeks to advance a contemporary critical political economy approach. In media and communication studies, critical political economy approaches are characterized by a central claim: that different ways of organising and financing communications have implications for the range and features of media content, and the ways in which these are consumed and used (Hardy, 2014; Mosco, 2009). Critical political economy refers to approaches that examine the unequal distribution of power and resources across societies and are critical of arrangements whereby such inequalities are sustained and reproduced, including by, and within, media industries. This approach calls for attention to the interplay between the symbolic and economic dimensions of the production of meaning. One direction of enquiry leads from media production arrangements to meaning-making and consumption; another considers the relationship of media and communication systems to wider forces and processes in society. In exploring these relationships, CPE approaches are not reliant on specific concepts or methods; rather the ongoing justification for CPE rests on the quality and salience of its analysis of problems in communication and social systems. My own short definition is as follows: ‘Critical political economic of communications is a critical realist approach that investigates problems connected with the political and economic organization of communication resources’ (Hardy, 2014: 14). The CPE analysis advanced requires attention to the organisation of communication industries, seeking explanations across all levels of operation and influence from the macro level of societal, political-economic arrangements, to the meso level of industry institutional arrangements, to the micro level of practices, processes, and interactions of actors and actants. This also means contexts matter. This book discusses international phenomena but focuses heavily on developments in the UK, US, and Europe, which I refer to as Euro-America. That is done to contribute to a wider effort to overcome the legacy of ethnocentrism and false universalism that efforts to internationalise media studies, advance comparative communications research, and decolonise education challenge.

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The CPE approach is also shaped by its orientation to consider and address problems. This book explores whether aspects of the merging of media and marketing are beneficial or detrimental, and if the latter what action has been or might be taken to tackle or ameliorate the problems. In doing so, I draw on the insights and passion of those who make and do branded content and try to engage fully and fairly with their perspective so that you can make up your own mind on the balance of evidence and arguments presented. So, while I will advance my own view, I want to conclude this opening chapter and survey by returning to what are perhaps the core issues in debate about the location and exercising of power over communications. In some account the rise of user-selected content services such as Netflix, and premium (ad-free) subscriptions such as Spotify, or YouTube Red, indicate a trend whereby audiences exercise increasing control over their exposure to advertising. Donaton sees a power shift: I think every trend is showing you that audiences are going to be more and more in control. So, I do think the answer is that brands have to figure out how what they want to say is worthy of someone’s time, and adds value to their life, and is something that someone would choose to spend time with. (Dzamic and Kirby, 2018: 119) That such shifts are occurring is widely acknowledged. For Sinclair (2015: 43), ‘The interactive properties of the internet, with the affordances of social networking and direct commercial transactions, have precipitated a shift in the balance of power between advertisers and consumers’. To summarise an argument I will advance below, there have indeed been shifts in power from marketers to users, although how far an overall case can be advanced remains much less certain. Marketers have lost control vis-à-vis consumers in various ways. However, this much-discussed shift displaces and masks the extension of marketers’ power over media and communications dependent on advertising finance. Their co-dependency underlies forms of media-marketing integration that result in complex relations of power, but ones that cannot be described, in summary, as constituting a power shift to users. Branded content connects to much older and longstanding issues of how culture and communications are financed and the role of advertising as subsidy. This involves relationships and tensions between three sets of interests: those of sponsors, those of creators, and those of audiences. These asymmetric relationships can be traced back to the earliest forms of patronage of culture and communications, but their interrelationship has the upmost importance for the qualities we wish to secure in our communication environments.

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Advanced Television (2018) ‘Spain: Pay-TV revenues up 14%’, Advanced Television, 14 May. https://advanced-television.com/2018/05/14/spain-pay-tv-revenues-up-14/. ANA (2015) Advertising Is Going Native. 2015 ANA Survey Report. http://www.ana.net/ content/show/id/33507. ASA (2019) ‘ASA Ruling on Cocoa Brown in association with Olivia Buckland’, 7 August. https://www.asa.org.uk/rulings/cocoa-brown-A19-561238.html. ASA (2020) ‘Recognising ads: Native advertising’, 16 October. https://www.asa.org.uk/a dvice-online/recognising-ads-native-advertising.html. Asmussen, B., Wider, S., Williams, R., Stevenson, N., Whitehead, E., and Canter, A. (2016) Defining Branded Content for the Digital Age. London: Branded Content Marketing Association. Borst, S. (2015) IAB Deep-Dive on In-Feed Ad Units: A Supplement to the IAB Native Advertising Playbook, 21 July. New York: IAB. https://www.iab.com/news/iab-deep-dive-onin-feed-ad-units-a-supplement-to-the-iab-native-advertising-playbook/ BuzzFeed (2015) ‘11 things all busy families should make time for’, 9 March. https://www. buzzfeed.com/kfc/12-things-all-busy-families-should-make-time-for?b=1&utm_term=. vxJRxlRn0#.tuw36q3Yk. Canter, A. (2012) ‘The age of branded content’. London: BCMA. http://thecma.info. Canter, A. (2017) Interview, 7 June. Canter, A. (2018) ‘Preface’ in A. Canter (ed.) Fifteen Years, A Branded Content Story. London: BCMA. Channel Five (n.d.) ‘Commercial Development’. https://www.channel5.com/commercialdevelopment/. Content Marketing Association (2017) ‘About the CMA’. http://the-cma.com/about-us/. Conticchio, B. (2017) ‘Branded content just another shade of fake news?’, Business2community, 27 January. https://www.business2community.com/content-marketing/branded-contentjust-another-shade-fake-news-01765717. Couldry, N. and Turow, J. (2014) ‘Advertising, big data, and the clearance of the public realm: Marketers’ new approaches to the content subsidy’, International Journal of Communication 8, 1710–1726. Dagnino, G. (2020) Branded Entertainment and Cinema: The Marketisation of Italian Film. Abingdon: Routledge. Davenport, T. and Beck, J. (2002) Attention Economy: Understanding the New Currency of Business. Cambridge, MA: Harvard Business Review Press. Dietrich, G. (2013) ‘The four different types of media’, Spin Sucks, 24 June. http://spinsucks. com/communication/the-four-different-types-of-media/ Donaton, S. (2004) Madison & Vine: Why the Entertainment and Advertising Industries Must Converge to Survive. New York: McGraw-Hill. Donaton, S. (2007) ‘Madison & Vine: A look back, a look ahead’, Advertising Age, 11 October. https://adage.com/article/madisonvine-case-study/madison-vine-a-back-a-ahead/121042. Dzamic, L. and Kirby, J. (2018) The Definitive Guide to Strategic Content Marketing. London: Kogan Page. Einstein, M. (2016) Black Ops Advertising: Native Ads, Content Marketing, and the Covert World of the Digital Sell. New York: OR Books. Forrester Research (2016) ‘Don’t Confuse Media-Led and Customer-Led Content Marketing’. https://www.forrester.com/report/Dont+Confuse+MediaLed+And+CustomerLed +Content+Marketing/-/E-RES131044#. Fuchs C. (2014) Social Media: A Critical Introduction. London: Sage. Fulgoni, G., Pettit, R., and Lipsman, A. (2017). ‘Measuring the effectiveness of branded content across television and digital platforms’, Journal of Advertising Research, December: 362–367.

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Gardiner, K. (2013) ‘The story behind “The Furrow”, the world’s oldest content marketing’, Contently, 3 October. https://contently.com/2013/10/03/the-story-behind-the-furrow-2/. Gartner (n.d.) Customer Experience Management (CEM). https://www.gartner.com/it-glossary/ customer-experience-management-cem. Gillan (2015) Television Brandcasting: The Return of the Content-Promotion Hybrid. Abingdon: Routledge. Grainge, P. and Johnson, C. (2015) Promotional Screen Industries. Abingdon: Routledge. Hammett, E. (2016) ‘Native advertising to dominate European digital display by 2020’, Mediatel, 23 February. http://mediatel.co.uk/newsline/2016/02/23/native-advertising-todominate-european-digital-display-by-2020/. Handley, L (2017) ‘Sixty-five percent of people skip online video ads. Here’s what to do about it’, 16 February, CNBC. https://www.cnbc.com/2017/02/16/sixty-five-percentof-people-skip-online-video-ads-heres-what-to-do.html. Hardy, J. (2010) Cross-Media Promotion. New York: Peter Lang. Hardy, J. (2013) ‘The changing relationship between media and marketing’ in H. Powell (ed.) Promotional Culture and Convergence: Markets, Methods, Media. Abingdon: Routledge. Hardy, J. (2014) Critical Political Economy of the Media: An Introduction. Abingdon: Routledge. Hesmondhalgh, D. (2019) The Cultural Industries, 4th Edition. London: Sage. Holt, D. (2016) ‘Branding in the age of social media’, Harvard Business Review, March. https:// hbr.org/2016/03/branding-in-the-age-of-social-media. IAB [Interactive Advertising Bureau] (2013) The Native Advertising Playbook, 4 December. New York: IAB. http://www.iab.com/guidelines/native-advertising/. IAB [Interactive Advertising Bureau] (2015) IAB Deep Dive on In-Feed Ad Units: A Supplement to the IAB Native Advertising Playbook. July. New York: IAB. IAB [Interactive Advertising Bureau] (2017) RTB Project OpenRTB Dynamic Native Ads API Specification, Version 1.2, Draft for Public Comment, April. IAB [Interactive Advertising Bureau] (2019) Native Advertising Playbook 2.0, May. New York: IAB. http://www.iab.com/guidelines/native-advertising/. International Chamber of Commerce (2014) ‘ICC Marketing Commission looks at new challenges to ad standards worldwide’, 10 September. https://iccwbo.org/media-wall/ news-speeches/icc-marketing-commission-looks-at-new-challenges-to-ad-standa rds-worldwide/. Internet Advertising Bureau [IAB UK] (2015) ‘IAB/PwC study: Digital adspend up 14% to record £7.2 billion’. http://www.iabuk.net/about/press/archive/iab-pwc-study-digitaladspend-up-14-to-record-72-billion. Jansen, J.B. (2008) ‘Sponsored search: An overview of the concept, history, and technology’, International Journal of Electronic Business 6(2). https://faculty.ist.psu.edu/jjansen/academ ic/pubs/jansen_overview_sponosored_search.pdf. Johnston, M.R. (2018) ‘How to rock mobile native advertising’, Content Marketing Institute, 8 February. https://contentmarketinginstitute.com/2018/02/mobile-native-advertising/. Kretchmer, S. (2004) ‘Advertainment: The evolution of product placement as a mass media marketing strategy’, Journal of Promotion Management 10(1), 37–54. Lehu, J. (2007) Branded Entertainment: Product Placement & Brand Strategy in the Entertainment Business. London: Kogan Page. Leibowitz, D. (2020) ‘When BMW made action movies to sell cars’, Medium, 7 August. https:// medium.com/better-marketing/bmw-the-hire-3b31495a6ec2. Mathes, D. (2018) ‘Best legal practices for brands using influencer marketing’, Dallas Business Journal, 26 July. https://www.bizjournals.com/dallas/news/2018/07/26/best-legal-practicesfor-brands-using-influencer.html. McAllister, M. (1996) The Commercialization of American Culture. Thousand Oaks, CA: Sage.

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McAllister, M. (2000) ‘From Flick to Flack: The Increased Emphasis on Marketing by Media Entertainment Corporations’, in R. Anderson and L. Strate (eds) Critical Studies in Media Commercialism. Oxford: Oxford University Press. McCarthy Group (2014) ‘Millennial’s survey’. https://www.themccarthygroup.com/millennialssurvey. Meyers, C. (2011) ‘The problems with sponsorship in us broadcasting, 1930s–1950s: perspectives from the advertising industry’, Historical Journal of Film, Radio and Television 31(3): 355–372. Mole, A. (2016) ‘Be useful, be entertaining: Native advertising’s golden rules [promoted content]’, Campaign, 29 September. http://www.campaignlive.co.uk/article/usefulentertaining-native-advertisings-golden-rules/1410424. Mosco, V. (2009) The Political Economy of Communication, 2nd Edition. London: Sage. Native Advertising Institute (2015). ‘The definition of native advertising’. https://nativea dvertisinginstitute.com/blog/the-definition-of-native-advertising/. Newell, J., Salmon, C.T., and Chang, S. (2006) ‘The hidden history of product placement’, Journal of Broadcasting & Electronic Media 50(4): 575–594. Oberoi, A. (2013). ‘The history of online advertising’. https://www.adpushup.com/blog/ the-history-of-online-advertising/. Optimizely (n.d.) ‘Glossary’. https://www.optimizely.com/uk/optimization-glossary/ inbound-marketing/ Pfund, C. (2018) ‘Cultivating brand evangelists and ambassadors’, Forbes, 7 May. https://www. forbes.com/sites/theyec/2018/05/07/cultivating-brand-evangelists-and-ambassadors/?sh= 17f623ba3a5d. PQ Media (2018) Global Branded Entertainment Marketing Forecast 2018. https://www.pqm edia.com/product/global-branded-entertainment-marketing-forecast-2018/. PQ Media (2015) ‘PQ Media: Global content marketing revs surge 13% to $26.5B in 2014’, 8 July.http://www.pqmedia.com/about-press-20150708.html. Pulizzi, J. (2015) ‘Native advertising is not content marketing’. http://contentmarketingin stitute.com/2015/08/native-advertising-content-marketing/. Roxburgh, H. (2016) ‘Sometimes, logos get in the way of a good ad’, Campaign, 3 February. Sebastian, M. (2014) ‘“Madison & Vine” turns 10 – but how far has branded content really come?’, Advertising Age, 13 May. Serazio, M. (2013) Your Ad Here. The Cool Sell of Guerrilla Marketing. New York: New York University Press. Sharethrough (n.d.) ‘Native advertising insights’. https://www.sharethrough.com/nativea dvertising. Shiao, D. (2019) ‘What you need to know about native advertising’, Content Marketing Institute, 14 February. https://contentmarketinginstitute.com/2019/02/about-native-advertising/. Sinclair, J. (2015) ‘Advertising, the media and globalisation’, Media Industries Journal 1(3): 42–47. Sinclair, J. (2020) ‘Cracking under pressure: Current trends in the global advertising industry’, Media International Australia 174(1): 3–16. Smulyan, S. (1994) Selling Radio. Washington, DC: Smithsonian Institution Press. Somethin’ Else (2020) ‘We are an audience business’. https://somethinelse.com/. SpinSucks (2020) ‘The PESO Model image’. https://spinsucks.com/peso-model-image/. Sterling, G. (2018) ‘Native will dominate display spending in 2018’, Marketing Land, 11 April. https://marketingland.com/native-will-dominate-display-spending-in-2018-238081. Sullivan, L. (2013) ‘Banner blindness: 60% can’t remember the last display ad they saw’, Media Post. http://wwwmediapost.com/publications/article/196071/banner-bindness-60-cantremember-the-last-disp.html.

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Swan, G. (2020) ‘What is OTT advertising: A breakdown of over-the-top ads’, Tinuiti, 16 March. https://tinuiti.com/blog/ott-over-the-top-ads/ott-advertising-guide/. Swatman, R. (2015) ‘2012: Highest freefall parachute jump’, Guinness Book of Records, 18 August. http://www.guinnessworldrecords.com/news/60at60/2015/8/2012-highest-freefallparachute-jump-392848. Tench, R. and Yeomans, L. (2017) Exploring Public Relations. Harlow: Pearson. Tran, K. (2018) ‘OTT services are helping to drive product placement deals’, Business Insider, 18 June. https://www.businessinsider.com/amazon-hulu-netflix-driving-product-placem ent-deals-2018-6?IR=T. Turow, J. (2011) The Daily You. New Haven, CT: Yale University Press. Velocity Partners (2013) ‘Crap: The content marketing deluge – the single biggest threat to B2B content marketing’, Slideshare, 10 January. Slideshare.net/dougkessler/crap-thecontent-marketing-deluge. Verizon (2019) Verizon State of Native 2019, 12 March. https://www.verizonmedia.com/ insights/state-of-native-2019. Wall Street Journal (2016) Defy Hunger Together. http://partners.wsj.com/mini/defyhunger-together/. Weise, M. (2011) ‘The evolution of branded entertainment’, Forbes, 22 August. http:// www.forbes.com/sites/onmarketing/2011/08/22/the-evolution-of-branded-entertainm ent/. Yaxley, H. (2020) ‘Tracing the measurement origins of PESO’, PR Conversations, 28 June. https://www.prconversations.com/tracing-the-measurement-origins-of-peso/. Yesiloglu, S. and Costello, J. (eds) (2020) Influencer Marketing: Building Brand Communities and Engagement. Abingdon: Routledge.

2 NEWS MEDIA AND MARKETING

It’s a huge story: the complete transformation of the economics of journalism in a way that renders the concept of journalism extinct. (Sullivan, 2014)

Branded content is not a unified activity but a series of diverse practices that interconnect in various ways. Different practices and arrangements occur across different media forms and their institutional arrangements. At the same time, branded content activities criss-cross and bind together formerly disparate areas of communications activity. This is a story of dynamic adaptive systems, with characteristics of separateness and convergence, whereby such demarcations must always be questioned and reviewed, not simply asserted. There are, though, some institutionalised demarcations that help in locating branded content. The first is the division between news (and information) and entertainment content. This maps on to a second, historical, and institutional division between media industry forms, or platforms, when that term is used to describe all different types of media-carrying vehicles. In their ‘legacy’ forms these are print publishing (newspapers and magazines), broadcasting (radio and television), and cinema. In our digital systems, all content can appear on multiple platforms, yet media industry forms remain variously organised and influenced by their institutionalised legacy forms as well as values, purposes, professional organisation and governance, market arrangements, and user expectations and engagements. In a contemporary demarcation we can identify publishing, audiovisual, and UCG/social media as the main top line groups. These are not distinct. Online news media produce an increasing proportion of audiovisual content, for instance. Yet, they do identify groupings, albeit porous, interacting, and converging ones. This chapter explores how branded content has emerged in publishing and specifically in news publishing. Advertising that resembles editorial long predates the digital age, but brands are increasingly involved in the production of publisher-hosted branded content, including a DOI: 10.4324/9781315641065-3

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range of practices and artefacts described as paid content, sponsored content, native advertising, programmatic native, brand journalism, content recommendation, and clickbait. While commercial publishers leverage the business opportunities of sponsored content, these activities are transforming journalistic practices and generating critical debates on the implications for the purposes, and performance of journalisms. Sponsored editorial content is material with similar qualities and format to content that is typically published on a platform, but which is paid for by a third party. This sponsored content covers two main, converging, forms. The first is advertising, where brand-controlled content and storytelling extends into formats that resemble editorial and where so-called native advertising builds on earlier integrations of advertising and editorial, such as advertorials. The second is sponsorship, where a sponsor pays for but does not control the journalistic output, formally at least: underwriting but not writing the content. Under institutionally sedimented arrangements, practices, and expectations, advertisers have controlled advertising content and publishers have controlled editorial content, including sponsored editorial. Those arrangements have been disrupted by the growth and proliferation of forms of content that are financed by brands or other sponsors but published, and variously ‘produced’ and co-created, by news and other content publishers. This book offers a critical examination of the merging of media and advertising, and it is in relation to brand communications integrated into publishing that some of the strongest criticism of that merging is advanced (Chapter 9). This chapter discusses the forms and practices that have developed, while the more critical issues are addressed in the discussion of policies and problems in Part II. Yet the basis of that criticism needs to be understood in order to make sense of the changes in news publishing. By the 20th century, in Western journalism, a mix of laws, industry (self-)regulation, professional norms, and institutional arrangements upheld a ‘separation principle’, whereby advertising and media content should be kept separate and distinct. These governance arrangements differed in important ways across time, space, and publishing contexts, but the core norm was recognised and influential worldwide, while always inflected through the pertinent ‘local’ arrangements, cultures, and practices of journalisms. These ‘rules’ of conduct came under increasing pressure from the 1970s, notably in local city and regional commercial newspapers in the United States (Hallin, 2000). This chapter examines how, in the metaphors of US journalism, the ‘firewall’ between ‘church’ and ‘state’, between editorial and commercial considerations, was challenged and weakened, and explores the various ways in which commercial interest from advertisers and corporate interests have been promoted and articulated in new norms. Across today’s digital journalism the range of practices and articulated norms is highly diverse. This chapter describes contemporary practices and relationships between journalism and corporate and commercial interests.

Contexts: Changes in news publishing Across most countries news media have struggled with diminishing advertising revenues, falling fee-paying audiences, reduced operating budgets, and intensifying

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competition from online media and platforms that are undermining the business models and structures of the older, ‘legacy’, news industry. Digitalisation has profoundly affected all aspects of the creation, circulation, and consumption of content. In the pre-digital era, most print publishers and broadcasters competed in spatially confined market sectors, sharing advantages of economies of scale and scope, and legal-regulatory requirements, that created barriers to market entry. The growth of internet communications enabled all those conditions to be undermined, although crucially the resulting pattern is one mixing sustained advantages for large firms with ongoing disruption for all market actors. The most straightforward and significant impact has been the shift of advertising revenue from news publishers to other content suppliers, and increasingly to platforms (Bell and Owen, 2017). ‘The news business … is going out of business’, declared Wolff (2007) – an aphorism capturing a period of unprecedented turbulence. Waves of disruption have pummelled islands of newsmaking, ripping through business models, working arrangements, settled practices, and identities of journalists alike. Between 2008 and 2017 an estimated 39,000 jobs were lost in US newspapers, a 45 per cent fall (Greico, 2018). Across the five industries that produce news (newspaper, radio, broadcast TV, cable, and digital-native) there were some 114,000 newsroom employees in 2008, working as reporters, editors, photographers, and videographers; by 2017 this workforce had declined to 88,000 (Greico, 2018). In the UK, the number of workers describing themselves as journalists declined by 11,000, from 84,000 in August 2016 to 73,000 in August 2017, according to Labour Force Survey estimates (Ponsford, 2017). Across UK print as a whole, the number of journalists fell by over a quarter, from 23,000 in 2007 to 17,000 in 2017 (Mediatique, 2018: 5). Debates about the ‘crisis’ in news media intensified in the 2000s. Since then, some aspects at least are clearer. First, variability across countries and regions challenges ethnocentric generalisation and requires more fine-grained analysis. For example, a survey of ten countries (Newman and Levy, 2014: 55) found economic disruption was greatest in countries where the majority of sales were from newsstands or shops (UK, Spain, Italy, Brazil) compared to home delivery via subscription (Japan, Denmark, Finland, Germany). Second, the Euro-American literature has tended to ignore the growth of paid newspaper markets across fast-growing economies in Asia, Africa, and Latin America (Franklin, 2009). Global printed newspaper circulation (including free titles) was 7.7 per cent higher in 2009 than it had been five years earlier; declining circulation in mature markets was countered by growth in Latin America, Africa and in Asian markets, notably India (WAN/ IFRA, 2009; 2016). An estimated 40 per cent of the world’s adult population read a newspaper on a regular basis (WAN/IFRA, 2016: 6). Global audience revenues grew by 7 per cent between 2012 and 2016; while global advertising revenues declined by 21 per cent overall in the same period, rates of decline varied greatly across different markets (WAN/IFRA, 2016). Third, even across advanced economies the general trend has been decline and restructuring rather than collapse, and fourth, that highlights the importance of differentiation between news sectors and competing enterprises (Franklin, 2009). The crisis debate tends to conflate print-

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based and broadcasting-based media, which makes some sense in examining trends across the convergent, commercial media of the United States but less so when addressing the mixed systems of Europe with relatively strong public service media alongside commercial publishers. Nevertheless, the common feature across media systems whose newspaper market was larger before digitalisation has been an irreversible decline in print revenue, accompanied by cost cutting to manage that decline. In the UK, circulation fell by 25 per cent between 2005 and 2010 in the ‘quality’ press, and by 17 per cent in the popular press (Enders Analysis, 2011). Explanations for the crisis of the press indicate a range of perspectives on the various causes, and possible solutions, with debates reflecting: not only different degrees of real impact by the crisis and national policy traditions but [the diffusion of] an evolving transnational paradigm that dominates public discourse. […] the state is supposed to play the role of a benevolent but mostly passive bystander, while commercial media outlets should tackle the problem by developing innovative content and business strategies. (Brüggemann et al., 2016: 547) If internet disruption has been the chief explanatory narrative of commercial business managers, underinvestment has been the counter-narrative of their critics. Owners were maximising profits while revenue declined, by cutting staffing and production costs, allowing newsbrands to plummet in a spiral of neglect. Critical scholarship highlights the processes by which corporations have come to dominate markets and pursue profit-maximisation at the expense of public interest news provision (McChesney, 2013). They describe the advancement of market values within commercial news media, what McManus (1994) calls ‘market-driven journalism’ and McChesney (2013) ‘hypercommercialism’. The balancing of commercial and journalistic imperatives in for-profit news businesses, present since the 17th century, tilted towards profit extraction under corporate and investor pressures, within conditions of increasing market volatility, acquisitions activity, and financialisation. In corporate decision-making structures, news editors and journalists formed a ‘shrinking proportion of corporate personnel’ (Anderson and Ward, 2007: 23). Commercial news owners ‘privileged profit over reinvention’ (Carlson, 2017: 181). Waves of corporate consolidation, aided by liberalisation of ownership regulations, left commercial news production in the hands of debt-laden, financialized corporations with decreasing tolerance to subsidise loss-making reporting and whose corporate logics undermine journalistic independence and investigative capacity alike (Almiron, 2010). The American newspaper market entered a ‘death spiral’, summarised by Rusbridger (2018: 74): Circulation decline led to advertising decline. Management cut back editorial employees to stem declining margins while, at the same time, asking them to work harder and adding new digital requirements to their roles. Newspapers shrank and became less compelling. Readers found less of interest and stopped

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buying them. With few readers came fewer advertisers. The margins declined further. Managements made further cuts. As profitability declined, capital began to abandon news journalism, shifting to more profitable activities, including classified ad websites (McChesney, 2013). The crisis, critics argued, laid bare fundamental tensions between capitalism and democracy, between ‘communication groups subject to financial logics and who can, and indeed do, exercise political action, and … the need that democracy and society have for an independent, rigorous and professional journalistic practice’ (Almiron, 2010: 158). In debate were two principal causes of cuts: profit-maximisation on behalf of shareholders, or the collapse of profitability as advertising migrated online. While responsibility for the decline is contested, the outcome was downsizing the journalistic workforce combined with intensifying productivity across always-on, converged newsrooms, leading to reductions in the breadth and depth of commercial news output (Anderson and Ward, 2007: 23). In the UK, local papers declined from 1,687 in 1985 to 1,286 by 2005, with 242 closing between 2004 and 2011, while leading newsgroups maintained substantial profit margins averaging 15–20 per cent (Ramsay and Moore, 2016). By 2017, the majority of UK adults (58 per cent) had no local daily paper.

Advertising revenues Newspaper costs and revenues shifted with changes in production, distribution, and consumption across the decades, yet some core features remained stable. Most newspapers competed in what is described as a dual-product, or two-sided market: a market for consumer sales and a market for advertising revenue. The ratio of dependence on revenue from advertising or consumer sales varied considerably; however, a persistent pattern was that so-called quality papers received a higher proportion of their revenue from advertising over sales. The second Royal Commission on the Press found the ratio of advertising to sales revenue for quality papers to be 74/23 in 1937 and 73/24 in 1960, while for popular papers it was 50/49 in 1937 and 45/54 in 1960 (RCP [Royal Commission on the Press], 1962: 23). This had several important consequences. The popular press, deriving a greater share of income from consumers, was under pressure to compete with content that would maximise sales: entertainment, celebrities, scandal, and sports. The quality press, more reliant on advertising income, could sustain a competitive position on comparatively lower circulation. Focusing editorial content on attracting readers with high value for advertisers, the qualities provided public affairs coverage in a manner approximating the free press of ‘democratic mythology’ (Sparks, 1999: 59). Initially the challenge of digitalisation was to classified ads as online markets blossomed. The internet’s share of classified advertising in the UK rose from 2 per cent in 2000 to 45 per cent by 2008. In the same period, the local press share fell from 47 to 26 per cent, while national newspapers’ share of classified fell from 14 to 6 per cent. The lucrative display ad revenue also gradually eroded. The deal, whereby advertisers paid for journalism to attract readers who would see their ads, has been unravelling

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since the early 1990s, as marketers found more direct, information-rich, and costeffective ways to track and target consumers online (Turow, 2011). UK local papers had reaped profits from their quasi-monopoly control over local advertising for cars, housing, and jobs into the mid-2000s only to see that model collapse as classified moved online and advertisers followed users to Facebook and Google. Print advertising expenditure for national newspapers dropped from nearly £1.4 billion in 2011 to approximately £0.8 billion in 2016 (Ofcom, 2017: 45). Advertising revenue for the three largest UK regional publishers fell from £2.8 billion in 2006 to £832 million in 2016 (Waterson, 2019). Online advertising revenue for publishing has been growing, and became a significant revenue stream for some, but for the majority the ‘dollars’ lost from print advertising have been replaced by ‘cents’ earned from digital advertising (McChesney, 2013). While digital advertising revenues have continued to grow overall for many legacy news publications, they have not replaced the losses from print display advertising revenue. Online advertising became the leading advertising medium worldwide from 2017 (ZenithOptimedia, 2018). Yet, an increasing proportion of total online advertising revenue goes to the platform giants. Facebook and Google accounted for an estimated 53 per cent of the online display ad market in 2016 (Ofcom, 2017: 44). By 2019, around 80 per cent of the £14 billion ($17 billion) spent on digital advertising in the UK went to Google and Facebook (CMA [Competition and Markets Authority], 2020). Such dominance is replicated across other markets, such as Australia where the duopoly held more than 80 per cent of the digital advertising market in 2019 (Meade, 2020). Efforts to make good the loss of advertising by more effective retailing, through paywalls, micropayments, and subscription have so far had only modest success. The Guardian had 500,000 regular subscribers worldwide in 2018, a significant achievement, but one outweighed by continued heavy losses as the paper struggled to break even (Waterson, 2018). Successful monetisation online has been mostly restricted to products serving elite or specialist audiences, where there are attributes of high-value content (relatively non-reproducible and/or fast), scarcity in supply, a valued user interface, and enhanced cross-platform availability. The Nikkei-owned Financial Times, which introduced a metered paywall in 2007, announced 1 million subscribers in 2019, with most growth in international markets where it competes with the Wall Street Journal’s 2.5 million subscribers (Greenslade, 2019). Yet, while subscription secures the FT’s profitability, print advertising fell by 5 per cent and digital 3 per cent on the previous year. The failure to raise revenue from consumers has meant ever greater dependence on advertising. Yet, the revenues from traditional display and classified advertising cannot support commercial news journalism. As Ofcom (2017: 45) summarises, ‘Print budgets have consistently migrated away from newspapers and magazines to online display, search, and classified formats, due to falling print circulation levels and the relatively high costs of placing print advertisements’. Declining click-through rates and ‘banner blindness’ encouraged advertisers to test other formats, such as pop-ups and interstitials, and then animated advertisements, pre-roll, and other video formats. These formats, though, have also generated negative responses from consumers and ad-avoidance

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strategies, most notably ad-blocking. A survey of publishers worldwide found that 10 per cent were preparing for a future with little or no display ads (Newman, 2018: 22).

Brand-sponsored editorial content The migration of advertising from newspapers to online and mobile is recognised as part of the ‘crisis’ for news media. But less recognised is how this left news media with even greater dependence on ad finance, just as advertisers, faced with increasing choices online, want ‘more bang for their buck’. That has created the conditions for native advertising, advertising mimicking editorial (Carlson, 2015; Ferrer-Conill, 2016; Lynch, 2018). This is the context in which media have offered ever increasing incentives to marketers, including paid/sponsored content and related formats. Amid falling display advertising and subscription revenues, sponsored content has offered publishers the potential for increased earnings, and marketers a means to tackle ad-avoidance and boost engagement (Harms et al., 2017). The outcome has been the growth of brand-sponsored content, including editorial-like content that is hosted by publishers and which may be controlled by publishers, by advertisers, or jointly. Branded/sponsored content is amongst the top three most important sources of income after subscription and video by nearly 300 publishers surveyed (Newman, 2018). Sponsored content is now the second most important revenue generator (44 per cent), after advertising (70 per cent) and ahead of subscription (31 per cent), according to a worldwide survey of news publishers (ICFJ, 2017). Over the last decade, news publishers have restructured newsrooms and established teams to produce content, funded by brands or others, that blur traditional demarcations between editorial and advertising.

Definitions Various terms are used to describe varieties of material funded by, or produced and supplied by, marketers which appears in print or online publications owned and controlled by persons other than the marketer. In the pre-digital era, the principal term for advertising material that appears with some generic or publication-specific features of design or editorial matter is advertorial. Alternative terms used, indeed required, for the labelling of content in some systems of governance are advertisement feature, or advertising feature. The Association of Advertisers in Ireland (AAI [Association of Advertisers in Ireland] , n.d.) define an advertorial as ‘an advertisement that has the appearance of a news article or editorial, in a print publication’. Advertorial is defined by the UK Committee of Advertising Practice (CAP Code Introduction III, k) as ‘an advertisement feature, announcement or promotion, the content of which is controlled by the marketer, not the publisher, that is disseminated in exchange for a payment or other reciprocal arrangement’ (CAP, 2014: 8). The Institute of Public Relations (now Chartered Institute of Public Relations) produced a guide for practitioners, Resolving the advertising/editorial conflict, which states that the term advertorial is ‘used to describe a previously agreed

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combination of advertisements and editorial matter. The usual format is for a theme to be adopted and space sold to appropriate advertisers’ (IPR [Institute of Public Relations], 1998). Advertorials remain a significant format for branded content in both print and online publications, and remain a term required, or used, for labelling and identification in many. However, within industry discourses, the term ‘native advertising’ has been widely adopted to apply to and incorporate advertorial content where this refers to content that is paid for and controlled by brands, and usually also supplied by brands. Industry discourses are examined in more detail in Chapter 8, but some key reasons for this shift are evident, if still controversial and debated. Advertorial carries associations with pre-digital, older advertising formats. Native is a term from the digital era and conveys a more flexible, adaptable, cross-platform approach. For marketing agencies and media selling their services to marketers, native is a more attractive, contemporary proposition.

Native advertising Native advertising describes various forms of integration of advertising and content, especially in online, mobile, and social media, where advertisements follow the form and user experience associated with the context in which they are placed. The US Federal Trade Commission (FTC, 2015: 1) describes native advertising as ‘advertising and promotional messages integrated into and presented as non-commercial content’. Native advertising is described as ‘content paid for and controlled by brands, but which looks like news, features, reviews, entertainment and other content that surrounds it online’ (Parker, 2016). The term is used to refer to ‘paid-news content that mimics non-advertising content’ (Wojdynski, 2016) and as ‘any paid advertising that takes the specific form and appearance of editorial content from the publisher itself’ (Wojdynski and Evans, 2016: 157). Reviewing US practice in the mid-2010s, Wojdynski (2016) identifies sponsored content, partner content, advertorials, and branded journalism as among the key terms used but argues native advertising has become the most widely adopted. He suggests this is because the two words convey its inclusion criteria: messages that are ‘native’ to non-paid content, while at the same time being paid advertising. However, the core claim of being ‘native’ is itself promotional, and so definitions that represent it as a putatively neutral description are problematic, at least as a foundation for research. Some definitions are too particular in their description of components, combining or excluding elements that need to be differentiated. For instance, Ferrer-Conill (2016: 905) defines native advertising as ‘a form of paid content marketing, where the commercial content is delivered adopting the form and function of editorial content with the attempt to recreate the user experience of reading news instead of advertising content’. However, only some native advertising seeks to recreate ‘reading news’, as the continuities with advertorials and ‘reason why’ advertising copy demonstrate. There are then a range of terms used and definitional inexactitude. I suggest that the best routes through this are to identify the components and distinctions in

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practices and to engage fully, and critically, with the terms used by practitioners in specific media system contexts, and the terms that structure the governance of communications in those media systems. Key differential features are advertising placement type, content type, and content location. All these are subject to formal, informal, and increasingly part-automated transactional arrangements between parties, and so the other key differentiators can be summarised as actors, payment, and control. The Interactive Advertising Bureau Playbook (IAB [Interactive Advertising Bureau], 2019: 7) defines branded content (and native content) as ‘paid content from a brand that is published in the same format as full editorial on a publisher’s site, generally in conjunction with the publisher’s content teams themselves’. Such content requires disclosure that it is paid for, and ‘should be considered as a native ad type’ (IAB [Interactive Advertising Bureau], 2019: 7). This substantive content (the text, images, and graphic elements that make up an article, ‘story’, or other item of branded content) is distinct from two other categories of ‘native advertising’ which are both vehicles for the promotion of the branded content. These are in-feed and content recommendation ads. In-feed is a form of native advertising that appears in publishers’ content feed. In-feed native advertising units are usually surrounded by the publisher’s editorial content. The native ad link takes users to a third-party website, but may link to a section of the publisher’s own site carrying brand-sponsored content. By contrast, content recommendation ads usually appear below articles, carried in a designated section with other content recommendation ads, and ‘does not mimic the appearance of the editorial content feed’ (IAB [Interactive Advertising Bureau], 2019: 19). Content recommendation ads also always link to pages outside the publisher’s site. The ‘content recommendation’ or ‘content discovery’ industry generates revenue ‘primarily by providing cookie-based tracking of user data across vast networks of sites, and by delivering embedded “native” blocks of linked stories tailored to match the resulting algorithmically determined preferences of those users’ (Wojdynski, 2016: 210). Leading companies include Outbrain and Taboola (whose planned merger was abandoned in 2020), Gravity, nRelate, and others who offer publishers content blocks that they manage and share revenue from driving users to content on third-party sites via what Wojdynski (2016: 12) calls ‘sponsored hyperlink listings’. Publishers are paid a small fee when users click on hyperlinks for either of these types of native advertising. One attraction of infeed for marketers is that it is often standalone rather than a grouped collection of adverts, as in content recommendation ads. The practices and relationships surrounding content recommendation are examined further in Chapter 5 together with the automation that distinguishes programmatic native advertising from other forms. The pejorative term for some of this material is clickbait, but that term also applies not only to third-party material featured on publisher sites but also publishers’ own content, especially where drivers of direct or indirect monetisation of user activation prompts the production and promotion of low-quality, sensationalist content.

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Sponsored content After native advertising, the other key terms are sponsored content and associated descriptors such as paid content, or promoted content. This category is used to include advertorials and more modern labelling, such as native advertising. Sponsored editorial content is used to describe material with similar qualities and format to content that is typically published on a platform, but which is paid for by a third party. However, sponsored content includes relationships between brands and third-party publishing that goes beyond the assembling of specific text and image represented by advertorials. An advertorial is a form of advertising in which the marketer pays for the display of content. That content may be created and supplied by the marketer or by agencies acting on behalf of the marketer, or it may be created by or on behalf of the publication. It is a form of paid communication that is subject to control by the brand. Sponsored content encompasses a relationship in which the marketer provides payment or other valuable consideration but where control may formally, and to varying degrees actually, reside with the editorial control of the publication. Sponsored content also indicates a broader range of relationships between the brand and publication. The brand may sponsor a section of the publication, or a themed issue, or various activities involving the publication, such as events. This is better understood in the context of the delineation, and the blurring, of differences between sponsorship and advertising, occurring in both institutionalised industry discourses and practices, and in law and governance. In the United States legal-regulatory system, a key structuring component is persuasive content. ‘The term “advertising” refers to paid persuasive communications, whereas the term “sponsorship” typically refers to communications that are not persuasive in nature’ (Campbell and Grimm, 2019: 117). Advertising is paid communication and persuasive in nature, ‘where the communication features or advocates for a sponsor’s products or services’ (Campbell and Grimm, 2019: 117). However, increasing use of the terms ‘“sponsored content,” “sponsored post,” and “sponsored” in conjunction with native advertising has likely eroded the traditional distinction between the meanings of “advertising” and “sponsorship”’ (Campbell and Grimm, 2019: 115). The practices of branded content will be examined below, but it is first important to trace their evolution, as this informs critical analysis and contemporary debates. The history of branded content informs and is mobilised within contemporary debates, as Chapter 1 has discussed. There has been a close interlinking of media and advertising throughout the history of print media. Yet, there has also been the establishment of a principle of separation of media and advertising that the growth and advocacy of branded content erodes.

History and development In 1914, The Rotarian magazine carried an advertorial that was distinguished by a disclosure label, different typeface, and paragraph mark at the start of each sentence (Hoofnagle and Meleshinsky, 2015: 15). Theodore MacManus penned the article,

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‘The Penalty of Leadership’, published in the US Saturday Evening Post, which was a subtle promotion for Cadillacs prepared on behalf of General Motors (Bachmann et al., 2019). Advertorials originated in early 20th century magazine and newspaper publishing. However, the interlinking of advertising and editorial needs to be traced back much further. The first daily newspaper in the UK, The Daily Courant (1702–35), established by Samuel Buckley, was financed by the government. The first issue had 104 lines of text. Within 50 years other London and regional papers were established, some of whose names indicate the importance of advertising for revenue and content appeal, such as the Bath Advertiser. Newspapers carried advertisements in the form of typeset copy, with only text supplied by advertisers, and usually with little embellishment except for woodcut or, later, metal images, such as a ship to indicate the advertising of sailing times. Such imagery was generic and prepared by publishers. In America’s first daily paper, the Pennsylvania Packet, also titled The General Advertiser (1777–83), such images of ships featured alongside advertisements for goods and services aimed at affluent white readers and included the abominable traffic in Black African and other human slaves. Advertising was distinct from the editorial material on the whole. However, it was not until late the 19th century that marketers supplied ‘made-up’ display ads as they continued to do using various technologies, from the print era to the digital era. Advertisers supplied text content that was then prepared for publication by publishers, from basic typesetting to more advanced design and layout. One historical form of integration is ‘reading notices’, which appeared in US newspapers in the late 19th century. Baldasty (1992: 66, 79) describes these as ‘advertisements designed to appear as news articles’ and notes their popularity with advertisers and their agents who ‘appropriated the form of a news story to hide their ads as news reports’. A headline in The Pittsburgh Leader in 1897, ‘Coasted down the Capitol steps’, reported a daring bicycle ride, with the third paragraph promoting a tonic, Dr Pierce’s Golden Medical Discovery (Baldasty, 1992: 66–7). Marketers ‘believed that such ads would draw more readers because they appeared to be news [and that] readers would tend to be more receptive to a product promoted by a supposedly independent source [viz., the newspaper] than to an advertiser’s pitch’ (Baldasty, 1992: 66). Reading notices became common, and proved popular with readers. Major newspapers developed standardised rates for such notices, which were also often stipulated as a condition in advertising contracts. In one contract for a patent medicine product, Athlophoros, it was stipulated that the newspaper must publish a reading notice ‘set in the type used by you for reading or news matter; and it must be the first notice following pure reading matter’ (Baldasty, 1992: 68). Reading notices were enthusiastically endorsed by some publishers, but rejected by others, and a source of controversy. One editor warned that while readers might admire the ‘nerve and ingenuity’ of advertisers who disguised their sales pitch in a news-style story, ‘he [sic] will bear an indefinite grudge against the paper’ (Baldasty, 1992: 67–8). However, some advertisers clearly did not share notions that news and advertising should not be mixed and instead viewed newspapers as central tools in their marketing campaigns. Advertisers sought and expected free publicity and promotion (‘puffs’) as the price of securing further advertising expenditure. According to Baldasty

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(1992: 71), both advertising agents and newspaper owners were ‘willing participants in the commercialization of newspaper content’, such that the ‘line between reading notices or puffs and legitimate stories about business enterprises … was sometimes narrow’. In the period Baldasty describes, pressures from advertisers intensified but some editors resisted pressure for free advertising or disguising ads as news. Printers’ Ink noted how suspicious editors could spike promotional stories and advised that ‘Free advertising for advertisers should generally be secured through the business end of the paper’ (Baldasty, 1992: 73), with business office personnel sometimes bribed to secure favourable news coverage. However, as the newspaper advertising market grew, papers promoted their public commitment not to carry unlabelled reading notices as part of their appeal to attract readers, and the practice of notices declined sharply in the 1890s (Ellman and Germano, 2009: 5). Moreover, news publishers in the Progressive Era (1890s to 1920s) sought to build reputations for objectivity during intensified competition for readers, and advertising revenue, served by normative principles of the separation of news and advertising. By the mid-20th century, the demarcation between news and advertising was institutionalised in the major US newspapers. In some instances, it was established in the architecture of buildings themselves, as part of the governance of separations between the business (advertising sales) and editorial sides of the firm. A notable example is the Chicago Tribune’s headquarters, where founder ‘Colonel’ Robert McCormick had separate elevators installed to carry the advertising and news divisions. Into the 1970s the advertising elevator did not stop on the news floors. The media magnate Henry R. Luce also promoted the strict separation of business and news at Time magazine. However, different types of ‘masked marketing practices’ continued to evolve in US papers, with advertorials becoming common, especially in magazines from the mid-20th century (Bachmann et al., 2019: 97; Ju-Pak et al., 1995). The format was addressed in an advisory option by the US Federal Trade Commission (FTC, 1968: 1307–8), where it noted that when a published message: uses the format and has the general appearance of a news feature and/or article for public information which purports [to be] independent, impartial and unbiased view … [but in fact is] paid for by advertisers, the Commission is of the opinion that it will be necessary to clearly and conspicuously disclose it is an advertisement.

Church and state In the classic formulation of mid-20th century American journalism, ‘church and state’, advertising and editorial, should be kept separate, divided by a ‘firewall’. These tropes have structured debates on advertiser influence and commercialism in US journalism (Schudson, 1978; Bagdikian, 2004; Rappleye, 1998). The processes of commodification and their resulting forms in newspapers are certainly not new,

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as Baldasty (1992) illustrates. The first ethics codes for news were established in the 1920s, partly in reaction to the excesses of sensationalist ‘yellow journalism’ (McManus, 1994: 201). But it was from the 1960s that one of the most successful newspaper chains, Gannett, became a market leader after adopting new technologies, reducing staff costs, and introducing ‘market-driven journalism’ (McManus, 1994). Under Al Neuharth, Gannett secured stockholder investment to fund aggressive expansion, generating profits considerably higher than most traditional newspaper owners were achieving, through a strategy of acquiring monopoly papers and increasing advertising rates (McManus, 1994: 202). Since the 1970s, stockholders came to expect high profits from newspapers held by publicly listed companies (Bagdikian, 2004). Journalistic professionalism, it is argued, survived largely in an economic context where profit margins of 5–7 per cent were acceptable, before returns of 15–20 per cent were required (Squires, 1994: 72–102; Hallin, 2000: 222–3). Accompanying the growing influence of business strategies in editorial content has been a shift in journalistic culture and professional outlook, responding in part to the economic pressures, uncertainty about the future of newspapers, and exigencies of fierce competition. Auletta (1998) captures the ambivalence of some professionals, quoting a Chicago Tribune bureau chief who justifies ‘better communication between business and editorial’, but warns, ‘I would be very troubled if I saw advertising guys talking to my reporters’. Five interrelated processes need to be distinguished here. First is the operational integration of formerly more separate departments, second is advertiser influence, third is corporate influence on media content, fourth are changes in the skills and training of personnel-shaping content, and fifth is a shift in the values of journalists themselves. In December 1999, the Los Angeles Times published a report by staff journalist David Shaw which severely criticised senior executives, while making renewed commitment that ‘[i]f the editorial mission and the commercial interests of the Times conflict, editorial integrity will always come first’ (Los Angeles Times, 1999). This unprecedented mea culpa was made in response to the publication of a 164page magazine supplement devoted to the Staples sports arena in Los Angeles which did not disclose that the $2 million advertising revenue the supplement raised would be split between the paper and Staples. This incident was a culmination of a longer process. In June 1995, the paper’s owner Times Mirror hired Mark Willes as CEO, a former executive at food giant General Mills, who had earned the title Cap’n Crunch for his labour cost-cutting. Willes declared he would ‘blow up’ the wall separating the newsroom from the business side. By 1998, Willes had secured significant backing from some staff journalists (Rappleye, 1998), although after the Staples incident 300 journalists signed a petition calling for all financial relationships that might comprise the paper’s ‘editorial heritage’ to be reviewed. Interviewed in 1998, Willes argued that the firewall was a ‘phoney issue’ because publishers had always had the ability to jump it, and cited instead the need for ‘standards’ of editorial integrity. Concern about the breaching of the firewall and the erosion of journalistic autonomy grew during the 1990s.

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Sponsored content in the digital age Across many countries journalistic media have struggled with diminishing advertising revenues, falling fee-paying audiences, reduced operating budgets, and intensifying competition from online media and platforms that are undermining the business models and structures of the older, ‘legacy’, news companies (Weaver and Willnat, 2012). Yet, for news journalism the pattern is highly uneven. The collapse of legacy newspaper businesses has accelerated alongside growth in digital-only journalism, albeit with fewer paid jobs than those lost. In most advanced economies, print advertising has been falling faster than digital ad revenue has risen. Classified advertising moved online from the mid-1990s in countries with above-average rates of household internet access. Print display advertising has been affected by cyclical factors such as the 2008 recession, and the Covid-19 pandemic in 2020, but has tended to decline structurally with the loss of job vacancy advertising, and with brand marketing shifting online. Print advertising revenue in UK consumer magazines shrank by more than half, from £512 million in 2010 to £220 million in 2018 (Sweney, 2019). The online ad market across America and Europe is dominated by Facebook and Google, taking 60 per cent of US digital ad revenue, leaving 40 per cent for the rest of the internet, including publishers (Perrin, 2019; News Media Alliance, 2020). In 2010, Google publicly disclosed that 68 per cent of revenue made through its AdSense ad network was passed to the publisher of the content ad, and 51 per cent of search revenue, yet AdSense became less relevant compared to Google’s Ad Manager, with the US Association of National Advertisers estimating that after taking account of advertisers’ payment for Google’s adtech services, publishers receive between 30 and 40 cents in every dollar, while the 2019 Cairncross Review of UK news publishers found that they received between 43 and 72 per cent of revenue generated from ads on publishers’ websites. (News Media Alliance, 2020). Declining sales and advertising revenue has increased pressure on legacy news organisations to find alternative sources of income from branded content. The latest phase of brand-sponsored content in editorial began in the early 2000s and grew most rapidly from the 2010s. Forbes’ Brand Voice started in November 2010 when it was originally named AdVoice. The New York Times (NYT) began its ‘Paid Posts’ service in late 2013. In January 2014, when it ran its first native advertisement (for Dell), the NYT attracted over 40 advertisers, with native advertising making up nearly 10 per cent of its total annual digital advertising revenue, $128 million (Sebastian, 2015). The period from 2012–14 was one of rapid revenue growth, market action, and debate. Native advertising was a key topic at the Cannes marketing festival in 2013 (Dvorkin, 2013) with forecasts of growth in native advertising spending of 69 per cent in 2015, reaching $7.9 billion from the 2013 level of $4 billion (Rosin, 2015). An American Press Institute Report (Sonderman and Tran, 2013) described how many commercial publishers placed ‘growing hopes for a new revenue stream … sponsored content’. A survey of 4,000 US marketers by Salesforce found that native advertising was the third most popular publishing strategy, along with video ads, becoming ‘an important component of most major brands’ marketing repertoire with a growth in the number of native advertising platforms’ (Richter, 2017).

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With marketers able to reach consumers more directly and effectively online and becoming less reliant on publishers to do so, commercial news brands moved to offer more integrated advertising opportunities (Marshall and Alpert, 2016). Ad tracker MediaRadar found more than 1,000 US publisher sites selling native advertising in 2017, up from 218 in 2015 (Moses, 2017). Branded content has become an increasingly important revenue stream for news publishers. According to a WAN-IFRA global study, news providers secured on average 20 per cent of their ad revenues from native content in 2017. The news executives surveyed expected that revenue share to increase to 36 per cent by 2021 (Carroll, 2019). While the proportion of total revenue has remained relatively small for some publishers, branded content made up around half of The Atlantic’s advertising revenue in 2013. Native advertising in publishing increased rapidly, with a majority of magazine publishers saying they offered or intended to offer native ads (Native Advertising Institute, 2016), yet still some way behind revenues from online display advertising. In the UK content and native advertising grew to £509 million in 2014, accounting for 22 per cent of all display ad spend, part of the 14 per cent increase in total digital advertising spending to a record £7.2 billion (Jackson, 2015). AdYouLike, in their Native Ads Research 2018, predicted that native advertising would grow to an $85 billion industry by 2020. According to BI Intelligence, the UK was expected to lead Europe in spending of £4.7 billion on native advertising by 2020 (Tan, 2017) For some digital native publishers, branded content was the biggest source of advertising revenue. BuzzFeed eschewed digital display ads until 2017 and instead depended for most of its revenue on branded content, notably its listicles (Sonderman and Tran, 2013; Marshall and Alpert, 2016). It had estimated revenue from native advertising of $120 million in 2014, with an average fee of $92,300 for each campaign (Agius, 2015). According to Chittum (2014), the economically successful adoption of native advertising by digital news outlets such as The Huffington Post and BuzzFeed influenced and encouraged adoption by established legacy publishers such as the New York Times and the Guardian. Publishers adopted a variety of models to develop branded content, with some larger publishers establishing content studios that integrated ad selling with content creation. Publishers moved into activities traditionally undertaken by advertising agencies, carrying out research for brands, creating ads, and promoting branded content across their own media and social media (Marshall and Alpert, 2016; Feng and Ots, 2018). The New York Times’ T Brand Studio in 2015 employed 110 people and generated some $35 million revenue, approximately 18 per cent of total digital advertising revenue (Marshall and Alpert, 2016). The Guardian launched its content marketing agency, Guardian Labs, in 2014, and by 2015 had worked on more than 400 branded content projects (Hayday, 2015). One such project involved a partnership with Vodafone across print and online to promote its global enterprise platform, Ready Business, launched in 2015. The content included a series of short two-minute videos featuring the actor Jessica Hynes, star of faux-reality comedy series 2012 and W1A, playing a stereotypical business guru character who spouts confusing jargon, a variant of her character from Perfect Curve PR and marketing

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agency in both series. The campaign was aimed at small and medium-sized enterprises (SMEs) and positioned Vodafone as a voice of reason and simplicity. Other activities included ‘Meet the mentor’ podcasts, 50 branded content articles, and a series of networking events (Newsworks, n.d.). Guardian Labs was remodelled in 2017 to make it more integrated with the newsroom. The restructured 62-person Labs team increased revenue by 66 per cent in the first half of 2018 (Davies, 2018). The model of in-house branded content agency has expanded worldwide. For instance, Pacific Magazines in Australia launched its agency Eve in 2019 (MediaWeek, 2019). The South China Morning Post created a branded content unit, Morning Studio, in 2018, creating an award-winning campaign ‘Building Connections’ for the Hong Kong Tourist Board (Campaign, 2019).

Sponsored content practices The New York Times published its first ‘paid post’ in January 2014 for Dell: a blue box on the homepage, alongside the masthead, which took those who clicked to a distinct URL (paidpost.nytimes.com) with a disclaimer stating: ‘This page was produced by the Advertising Department of the New York Times in collaboration with Dell. The news and editorial staffs of the New York Times had no role in its preparation’ (Riordan, 2014). A Times editor from its internal ‘content studio’, not the newsroom, pitched story ideas to Dell, with the approved story ideas farmed out to freelancers. Under the arrangements agreed, Dell’s paid posts would remain available after the three-month campaign ended. According to the Times, paid posts would not appear among editorial stories in search results and would not be indexed on Google in the same way as news stories (Riordan, 2014: 23; Sebastian, 2014). One of the most famous examples of sponsored editorial content is the New York Times’s 1,400-word article ‘Women Inmates’, sponsored by Netflix to promote the new series of Orange is the New Black in 2014. The online version of the post carried a small disclaimer at the bottom stating, ‘The news and editorial staffs of the New York Times had no role in this post’s preparation’ (Deziel, 2014). For supporters, a serious investigative report, with extensive accompanying multimedia, was underwritten by sponsorship. The native advertising was praised by some Times journalists, including former media correspondent David Carr (Crouch, 2016). According to the lead writer and creator, Melanie Deziel of T Brand Studio, the article ‘appeared in the mostemailed module on the home page of the New York Times’ (Johnston, 2018). For critics, the front-page news of a prestigious newspaper was turned into an advert. The following year the Wall Street Journal’s ‘Cocainomics’ series, to promote the Netflix series Narcos, was named the year’s best branded content partnership by Advertising Age magazine (Grimm, 2015). While such examples are often lauded in industry discourses, another example from 2013 garnered industry rebuke as an illustration of what to avoid. The Atlantic magazine, which, under the label ‘Sponsor Content’, ran an advertorial titled, ‘David Miscavige Leads Scientology to Milestone Year’, gave over its cover page to the Church of Scientology (Carlson, 2015). As one journalist blogged (Shewan, 2020):

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Although The Atlantic was quick to pull this disastrous foray into native advertising from its site soon after it went live, it will live on forever thanks to the fine folks at the Poynter Institute for Media Studies, who decided to permanently archive it – presumably to prevent such a tragedy from ever happening again. After this much-criticised debacle, The Atlantic revised its guidelines to state: ‘The Atlantic will refuse publication of such content that, in its own judgment, would undermine the intellectual integrity, authority, and character of our enterprise’ (Sonderman and Tran, 2013). Sponsored content offers to link brands to the qualities of prestige, engaged readers and reader trust publications can provide. Pricing reflects the differential value publications can offer. The pricing for sponsored content by 76 publications in 2015 showed large differentials in the rates that higher and lower valued publications could charge (Pollitt, 2017). Prices for one-off sponsored article ranged from Entertainment $50,000; Huffington Post $40,000; Business Insider $5,000; GIGAOM $2,000. Prices for ongoing relationships were priced at Forbes $50,000 per month, minimum three months ($150,000 total, unlimited articles); Gawker $50,000 activation cost, followed by $12,000 per article; CIO $20,000 for three months, two articles per week maximum. Research on user attitudes is examined in Chapter 9 but the underlying premise was tested by Network Research, which found that 20% of respondents are more likely to trust the brand sponsoring an advertorial – even if they are unfamiliar with the brand – if it is placed in a media outlet they know and trust; 63% give a neutral answer. However, even if respondents have a favourable opinion of a brand, if an advertorial is placed in a newspaper or medium they do not like or trust, 19% are more likely to lower their trust in that brand. (Chahal, 2017)

Digital native publishers The growth of native advertising reflects new pressures and opportunities, shifts in governing values across established media, and the spreading influence of formats and business models from the inaptly named ‘pure players’, digital-only publishers like BuzzFeed, Vice, Vox, and Huffington Post who attract a younger demographic via social media and mobile (Nicholls et al., 2016). In the 2000s, digital-only publishers like BuzzFeed adopted business models based on integrated native advertising: the firewall that was crumbling and then gleefully torpedoed by some news executives in the late 20th century, is now an archaeological curiosity for many of these contemporary publishers. BuzzFeed built its audience through shareable entertainment content. BuzzFeed’s business model was established on the basis of no display advertising but instead advertiser-funded content. The notable format, as for non-sponsored, attention-

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grabbing, and ‘snackable’ editorial content, was the listicle, articles using lists as their structure. Sponsored content for brands includes such listicles as ‘9 things that have changed in the last 20 years’ (BuzzFeed, 2013), paid for by Motorola. The aim is to create content that is engaged with and enjoyed, and there have been undoubted successes, valued for creativity and pleasure as much as monetary effectiveness. Some branded listicles have been subtle and imaginative, such as TV Land’s funded ‘13 things you’ll miss most from your twenties’ (BuzzFeed, 2015). Some have been overtly promotional, with knowing humour, such as Dunkin Donuts’ ‘Which Donut are you?’ (Vinderslev, 2015). In 2016, BuzzFeed advised that branded content and related agency services would account for nearly all of its $250 million annual revenue forecast, while Vice Media also anticipated that the majority of its projected $750–850 million revenue would come from sponsored content and agency work (Marshall and Alpert, 2016). Vice offers ‘sponsored content’ packages through Virtue, its faux-distinct in-house marketing agency (Auletta, 2018: 206–8). Yet, this has been anything but a smooth expansion of new business models for integrated advertising. The extent to which sponsored content can sustain profitability is uncertain, with some digital native publishers reliant on branded content struggling. BuzzFeed is a good illustration of such volatility. BuzzFeed’s revenues grew from $4 million in 2011 to $64 million in 2013 (Vinderslev, 2015). Yet, in 2017, BuzzFeed and Vice both missed revenue targets, while Mashable was sold for $50 million below market expectations. The original branded content model meant native ads were created in custom form for brands, requiring BuzzFeed to hire creatives and limiting take-up to major brands able to ‘commit hundreds of thousands of dollars at a time’ (Owens, 2019). Having previously boasted ‘You are more likely to summit Mount Everest than click on a banner ad’ (in the words of Jonathan Perelman, BuzzFeed’s vice president of agency Strategy), BuzzFeed added banner ads from 2017 organised through open exchanges such as Google’s AdX and Facebook’s Audience Network (Peterson, 2018). BuzzFeed also introduced the formerly eschewed display advertising, and programmatic ads, on BuzzFeed News. In an upbeat account, CEO Jonah Peretti told CNN in 2018 that the company generated over $100 million in revenue ‘from business lines that didn’t even exist in 2017’ (Radcliffe, 2019). These included native advertising/ecommerce deals for direct-toconsumer products marketed through native ads, with BuzzFeed sharing sales income (Owens, 2019). BuzzFeed employed 19 people writing commerce-related content in 2017, with ecommerce partnerships including videos on its Tasty cooking channel and listicles (such as ‘30 things under $10 you can get on Amazon that people actually swear by’ and ‘19 skincare products with dramatic before-and-after photos’) with affiliate links (Willens, 2017). In 2019, BuzzFeed developed shoppable recipes linking its Tasty channel recipes to Walmart online grocery orders, as part of a partnership that includes Tasty kitchenware and other products. Yet, in early 2019 BuzzFeed cut 200 staff jobs amid increasing digital advertising from the more powerful platforms such as Facebook whose revised algorithms also sent less traffic to Buzzfeed.com (Uberti, 2019). There were further job losses and salary reductions in 2020, but successes for BuzzFeed’s Direct Sold and Organic Affiliate businesses, with the revenue share from

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native advertising falling from 60 to 30 per cent between 2016 and 2019 (Guaglione, 2020). With branded content ‘expensive to create’, Casey McDevitt, commercial director for BuzzFeed Europe, commenting on Covid-19 impact, noted (McCarthy, 2020), ‘We’re fortunate that BuzzFeed has been diversifying our revenue for the past few years, enabling us to rely on our affiliate and commerce businesses as well as programmatic revenue increasing due to an increase in site traffic’. In May 2019 Vice Media reported it had raised $250 million in debt from investors and in October announced it would acquire the digital native publisher Refinery29 in a deal worth $400 million that valued the combined company at $4 billion. Yet, by May 2020, Vice Media announced it was laying off more than 150 staff due to financial difficulties, while in June 2020, Vice began an investigation into subsidiary Refinery29’s toxic work culture.

Corporate and institutional arrangements If some of the digital native publishers integrated branded content into their core business model, some legacy publishers, by contrast, have undergone more protracted transformations. The Guardian, like other legacy newspapers, is transitional; its unit, Guardian Labs, which organised 400 branded content projects in 2015, quarantines the journalistic labour of producing content that is paid for by marketers. Yet firewalls tumbled as commercial publishers engaged in an ever more desperate struggle for revenues. The corporate introduction of branded content navigated varying levels of criticism and resistance from companies’ own journalists and editorial staff, especially but not only in news journalism. The focus in this chapter is on understanding practices, but the attitudes of journalists towards sponsored content are examined more fully in Chapter 8. What is most relevant here is that the shift to sponsored content has occurred in the context of increasing job losses, precarity, de-professionalisation, and proletarianization of journalistic labour in some sectors and markets. There are indications of journalistic resistance softening in contexts of job losses. The Guardian had a pre-tax loss of £69 million in 2016, cut 260 jobs, and announced it was reducing its US workforce by a third. At the Independent newspaper, which cut pay and jobs when it switched to online-only publication in March 2016, the executive in charge of native advertising said journalists were initially ‘dragged kicking and screaming’, but that now they ‘saw the value of it’ (Ponsford, 2014). The introduction of branded content was also controversial at the NYT. Writing in PR Week, a Cramer-Krasselt marketing expert, Scott Smith, discussed apparent clashes between the then editor, Jill Abramson, and the business side of the paper, before her sacking: ‘According to reports, Abramson’s primary concern with native advertising was her belief that it could mislead readers into thinking the Times was the source of the work rather than an advertiser’ (Riordan, 2014: 24). Following the Netflix promotion, T Brand Studio went on to produce features on capital markets, sponsored by Goldman Sachs, as well as a feature on future cities, funded by fossil fuel giant Shell.

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The arrangements for native advertising in publishing illustrate three key trends: the proliferation of agencies and intermediaries in digital media/marketing; the corporate interlocking and integration across media and marketing; and the organisation of practices in ways that manage and respond to shifts in professional values and identities, working conditions, and power relations. This section will focus on the first two of these with further discussion on journalistic identities below. So far, we have identified our core actors as marketers, marketing agencies, and media. For publishing, we have identified legacy media and digital natives. For legacy media in particular, the work involved in contracting between the publisher and third-party marketers and in producing branded content may be undertaken in-house by existing sales and editorial teams, or by dedicated branded content teams, or contracted out. The second of these, the creation of content agencies, has been commonly adopted, located in a more liminal space, inside and outside the publisher’s editorial activities. Such arrangements enact a quarantining of labour and practices that reflects the influential legacy of church–state divisions. However, while that cultural-institutional influence is always present to some degree, it would be mistaken to attribute it as the dominant force, and even more so to assume that arrangements reflect the strength of ‘producer power’ and journalistic values. They may do so, but that needs to be demonstrated and not assumed in any specific institutional context. Studies show a range of configurations for branded content production and para-journalistic labour have developed. Sonderman and Tran (2013) identify four main business models then developing in US media: an underwriting model (brand as sponsor for publisher-controlled editorial); an agency model (publisher employs workers to create custom content in partnership with brands); a platform model (publisher provides space for publisher-owned content [e.g. Forbes’ BrandVoice]); and an aggregated/repurposed model where a publisher allows its content to be repurposed for brand communications. They identify the agency model as the most commonly adopted arrangement, comprising ‘a separate stable of writers/editors’, removed from the newsroom, although ‘newsroom people may have some say in final approval’ (Sonderman and Tran, 2013). Here a publisher ‘employs specialized writers and editors to help create custom content in partnership with a brand. The specialists balance the brand’s marketing goals with their own understanding of how to create engaging content, to make something that serves everyone’s needs’ (Sonderman and Tran, 2013). However, this schema identifies only one model for units within publications dedicated to branded content production, whereas there is now significant variation within this type. The authors also did not present, or perhaps countenance, a more integrated model with branded content being produced ‘within’ newsroom operations, as takes place, especially but not only within smaller publications, more team-based, and more horizontally organised entities (Medeiros, 2019). Chadha (2016) found that journalists at hyperlocal news startups composited their business and editorial duties to create a seamless identity oriented to public service. Boyles (2016) examines ‘intrapreneurial’ units whereby legacy publishers adopted innovative features from digital natives.

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New agencies and intermediaries There is increasing pressure, and incentives, for news publishers to produce or ‘curate’ more inexpensive content for digital platforms (Bakker, 2012). This includes new routes for commercial content to appear alongside or ‘within’ the editorial content of the publisher. A range of new agencies emerged from the 2000s, connected with publishing and content, such as content farms, where low-paid and mostly precarious workers produce articles designed to feature high up in web searches, or in feeds on publisher sites provided by content recommendation engines (or platforms), such as Outbrain and Taboola. As introduced in Chapter 1, a content recommendation engine presents the user with suggested content in specific areas on a web page demarcated by labels such as ‘Recommended for you’ or ‘You may be interested in’. Publishers have entered arrangements to cede parts of their online and mobile presence to companies who manage content on behalf of third-party suppliers. In April 2017, Trinity Mirror (now Reach, the UK’s largest news publisher) signed a global deal with native ad platform Adyoulike for the latter to drive in-feed ad units across the national Daily Mirror and regional publications (Tan, 2017). The production of ‘clickbait’ to serve these content recommendation sites includes work undertaken by so-called content farms. Such companies use search algorithm data to design and produce articles, videos, and other media content designed for search engine optimisation (SEO), to rank high in search results, and generate advertising revenue from search and via the circulation of content on social media. There is a spectrum of production not captured by these critical terms, and some companies supplying informational content, such as Demand Media’s eHow, would defend their output. The associations with not only low-quality content for profit but misinformation has certainly damaged the reputation of the sector, but such content production covers a spectrum from the criminal to businesses serving the growth of brands’ own content and brand journalism (Bull, 2013). One custom content platform, BrandAmp by AAPR, promises ‘inspiring, educational and persuasive brand stories to a receptive and exclusive audience, all with the look and feel of AARP’s award-winning editorial’ (IAB [Interactive Advertising Bureau], 2018). Content recommendation and the programmatic native advertising processes involved are discussed more fully in Chapter 5, and brand’s own and contracted publishing in Chapter 6.

Employment status and conditions The conditions of those working in branded content is underexamined. However, it is clear that features identified in studies of work in media and creative industries are present. Broader trends include shifts from salaried (salariat) to freelance and project or piece work arrangements. For the latter, there are proficiens, those with scarce resources and talents, who can command higher rates of pay, and the precariat, those with low or volatile incomes, lack of job security and in-work benefits (Standing, 2016; Bakker, 2012). Against the downward employment trends, digital news

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publishing has been a source of jobs growth. Startups like BuzzFeed, Huffington Post, Vox, and Business Insider were the generators of most new jobs in the US news industry (Jurkowitz, 2014). Between 2008 and 2019 some 6,000 jobs were created in digital-native newsrooms, a 79 per cent increase. However, ‘too few newsroom positions were added to make up for recent losses in the broader industry’ (Greico, 2018). Digital native publishers have themselves faced considerable turbulence in recent years, after initially strong growth. A Pew Research Center report found that nearly a quarter of digital publishers laid off workers during 2017–18, despite the increase in employment in this sector overall. At the start of 2019, BuzzFeed announced plans to cut around 15 per cent of its total workforce, while Vice cut 10 per cent of staff in a restructuring of the business after missing revenue targets in 2018 (Willens, 2019). In 2020, as the Covid-19 pandemic struck, branded content teams were cut back at publishers, including The Atlantic, CNN and The Telegraph (McCarthy, 2020).

Magazine, lifestyle, B2B, B2C, and other journalisms Much of the academic literature on branded content in journalism, whether affirmative, descriptive, or critical, has tended to focus on news publications. The extent to which branded content impacts on the production and circulation of news and information is clearly of huge significance. Yet, the ordering of attention and value towards ‘hard’ news is also problematic, both for understanding the phenomena and for identifying and addressing problems. Research by the Native Advertising Institute in 2016 showed that around a third of news and magazine publishers had created their own native advertising studios (Cain, 2017). Magazine publisher Condé Nast revealed that native advertising accounted for half of its total digital adverting revenue (Cain, 2017). Historically, the relationship between journalism and commercial interests, as sources and suppliers of public relations, as advertisers and as objects of attention for news and editorial, varies between economic sectors, media type, and features in the media system. Business-to-consumer magazines in sectors such as fashion and retail, health and beauty, sports and leisure have always had comparatively closer relationships and interdependency with the sectors covered, than the separation norms for news and financial journalism. Consumer magazines have had a closer relationship with the brands who feature in editorial and on whose advertising the publication depends, especially the more focused the market sector. The normative frameworks of church– state are articulated around ‘hard’ news and can have less purchase the further practice differs, although how editorial standards are articulated and negotiated always requires careful, engaged research. If there are historically embedded norms and institutional cultures that inform the prevailing norms and culture at individual firms, and groups working within, there is also increasing volatility and dynamic interaction across sectors. Further, within individual publications, attitudes towards the relationships between marketers and media can vary considerably across sections and teams. My own research on the extent to which Murdoch’s UK newspapers cross-promoted the co-owned Sky television showed differences in how the paper’s agreed policies on disclosing the ownership link were observed and performed across business, news,

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sports, arts, TV critics, and in the more anonymised spaces of TV listings, previews, and graphical display (Hardy, 2010).

Beyond the firewall: Changes in journalistic practices and cultures The focus in this chapter is mapping changes in practice, whereas the critical debates on those practices and their relationship to both governance and journalistic attitude and identities are explored in more detail in Chapter 8. However, it is helpful to trace the main contours of normative shifts and debate here. The church–state firewall has been eroded in legacy news media and is residual, at best, in the normative and operational architecture of some digital native publishers. It was always upheld and applied differentially across publishing. In general, the strongest separation norms have been in more elite news and financial publishing, although that is an inaccurate guide to actual practice. The more accommodating and transactional interrelationships have tended to be in consumer magazine and sections, or B2B, where the relationships between media, marketers, and readership are close, although again with plenty of contrary examples of strong separation designed to serve readers. Even The Furrow, an early example of branded content (Chapter 1), established a culture of editorial authority, if never autonomy from the brand, John Deere. Interviewed in 2013, the publication manager David Jones said, ‘Even the most technical subject has to have a human story behind it … We’ve always been able to convince the management that the content shouldn’t be about John Deere equipment. We’ve stuck to that over time’ (Gardiner, 2013). Yet the blurring of editorial and brand is also acknowledged, but located in a unity of reader affiliation: When I came into this position last year, I was trying to familiarize myself with the brand on the editorial side, and I kept feeling a little like Harry Potter, lost in a new world. [The Furrow] is a portal into a brand that people feel passionately about – to the level that kids are wallpapering their rooms with [our] tractors. … You just don’t run across that every day. (Gardiner, 2013) The presence of para-journalistic activity created blurred lines and liminal spaces long before the modern, industrial-scale production of branded content. The tensions between journalism and public relations, between the avowed editorial independence of journalistic output and dependency on or reproduction of source supply, are long-standing. In post-war Britain, the first Royal Commission on the Press was urged by the National Union of Journalists and others to examine the influence of advertisers on editorial policy, and acknowledged that there may be direct or indirect pressure to avoid publishing anything detrimental to advertisers’ interests (RCP [Royal Commission on the Press], 1949: 135). However, neither this nor the subsequent two Royal Commissions in 1962 and 1977 met the need for systematic study to underpin policy proposals; the examples of advertiser influence presented were instead treated as isolated instances to be rebuked (RCP

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[Royal Commission on the Press], 1949: 143; Hardy, 2020). Likewise, the relationship between news agency support and in-house journalism, creating liminal editorial spaces, was well established by the 19th century. In the later 20th century, as news publication resources contracted, publishers have sought to contract out supply of a wider range of content, from more traditional areas such as international news to television and radio listings. In some publications, and sectors, there is a close relationship between the organisation of earned media (public relations) and paid media (branded content). In the standard, traditional model, public relations material such as news releases was selected and used on the basis of editorial control. It was ‘earned’ because the content supplied fitted the publication’s editorial judgement of value to readers such that the material was carried in some form. A publishable news release might be reproduced in full, rejected, or edited, re-written, and re-formatted to varying degrees. In some sectors the earned/paid distinction blurred with the introduction of payment elements such as ‘colour separation’ charges. Here a publication would accept to run a story supplied by a firm or PR agency, but attribute charges for colour images to generate income while, in part, avoiding the legal-regulatory requirements associated with paid communications. Such arrangements tended to suit the larger PR firms who could meet the charges and transaction costs and benefited from a vehicle for privileged access and editorial exclusion. By the same token the arrangements were challenged by smaller PR operatives for whose clients the costs were more significant, some of whom established the (UK) Campaign for Editorial Independence, in whose work I was briefly involved in the 1990s. So, one form of liminality is a division of labour in which the re-writing of press releases is done by workers assigned exclusively or principally to that task. The situation was vividly illustrated to me in 2016 by a young British journalism graduate whose job was to recycle PR material and who worked in a portacabin, a physical annex set apart from the more traditionally demarcated journalists who regarded him as a second-class service worker. It may only be speculated how far insecurity and fear conspired against workplace solidarity, but a graduate, fresh with the enthusiasm and ideals of journalism, was experiencing multiple levels of alienation. The liminality is also stretched as publishers have adopted so many different arrangements for the organisation of branded content, across planning and negotiation, production and co-production, design, publication, sales, and contract relations (MacRury, 2017). The Daily Mail adopted a more integrated model, encouraging or requiring editorial staff to participate in the production of brand-sponsored content and paying extra for this, a move described as ‘a popular gig’ by one former reporter (Crouch, 2016: 16). Larger publishers usually have rules and guidance on handling native advertising, which forms part of the governance of branded content examined in Part II. The Telegraph’s guidelines on ‘Payments in respect of the creation of commercial content’ states: All payments to staff and contributors for the creation of commercial content must be approved by their line manager in advance in writing. Commercially

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funded positions in editorial are permitted but hires must be made by editorial and such staff must work to editorial contracts and in line with editorial standards. Here, paid content is incorporated into the structuring of ‘editorial’ labour. The safeguarding of editorial line manager control indicates the sensitivity to, and influence of, working journalists, but the values of such management are themselves in flux and contested, including in relation to editorial-advertising divides (Chapter 8). Another variant is the use of freelance staff with varying levels of independence from the purchasing publication. Some papers have enforced stricter demarcations. At the Financial Times, none of the paper’s journalists were initially involved in writing paid-for content, according to a former news editor (Crouch, 2016). However, the FT now presents paid editorial content, including articles and shortform videos, on its site FT Transact, launched in May 2017. FT Transact includes a hub on FT.com, a YouTube channel and social media pages, offering ‘insightful but accessible reporting and analysis from FT Journalists who are specialists in their fields, FT Transact brings additional expert commentary from UBS in the form of partner content on the future of capital’ (Financial Times, 2020).

Journalistic roles and identities The extent to which those who self-identify as journalists advance attitudes towards branded content that are hostile, supportive, ambivalent, or conflicted is examined in Chapter 8. Here, the focus is on the organisational arrangements that give rise to such attitudes. First, it is vital to emphasise the complex ways in which demarcations are enacted and dissolved. In considering the organisational dimensions here, an important feature is the hybridisation arising from the movement and merging of individuals across workspaces and domains. AdWeek’s tech editor, Josh Sternberg, describes how ‘my career path [has] kind of ping-ponged between the editorial side and the business side’ (Patterson, 2018). There is an extensive literature from practitioners and researchers tracking the movement of journalists to other sectors, such as public relations, and specialist fields, such as public affairs (Viererbl and Koch, 2019). For branded content, the most relevant movements are those between ‘media’ and ‘marketing’, and ‘editorial’ and ‘business’. Branded content is produced by journalists, former journalists, early-career freelancing and aspiring journalists, and by para-journalistic content creators of diverse kinds. The upholding of firewall separation has been under attack from media owners and senior managers, especially since the 1970s. In such discourses, firewall proponents are characterised as traditionalists, resistant to change or incapable of the necessary adaptions. Such framing is also adopted by scholars of journalism and media, including those associated with more critical-cultural perspectives, and I offer a review and critique of such aligned perspectives in Chapter 10. Here I want to highlight another more useful and insightful approach that can help avoid the deficiencies of overly normative framings around resistance to or adaption to ‘change’. For Carlson (2015:

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861), media abundance has increased the strategic importance for news publishers of advertising content itself in generating audiences. In his study of native advertising, Carlson (2015: 861) highlights a shift in journalistic values, with ‘norm entrepreneurs’ embracing native advertising as part of a ‘broader curational norm of providing a coherent mix of both editorial and advertising content’, to attract readers to stay, return, and share content in the context of economic imperatives to attract advertising revenue. Here, a normative discourse upholding separation on behalf of readers is displaced and replaced by one that advances a different vision of serving readers. Research on the perspectives of news organisation staff includes Artemas et al. (2018); Coddington (2015); and Drew and Thomas (2018). Serazio (2019a; 2019b) conducted 28 in-depth interviews with brand journalism professionals who operate in the United States. Drew and Thomas (2018) interview individuals in editorial and business departments. The general findings of these Euro-American studies are that pre-existing church–state walls have become progressively more porous (Carlson, 2015; Coddington, 2015; Ferrer-Conill, 2016). The adoption of sponsored content has been accompanied by the creation of ‘hybrid editors’ (Poutanen et al., 2016), working at the intersection of brand promotion and journalistic work. The expansion of ever-evolving forms of branded content creates a blurring of storytelling craft and journalistic purposes that was more rigorously demarcated under previous governance arrangements. How journalistic authority is being reconfigured and how this may be assessed in relation to qualities of voice, access, reporting, and communication exchange need careful, situated examination. Important processes are underexamined, including the negotiation of brand copy requirements and copy approval. What is clear, though, is that journalistic identities are subject to a series of conflicting pressures. There is a blurring of boundaries between journalism and other communications, between professional and amateur, and between producers, prosumers, and users of content. There is blurring between human-based and automated journalism. There is blurring across content, and between a journalism of information and entertainment in particular. There is blurring between journalism and paid (advertising), earned (PR), and third-party owned communications. A host of other boundaries are dissolving or being reconfigured, including convergence across platforms and forms, across specialisms and sub-genres of journalism. The condition has been described as one of increasing ‘liquidity’, drawing on Zygmunt Bauman’s influential concept, not only of rapid change but also of the inability to form more stable identifications in response to such change. Bauman (2005: 1) describes ‘a society in which the conditions under which its members act change faster than it takes the ways of acting to consolidate into habits and routines. Liquid life … cannot keep its shape or stay on course for long.’ For Singer (2011), increasing ‘fluidity’ is applicable across the whole enterprise of journalism, from structures to products and processes. For Deuze (2005: 450), ‘[t]he high modernism of journalistic professionalization has moved to a liquid modern state of affairs of feverish journalistic differentiation across media genres (including popular, tabloid, and infotainment journalisms), platforms, and industries’. This chapter has outlined the growth and integration of sponsored content within journalism. Boundaries between journalism and commercial interests are relatively

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more fluid at digital natives than legacy news organisations and more differentiated across sectors, such as lifestyle and business-to-business. Researchers find that roles for staff increasingly overlap (Drew and Thomas, 2018: 199; Porlezza and Splendore, 2016). Researchers draw variously on organisational sociology, social psychology, cultural anthropology, and transdisciplinary media industries studies. Analysis of branded content as a liminal space between editorial and advertising sales connects to wider analysis of practices, cultures, and identities of those engaged in and around journalisms (Chapter 8). It is important to avoid an overly generalised account of liquidity. Not all boundaries are blurred, some remain sharp, and many are defended in ways that sustain collective values and identity-work. Singer (2011) highlights efforts to shore up identities; journalists ‘have sought to define who they are and what makes them distinct’, and asserted, ‘boundaries between themselves and other content providers in the open environment of the Internet’. Another route taken has been to embrace changing selfperceptions and definitions about what journalists do and their normative role in the world (Singer, 2011). This embraces shifts from gatekeeping to sense-making roles, or from notions of strict objectivity towards more personal, engaged, interpretative roles, involving greater reflexivity towards source information supply. How that reflexivity encounters brand sponsorship is examined further in Chapter 8.

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Drew, K. and Thomas, R. (2018) ‘From separation to collaboration’, Digital Journalism 6(2): 196–215. Dvorkin, L. (2013) ‘Inside Forbes: What’s next for native ads? Controversy gives way to market realities’, Forbes, 8 July. https://www.forbes.com/sites/lewisdvorkin/2013/07/08/ inside-forbes-whats-next-for-native-ads-controversy-gives-way-to-market-realities/#439a 316874b9. Ellman, M. and Germano, F. (2009) ‘What do that papers sell? A model of advertising and media bias’, The Economic Journal 119(537): 680–704. Enders Analysis (2011) Competitive Pressures on the Press: Presentation to the Leveson Enquiry. http://www.endersanalysis.com/content/publication/competitive-pressures-press-present ation-leveson-inquiry. Feng, S. and Ots, M. (2018) ‘Seeing native advertising production via the business model lens: The case of Forbes’s BrandVoice Unit’, Journal of Interactive Advertising 18(2):148–161. Ferrer-Conill, R. (2016) ‘Camouflaging church as state: An exploratory study of journalism’s native advertising’, Journalism Studies. doi:10.1080/1461670X.2016.1165138. Financial Times (2020) FT Transact. https://transact.ft.com/ (accessed 22 December 2020). Franklin, B. (2009) ‘Introduction’ in B. Franklin (ed.) The Future of Newspapers. London: Routledge. FTC (1968) ‘Advisory opinion digests’. https://www.ftc.gov/sites/default/files/documents/ commission_decision_volumes/volume-73/ftcd-vol73january-june1968pages1289-end.pdf. FTC (2015) Enforcement Policy Statement on Deceptively Formatted Advertisements, 22 December. Washington, DC: FTC. https://www.ftc.gov/public-statements/2015/12/commissionenforcement-policy-statement-deceptively-formatted. Gans, H. (1980) Deciding What’s News. London: Constable. Gardiner, K. (2013) ‘The story behind ‘The Furrow’, the world’s oldest content marketing’, Contently, 3 October. https://contently.com/2013/10/03/the-story-behind-the-furrow-2/. Greenslade, R. (2019) ‘Financial Times thrives by focusing on subscriptions’, The Guardian, 14 April. https://www.theguardian.com/media/commentisfree/2019/apr/14/financial-timesthrives-by-focusing-on-subscriptions. Greico, E. (2018) ‘Newsroom employment dropped nearly a quarter in less than 10 years, with greatest decline at newspapers’, Pew Research Centre, 30 July. https://www.pewresearch.org/fa ct-tank/2018/07/30/newsroom-employment-dropped-nearly-a-quarter-in-less-than-10-years -with-greatest-decline-at-newspapers/. Grimm, J. (2015) ‘The best branded content partnerships of 2015’, Advertising Age, 10 December. https://adage.com/article/digitalnext/brand-content-partnerships-2015/301683. Guaglione, S. (2020) ‘BuzzFeed claims profitability in 2020’, Publishers Daily, 5 November. Hallin, D. (2000) ‘Commercialism and professionalism in the American news media’ in J. Curran and M. Gurevitch (eds) Mass Media and Society, 3rd Edition. London: Arnold. Hardy, J. (2010) Cross-Media Promotion. New York: Peter Lang. Hardy, J. (2020) ‘Economics: Ownership and competition’ in M. Conboy and A. Bingham (eds) History of Newspapers and Periodicals in Britain and Ireland 1650–2011, Vol 3. Edinburgh: Edinburgh University Press. Harms, B., Bijmolt, T.H.A., and Hoekstra, J.C. (2017) ‘Digital native advertising: Practitioner perspectives and a research agenda’, Journal of Interactive Advertising 17(2): 80–91. Hayday, G. (2015) ‘Guardian Labs: Our New Year resolutions for 2016’, The Guardian, 21 December. http://guardianlabs.theguardian.com/blog/info/2015/dec/21/guardian-labs-ournew-year-resolutions-for-2016. Hoofnagle C.J. and Meleshinsky, E. (2015) ‘Native advertising and endorsement: Schema, source-based misleadingness, and omission of material facts’, Technology Science, 15 December. http://techscience.org/a/2015121503.

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IAB [Interactive Advertising Bureau] (2018) Publisher Branded Content Studio Directory. https:// www.iab.com/iab-publisher-branded-content-studio-directory/ [unavailable]. IAB [Interactive Advertising Bureau] (2019) Native Advertising Playbook 2.0, May. New York: IAB. ICFJ (2017) ICFJ Survey: The State of Technology in Global Newsrooms. https://www.icfj.org/ our-work/state-technology-global-newsrooms. IPR [Institute of Public Relations] (1998) IPR Guideline 3: Resolving the Advertising/Editorial Conflict, June. London: IPR. Jackson, J. (2015) ‘UK adults willing to pay only 92p a month to access news websites’, The Guardian, 9 April. http://www.theguardian.com/media/2015/apr/09/uk-news-website s-iab-digital-ad-spend-2014. Johnston, M. (2018) ‘How to rock mobile native advertising’, Content Marketing Institute, 8 February. https://contentmarketinginstitute.com/2018/02/mobile-native-advertising/. Ju-Pak, K.H., Kim, B.H., and Cameron, G.T. (1995) ‘Trends in the use and abuse of advertorials in magazines’, Mass Communication Review 22(3–4): 112–128. Jurkowitz, M. (2014) ‘The growth in digital reporting’, Pew Research, 26 March. Los Angeles Times (1999) ‘To our readers’, Los Angeles Times, 19 December. Lynch, L. (2018) Native Advertising: Advertorial Disruption in the 21st Century News Feed. Abingdon: Routledge. MacRury, I. (2017) ‘Branded content: Rupture, rapture and reflections’, Journal of Promotional Communications 5(3): 248–259. Marshall, J. and Alpert, L. (2016) ‘Publishers take on ad-agency roles with branded content’, Wall Street Journal, 11 December. https://www.wsj.com/articles/publishers-take-on-ad-a gency-roles-with-branded-content-1481457605. McCarthy, J. (2020) ‘How publishers are getting around the branded content slump’, The Drum, 1 October. https://www.thedrum.com/news/2020/10/01/how-publishers-are-getting-aroundthe-branded-content-slump. McChesney, R. (2013) Digital Disconnect. New York: The New Press. McManus, J.H. (1994) Market-Driven Journalism: Let the Citizen Beware? London: Sage. Meade, A. (2020) ‘Google, Facebook and YouTube found to make up more than 80% of Australian digital advertising’, The Guardian, 23 October. https://www.theguardian.com/m edia/2020/oct/23/google-facebook-and-youtube-found-to-make-up-more-than-80-of-a ustralian-digital-advertising (accessed 20 December 2020). Medeiros, V. (2019) Youth Media and the Business of Content: Conflict, Agency and Counterhegemony in a Branded Age, unpublished thesis. London: Goldsmiths College. Mediatique (2018) Overview of Recent Dynamics in the UK Press Market. London: DCMS. Mediaweek (2019) ‘Pacific launching branded content and marketing agency Eve’, Mediaweek, 18 February. https://mediaweek.com.au/pacific-launching-branded-content-and-marke ting-agency-eve/. Moses, L. (2017) ‘“The model can’t hold”: Publishers face content studio growing pains’, Digiday, 9 March. https://digiday.com/media/model-cant-hold-publishers-face-contentstudio-growing-pains/. Native Advertising Institute (2016) ‘6 things all brands and publishers need to know about native advertising’, 4 July. https://nativeadvertisinginstitute.com/blog/6-things-all-brands-andpublishers-need-to-know-about-native-advertising/. Newman, N. (2018) Journalism, Media, and Technology Trends and Predictions 2018. Oxford: Reuters Institute for the Study of Journalism. Newman, N. and Levy, D. (2014). Reuters Institute Digital News Report. https://reutersinstitute. politics.ox.ac.uk/sites/default/files/research/files/Reuters%2520Institute%2520Digital% 2520News%2520Report%25202014.pdf.

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News Media Alliance (2020) ‘Big tech says publishers keep majority of ad revenue, but experience suggests otherwise’, NMA, 16 November. https://www.newsmediaalliance. org/google-ad-revenue-op-ed-70-percent/. Newsworks (n.d.) ‘Vodafone – business made simple’, Newsworks. https://www.newsworks. org.uk/resources/vodafone-ad-case-study. Nicholls, T., Shabbir, N., and Nielsen, R. (2016). Digital-born News Media in Europe. Oxford: Reuters Institute for the Study of Journalism. Ofcom (2017) Public Interest Test on the Proposed Acquisition of Sky plc by Twenty-First Century Fox, Inc. https://www.ofcom.org.uk/__data/assets/pdf_file/0012/103620/public-interest-test-rep ort.pdf. Owens, S. (2019) ‘How BuzzFeed is solving native advertising’s scale problem’, What’s New in Publishing, 8 October. https://whatsnewinpublishing.com/how-buzzfeed-is-solving-nativeadvertisings-scale-problem/. Parker, G. (2016) ‘Hidden ads risk killing native not the ASA’, ASA, 27 January. https:// www.asa.org.uk/news/hidden-ads-risk-killing-native-not-the-asa.html. Patterson, D. (2018) ‘Why native advertising and branded content works’, TechRepublic, 12 May. https://www.techrepublic.com/article/why-native-advertising-and-branded-contentworks/. Perrin, N. (2019) ‘Facebook–Google duopoly won’t crack this year’, eMarketer, 4 November. https://www.emarketer.com/content/facebook-google-duopoly-won-t-crack-this-year. Peterson, T. (2018) ‘Inside BuzzFeed’s pivot to programmatic advertising’, Digiday, 9 March. Pollitt, C. (2017) ‘How publishers can increase sponsored content renewal rates 133%’, Native Advertising Institute, 11 May. https://blog.nativeadvertisinginstitute.com/sponsored-contentrenewal-rates. Ponsford, D. (2014) ‘Going native: Why journalists need to be involved in taming advertising’s new Wild West’, Press Gazette, 7 May. http://www.pressgazette.co.uk/content/ going-native-why-journalists-need-be-involved-taming-advertisings-new-wild-west. Ponsford, D. (2017) ‘Labour Force Survey: Sharp drop in freelancers accounts for 11,000 fall in the total number of journalists in the UK’, Press Gazette, 20 September. Porlezza, C. and Splendore, S. (2016) ‘Accountability and Transparency of Entrepreneurial Journalism: Unresolved Ethical Issues in Crowdfunded Journalism Projects’, Journalism Practice 10(2): 196–216. Poutanen, P., Luoma-Aho, V., and Suhanko, E. (2016) ‘Ethical Challenges of Hybrid Editors’, International Journal on Media Management 18(2): 99–116. Radcliffe, D. (2019) ‘More than just cat memes: BuzzFeed’s major eCommerce expansion’, What’s New in Publishing, 8 November. https://whatsnewinpublishing.com/more-thanjust-cat-memes-buzzfeeds-major-ecommerce-expansion/. Ramsay, G. and Moore, M. (2016) Monopolising Local News. London: Kings College London. Rappleye, C. (1998) ‘Cracking the church–state wall: Early results of the revolution at the Los Angeles Times’, Columbia Journalism Review, January/February: 20–23. RCP [Royal Commission on the Press] (1949) 1947–1949 Report. London: HMSO. RCP [Royal Commission on the Press] (1962) 1961–1962 Report. London: HMSO. Richter, S. (2017) ‘The future of native advertising for brands and publishers’, The Entrepreneur, 9 March. Riordan, K. (2014) ‘Accuracy, independence, and impartiality: How legacy media and digital natives approach standards in the digital age’, Reuters Institute for the Study of Journalism. https:// reutersinstitute.politics.ox.ac.uk/our-research/accuracy-independence-and-impartiality-howlegacy-media-and-digital-natives-approach.

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Rosin, B. (2015) ‘Why native advertising is a no-brainer for publishers and marketers’, Publishing Insider, 5 March. https://www.mediapost.com/publications/article/245070/ why-native-advertising-is-a-no-brainer-for-publish.html. Royal Commission on the Press (1949) 1947–1949 Report. London: HMSO. Rusbridger, A. (2018) Breaking News: The Remaking of Journalism and Why It Matters Now. Edinburgh: Canongate. Schudson, M. (1978) Discovering the News. New York: Basic Books. Sebastian, M. (2014) ‘Native ad spending to jump despite marketer reservations’, Advertising Age, 21 November. https://adage.com/article/digital/native-ad-spending-jumps-marketers-re servations/295956. Sebastian, M. (2015) ‘Native ads were ‘inside’ 10% of digital at the New York Times last year, Advertising Age, 3 February. https://adage.com/article/media/york-times-sold-18-2-millionworth-native-ads/296966. Serazio, M. (2019a) ‘Making (branded) news: The corporate co-optation of online journalism production’, Journalism Practice: 1–18. Serazio, M. (2019b) ‘The other ‘fake’ news: Professional ideals and objectivity ambitions in brand journalism’, Journalism. doi:10.1177/1464884919829923. Shewan, D. (2020) ‘Native advertising examples: 5 of the best (and worst) [blog]. https:// www.wordstream.com/blog/ws/2014/07/07/native-advertising-examples. Singer, J.B. (2011) ‘Journalism in a Network’, in M. Deuze (ed.) Managing Media Work. London: Sage. Sonderman, J. and Tran, M. (2013) ‘Understanding the rise of sponsored content’, American Press Institute, 13 November. https://www.americanpressinstitute.org/publications/reports/ white-papers/understanding-rise-sponsored-content. Sparks, C. (1999) ‘The press’ in J. Stokes and A. Reading (eds) The Media in Britain. Basingstoke: Macmillan. Squires, J. (1994) Read All About It!New York: Times Books. Standing, G. (2016) The Precariat: The New Dangerous Class. London: Bloomsbury. Sullivan, A. (2014) ‘Andrew Sullivan on native ads: Journalism has surrendered’, Digiday, 7 May. https://digiday.com/media/andrew-sullivan-native-ads/. Sweney, M. (2019) ‘Between the covers: How the British fell out of love with magazines’, The Guardian, 14 September. https://www.theguardian.com/media/2019/sep/14/ between-the-covers-how-the-british-fell-out-of-love-with-magazines. Tan, E. (2017) ‘Trinity Mirrors signs global deal with native advertising platform’, Campaign, 5 April. Turow, J. (2011) The Daily You. New Haven, CT: Yale University Press. Uberti, D. (2019) ‘BuzzFeed and the digital media meltdown’, Columbia Journalism Review, 11 March. https://www.cjr.org/business_of_news/buzzfeed-future-jonah-peretti-union.php. Viererbl, B. and Koch, T. (2019) ‘Once a journalist, not always a journalist? Causes and consequences of job changes from journalism to public relations’, Journalism: 1–17. doi:10.1177/1464884919829647. Vinderslev, A. (2015) ‘Buzzfeed: Top 10 examples of BuzzFeed doing native advertising’, Native Advertising Institute, 30 September. https://blog.nativeadvertisinginstitute.com/ 10-examples-buzzfeed-native-advertising. WAN/IFRA (2009) World Press Trends 2009. http://www.wan-ifra.org/microsites/worldpress-trends. WAN/IFRA (2016) World Press Trends 2016. http://www.wan-ifra.org/microsites/worldpress-trends. WAN/IFRA (2017) World Press Trends 2017. https://blog.wan-ifra.org/2017/06/08/ world-press-trends-2017-the-audience-focused-era-arrives-0.

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Waterson, J. (2018) ‘More than a million readers contribute financially to the Guardian’, The Guardian, 5 November. https://www.theguardian.com/media/2018/nov/05/guardian-passes1m-mark-in-reader-donations-katharine-viner. Waterson, J. (2019) ‘Read all about it? How local papers’ decline is starving communities of news’, The Guardian, 8 May. https://www.theguardian.com/uk-news/2019/may/07/readall-about-it-how-local-papers-decline-is-starving-communities-of-news. Weaver, D. and Willnat, L. (eds) (2012). The Global Journalist in the 21st Century. New York: Routledge. Willens, M. (2017) ‘BuzzFeed now has 19 people writing commerce content’, Digiday, 15 November. https://digiday.com/media/buzzfeed-now-19-people-writing-commercecontent/. Willens, M. (2019) ‘Following layoffs, Vice Media signals an end to its freewheeling days’, Digiday UK, 4 February. https://digiday.com/media/following-layoffs-vice-media-pitches-amore-mature-story-and-business/. Wojdynski, B. (2016) ‘Native advertising: Engagement, deception, and implications for theory’ in R. Brown, V. Jones, and B. Wang (eds) The New Advertising: Branding, Content and Consumer Relationships in a Data-Driven Social Media Era. Santa Barbara, CA: Praeger/ ABC Clio. Wojdynski, B. and Evans, N. (2016) ‘Going native: Effects of disclosure position and language on the recognition and evaluation of online native advertising’, Journal of Advertising 45(2): 157–168. Wolff, M. (2007) ‘Is this the end of news?’, Vanity Fair, October. ZenithOptimedia (2018) Advertising Expenditure Forecasts March 2018. https://www.zenithmedia. com/wp-content/uploads/2018/03/Adspend-forecasts-March-2018-executive-summary.pdf.

3 BRANDED ENTERTAINMENT AND PRODUCT INTEGRATION

Media and marketing communications integration in television and digital media includes sponsorship, ad-financed TV, product placement, virtual advertising, advergames, and more. This chapter explores the range and evolution of practices by which commercial communications feature in entertainment audiovisual content and discusses how product placement and brand integration have been addressed in regulation. Marx famously began his study, Capital (Marx, 2013), with the analysis of commodities, the elementary form of wealth in capitalist societies. Likewise, but more modestly, I propose we can better understand television, past and present, by analysing not just the commodity form of television but the promotion of commodities in television, and within programmes themselves. Product placement, the paid placement of brands in television shows, is a feature of commercial television’s past which is being re-invented as its salvation today, yet it remains a controversial, contested practice. There has, though, been a close and enduring relationship between brands and media content, especially in entertainment media. Murdock (1992: 226) notes how, from its inception, cinema ‘enjoyed an intimate relationship with mass consumption’, filming a world ‘saturated with branded goods and advertising displays’. This, then, is a story that connects television production and consumption, economics, technology, culture, regulation, and ethics, and one that invites you to take a view on the challenges and trade-offs for media and marketing businesses, and on the suitability of branded content across contemporary communications.

Free-to-air commercial television The 1954 Television Act established a UK commercial television service, ITV, whose main source of finance would be from paid advertisements shown in breaks during and between programmes. The service would be free, once users had bought a television set, and paid an annual television licence fee, most of which DOI: 10.4324/9781315641065-4

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supported the competitor service, the BBC’s advertising-free public service broadcasting. By 1955, when ITV began broadcasting, commercial television services had been running for nearly a decade in the United States, and were changing. In the US, free-to-air (FTA) commercial television reached 9 per cent of the population in 1950 but 64.5 per cent by 1955 (Turow, 2011: 447). Early US television followed the patterns established by its corporate owners for their radio networks, with shows financed by a single sponsor; daytime radio ‘soap operas’, so named as they were sponsored by brands such as Ivory soap from Proctor & Gamble. Radiosponsored shows, often made by advertising agencies, included The Maxwell House Hour (1927) and General Motors Family Party on NBC. By 1929, over half of radio shows were financed or produced by brands (Lehu, 2007). The television networks brought the advertiser-sponsor model, including The Texaco Star Theatre started in 1948, and the Camel News Caravan, featuring a smoking presenter and brand packaging. The latter ran from 1949 to 1956 in prime time on the leading network, NBC, funded by tobacco giant R.J. Reynolds which exercised control over the show, for instance, vetoing ‘no smoking’ signs in filmed reports. The first TV commercial, for Bulova watches, was aired on NBC-owned WNBT during an American baseball game in 1941, after the Federal Communications Commission (FCC) issued the first commercial television licences allowing broadcasters to collect fees from advertisers, although earlier, experimental sponsor messages had featured from the 1930s (Dalzell, 1995). At NBC, President Sylvester Weaver introduced an innovation with a profound impact on the future of TV advertising. A former Young and Rubicon advertising executive, Weaver had seen how single sponsors exercised considerable control over broadcasters and often owned the shows. To shift power towards the broadcaster, he introduced a new ‘magazine’ format for shows such as The Tonight Show, first broadcast in 1954, selling blocks of advertising time to a range of sponsors (Wu, 2016: 134–6). NBC introduced commercial breaks in shows, initially carrying one-minute advertisements. The age of spot advertising had begun, and became an increasingly necessary way to meet rising production costs, although single-sponsor shows such as the patent medicine Geritol-sponsored quiz show Twenty One continued, until scandals over sponsor manipulation and fakery, and a Congressional investigation in 1959, vividly shown in Quiz Show (1995, dir. Robert Redford), gave further momentum to the shift to advertising in breaks between programmes (Wu, 2016: 136–9, 149–50).

Product placement Product placement (PP) occurs when a company pays a TV channel or a programme-maker to include its products or brands in a programme. The US Federal Trade Commission (FTC, 2005) defines product placement as ‘a form of promotion in which advertisers insert branded products into programming in exchange for fees or other consideration’. There is nothing new about the integration of advertising and media content. Product placement in movies can be traced back to the Lumière brothers’ films of the 1890s, for instance promoting Lever Brothers

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Soap in the film Washing Day in Switzerland (1896), and was well established in the Hollywood studio system by the 1920s (Newell et al., 2006; Seagrave, 2004). Product placement is coterminous with the birth of cinema, but now extends across entertainment, news, music, and games, and appears, in actual or virtual forms, across screens and spaces, from football pitches to smartphones. Placement takes a variety of forms, from the incidental presence of brands, to verbal endorsement and sophisticated ‘brand integration’, where brands are weaved into storylines, such as such FedX parcels in Cast Away (2001), or BMW’s Mini Coopers in the remake of The Italian Job (2003). Beyond such ‘placement’, products have been integrated into full-length films, programmes, and series from children’s shows such as He-Man and the Masters of the Universe, an animated series from the 1980s (Kline, 1993) that was one of the first programme-length vehicles for children’s toys, through to the He-Man and the Masters of the Universe: The Beginning (2002) feature film. The Transformers film franchise, starting with Transformers (2007), arose from a deal between Paramount and General Motors to create a movie-length promotion for a range of toys and other merchandise and ‘a product brochure for General Motors’ (Donaton, 2007). From Toy Story to Lego the Movie, new forms of branded entertainment content have expanded the mixing of brands, movies, and merchandising, and the complexities of promotional reflexivity and cross-media promotion (Hardy, 2010). Product placement increased in US television in the 1990s, and then expanded rapidly in the 2000s. Between 2006 to 2008, the average US television programme went from ‘ten brand references in it to having fifty; [with] outliers [having] as many as 1,000 references per show’ (Fujawa, 2012: 554). Product placement has been most extensive in cable TV shows and reality TV formats, with weight-loss show The Biggest Loser, sponsored by fast-food outlet Subway, clocking up more than 500 product occurrences per season (Einstein, 2016: 31). The rise of branded entertainment integration and of ‘content-commerce alliances coincided happily with the rise of reality TV’ (Donaton, 2004: 21). Product placement also increased in non-interruptive, original television drama produced for pay viewing on premium cable or online, with an episode of HBO’s Entourage featuring 65 brands in 104 minutes of running time (Chahal, 2015). Netflix’s House of Cards, costing around $4.5 million per episode, was dubbed ‘house of product placement’ by the LA Times (Fleischer, 2013). Product placement has become an increasingly significant form of film financing. Heineken’s reported $45 million deal for Skyfall, in which Daniel Craig’s James Bond swapped his famous Martinis for beer, represented around a third of the entire production budget (Borum, 2016). Global spending on product placement rose 11.7 per cent in 2012 to $8.25 billion, with annual growth of more than 20 per cent in China, Russia, and India, according to PQ Media (WARC, 2013). The popular Chinese TV series We Get Married carried 49 product placements in 2013. Television was the main channel ($5.37 billion), but online and mobile was up 31.4 per cent ($247 million), while product integration in music (videos, lyrics, etc.) increased by 22.7 per cent. In 2013, ‘brands spent $5.3 billion on product placement in movies, TV shows, video games, music videos and books’ (Sebastian, 2014).

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Forms and formats Russell (1998) identifies three main dimensions for product placement: visual, auditory, and plot connection. In visual only (screen placement), brands are visible; in audio (script placement), the brand is not visible but verbally mentioned, while combined audio-visual (plot placement) includes both. Various placement forms are identified in the industry and academic literature, including innovation placement, for a product launch, corporate placement, the placement of a company name or service, and image placement, ‘where an entire movie is tailored to a single company, product or location’ (Gibbons and Katsirea, 2012: 186) In a report for Ofcom (2005: 4), Human Capital identifies ‘background product placement (defined as relevant to the programme and subtle); Noticeable product placement (defined as noticeable and not necessarily relevant to the programme); [and] Script product placement (defined as where programme scripts are built around products)’. Terms such as ‘product integration’ and ‘branded entertainment’ (Lehu, 2007) highlight the move beyond simple placement into more sophisticated, and extended, brand presence. That is further extended with the promise of ‘second screen’ interaction so that viewers can identify and purchase products seen in shows (Thinkbox, 2014). Product placement has also enveloped a range of other entertainment media forms, including computer games (‘advergames’).

Explanations and changes Embedded advertising is now well established across commercial film and television. Like most complex phenomena, the growth of PP in television is multifactorial. We therefore need to consider the specificity of practices, and the conditions giving rise to them, across different media systems. Yet, some common factors can be identified. The overall context is one of disruption across the television industry and marketing communications industries, as services, audiences, and advertising move online in ways that challenge older models of content provision and its financing. The shift from marketing spending on television advertising to digital media has challenged advertising agencies whose profit margins were supported by the spending of their largest clients on national television advertising (Sinclair, 2020: 8). With the growth of subscription streaming services, such as Netflix and Amazon Prime, the audiences for advertiser-supported television, while still strong, are declining. In 2017, the US experienced the biggest drop in US television advertising sales in two decades, falling by $4.9 billion, 7.3 per cent, to $62.1 billion (The Economist, 2018). A key driver has been the shift, especially among younger, upscale demographics, towards non-linear, video-on-demand viewing, initially via set-top boxes and increasingly via smartphones, tablets, and other personal devices. As users and then advertisers have moved from linear TV to over-the-top (OTT) services viewed on YouTube and other platforms, television companies face lower returns for monetising content than on traditional broadcasting, and share advertising revenue with platforms. Ad-avoidance long pre-dates the digital age, yet amid decreasing tolerance for ‘interruptive’ advertising,

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non-linear viewers have increasing opportunities, and if more affluent can pay, to skip ads in pre-recorded material, accelerating the decline in value and effectiveness of traditional TV advertising formats. Integrating advertising into programmes has therefore been regarded as a solution to three problems: the declining reach and effectiveness of ‘spot’ advertising; the rising costs of programme production; and the need for viable digital formats for selling advertising. Brand integration, it is claimed, offers advertising effectiveness (if done appropriately), an important source of income for programme-makers and/or broadcasters, and new forms of creative collaboration between advertisers and media. According to industry research cited by Tran (2018), 60 per cent of consumers feel more positive toward brands they recognize in a product placement; ‘Consumer receptiveness to product placement could eventually translate into an in-store or online purchase the next time a consumer encounters a brand that was integrated into a show’ (Tran, 2018).

Product placement regulation and liberalisation To understand the growth of product placement we also need to appreciate how it has been subject to changing regulation in different countries. While the regulation of branded content is discussed in more detail in Part II, this chapter outlines the specific rules for product placement and the context for their liberalisation in the US and European Union. In the United States, the Communications Act 1934 requires broadcasters to make sponsorship identification announcements in paid-for programming, and disclose when any ‘money, service, or other valuable consideration’ is provided for the inclusion of a product or brand in a television programme (sections 317, 508; Fujawa, 2012: 557). The FCC applies additional sponsorship identification rules, first enacted in the 1970s. However, the brief references in fast-moving end credits were deemed insufficient by a range of consumer advocacy groups and several FCC commissioners have tried unsuccessfully to introduce more prominent labelling and identification rules (Fujawa, 2012). In Western Europe, however, a very different regulatory culture has prevailed. In the UK, the 1954 Television Act authorised the clear separation between programmes and advertising: section 4 (6) prohibited any programme material which was or appeared to be ‘supplied or suggested by any advertiser’. The separation principle was reinforced after the Pilkington Committee (1962) rebuked ITV over so-called admags in which branded goods were promoted by characters in settings such as a pub, where actors presented themselves as ordinary folk weaving discussion of new products into their conversation (Murdock, 1992). The UK, until it left the European Union in January 2021, was subject to EU legislation alongside 27 other member states, and the directives incorporated into domestic law remain until any future amendments are made. The main instrument of European television regulation was originally known as the ‘Television without Frontiers’ Directive, established in 1989, revised in 1997, and then substantially overhauled and renamed the Audiovisual Media Services Directive (AVMSD) (European Parliament and the Council, 2010, updated 2018), covering broadcasting (linear), video-

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on-demand (non-linear), and related services. Under the original 1989 Directive surreptitious advertising was prohibited. Until the AVMSD, EU audiovisual regulation upheld the principle of separation: ‘advertising should be separated from creative or editorial content’ (Gibbons and Katsirea, 2012: 161). Most states already banned paid product placement in their national broadcasting regulation and took the 1989 Directive to include an outright ban, but others, notably Austria and Italy, had permitted advertisers to pay for brands to appear in programmes (Dagnino, 2020). For the European Commission, this was one reason given for introducing clearer rules, but advertisers and broadcasters had also lobbied intensively for the rules to be relaxed, and a fierce debate ensued, with many Members of the European Parliament (MEPs), and consumer, trade union, and civil society groups opposed. European film and television industry interests highlighted conditions of reduced government subsidies, growing competition from digital media, and DVR adoption to urge the EU and national regulators to liberalise rules. The European Commission (2005) proposed in a policy paper: ‘For product placement to be made possible, the principle of separation should cease to be an essential criterion and should simply be one of the means to enable users to identify commercial content and to distinguish it from editorial content’. The outcome was that the new Directive reaffirmed the general prohibition, but allowed individual member states to permit product placement in films, series, sports, and light entertainment, although not in news or children’s programmes. France, then the largest PP market in Europe, and Spain moved first to relax rules. By 2015 all EU member stated permitted product placement, with six applying additional restrictions to those set out in the Directive and implementing rules slightly differently in each case (European Commission, 2016: 79–80). For instance, in the UK no alcohol may be promoted, while in the Netherlands the alcohol ban only applies up to 9pm. In Germany, stronger restrictions are imposed on public service media (PSM) channels, with PP not allowed in programmes produced or commissioned by the broadcaster. After PP was permitted in Germany, in 2010, M&M’s were integrated into a gameshow, Siemens/Bosch products featured in a cooking show, and C&A fashion retail featured in a soap opera (Morris, 2011).

Liberalisation of product placement in the UK Liberalisation followed a period of consultation and lobbying. One Secretary of State for Culture, Media and Sport, Andy Burnham opposed liberalisation, arguing in a speech that PP risked ‘contaminating’ programmes. However, his successor, Ben Bradshaw, supported PP, advancing the case for UK TV industry growth and global competitiveness advanced by ITV and commercial TV. Advocates argued it would create a new and necessary source of commercial revenue. It was argued that audiences already accepted the PP they saw in acquired films and shows and were favourably disposed, or at least tolerant, towards PP in original programming. Safeguards would ensure audiences would be protected by transparent

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identification, and programme integrity would be maintained. The Department of Culture, Media and Sport (DCMS, 2009:10) reported that: [i]n response to our consultation last year, advocates of allowing product placement argued that it would generate funding to encourage production and innovation, and that it would help the UK’s commercial public service broadcasters – ITV, Channel 4, Five, and S4C – to continue to meet their obligations. They also argued that a continued prohibition of product placement would leave UK television broadcasters and programme-makers at a disadvantage as compared with international competitors especially in the EU and across the Atlantic. Announcing the new rules, Bradshaw (2010) stated: Adherence to our current position in which UK TV programme-making cannot benefit at all from the income potentially to be generated by product placement would lead to continuing damage to its finances at a time when this crucial part of our creative industries needs all the support we can give it. He stressed the importance of liberalising, since ‘every other EU Member State, with the sole current exception of Denmark, has either allowed television product placement already or has expressed a firm intention to do so’; failure to act would ‘jeopardise the competitiveness of UK programme-makers as against the rest of the EU’ (Bradshaw, 2010). Under the 2010 rules, paid PP remained prohibited for the BBC’s public services, but was now permitted for the first time on original programmes made for broadcast on commercial television, including the commercial PSMs. Product placement was allowed in all the genres permitted under the AVMSD, namely in films, series made for television (or other audiovisual media services), sports programmes, and light entertainment programmes (excluding news). No PP is permitted in children’s programmes. Stricter rules apply to programmes produced under UK jurisdiction, where product placement is also prohibited in religious, consumer advice, and current affairs programmes (Ofcom, 2017) The UK legislation went further than the EU-required ban on tobacco and medicinal products, outlawing the placement of products and services in relation to alcoholic drinks, foods, and drinks high in fat, salt, or sugar (HFSS), gambling, smoking accessories, over-the-counter medicines, and infant and follow-on formula milk. The AVMSD rules, described by Gibbons and Katsirea (2012: 163) as ‘opaque and fraught with complexity’, have also allowed scope for variation in national regulations. The EU rules require that paid placement is editorially justified, yet the conditions that distinguish justified from unjustified placement are precisely at issue, and unclear. ‘Integrating products in such a way that their brand is recognisable is never unavoidable. It is always possible to obscure brand names and logos or to hide them through appropriate camera work’ Gibbons and Katsirea (2012: 175). The UK regulator Ofcom softened its original proposal to ban thematic placement, described as ‘the payment by a third party for the creation of storylines or

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scripts as vehicles for the purpose of featuring particular issues or references (including generic references) to the third party funder’s aims, objectives, beliefs or interests’ (Gibbons and Katsirea, 2012: 181; Ofcom, 2017). In the 2010 AVMSD, Recital 93, thematic placement is identified as an example of interference with editorial responsibility and independence. In some countries, such as Germany, thematic placement was explicitly banned. Ofcom had also proposed an outright ban, but following a consultation, and industry lobbying, the final guidance states: There must always be sufficient editorial justification for the inclusion of product placement in programmes. In particular, editorial content must not be created or distorted so that it becomes a vehicle for the purpose of featuring placed products, services or trade marks. (Ofcom, 2010: 31) Ofcom (2010: 34, emphasis in original) argued: the statutory definition of product placement encompasses the paid-for placement of references in programmes to products, services and trade marks only. Therefore the product placement Code rules do not enable the inclusion in programmes of paid-for references to a third party’s aims, objectives or beliefs. Further, Ofcom argued that there were sufficient safeguards for editorial independence in the rules governing editorial justification, the absence of promotion, the maintenance of the distinction between editorial and advertising content, and undue prominence. The UK retained its existing rules prohibiting ‘undue prominence’; the Ofcom (2017: 51) Code states ‘[u]ndue prominence may result from … the presence, or reference to, a product, service or trade mark in programming where there is no editorial justification’.

Product placement in UK television Product placement was allowed for the first time in UK-made TV programmes in February 2011. Nestlé coffee brand Dolce Gusto, shown on ITV1’s This Morning, was the first brand to be featured in a deal brokered by WPP media agency Mindshare for an estimated £100,000. Advertising agency Mother and media planning agency Trinity Communications co-signed a deal with Channel 4 and clothes retailer New Look to create the first programme funded by product placement under the new rules (Magee, 2011). Since then, the paid placement market has grown, but much more slowly that many analysts, and advocates, predicted. In the first year there were fewer than 20 placement deals (Gibbons and Katsirea, 2012). There are four main reasons for this: (1) strong regulations; (2) insufficient incentives; (3) marketers’ caution; and (4) media caution and recognition of the need to introduce PP carefully to ensure support from viewers and key policy stakeholders.

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Even where product placement is permitted, there are formal restrictions, albeit ones difficult to monitor for enforcement: there must be no ‘undue prominence’ given to products featured, and editorial control must remain with the broadcaster. A universal P sign must be displayed around programme breaks to notify viewers. Ofcom has strict controls on commercial references in programmes, which apply even where PP is permitted (Ofcom, 2017). Rules are more relaxed for UK radio, however: radio broadcasting is not subject to the EU Directive, and commercial radio audiences are regarded as more tolerant of, and familiar with, sponsor mentions. Liberalisation occurred during a period of heightened attention to broadcasting standards following scandals over trust. Martin Frizell, former editor for ITV’s morning show GMTV, noted ‘[b]roadcast compliance teams are powerful and after what has happened they are likely to be even tougher when it comes to product placement. PR professionals trying to use celebrities to sell a campaign had also better make sure they are editorially relevant’ (PR Week, 2013). The second key factor is insufficient incentives. The UK already had a thriving prop placement market, with products supplied for TV set-dressing and use (Knapp, 2011). All that remains permitted, provided there is no payment or traceable economic consideration. Further, PP deals are relatively slow and costly to negotiate, compared to spot advertising deals, resulting in higher transaction costs, in addition to long lead times between filming and transmission. For Ben Devlin, a former programme maker and founder of BrandsonTV.com, which brokers placement deals, ‘No-one wants to get into product placement for deals worth less than £25,000. It requires too much paperwork and conversation to do it for less. ITV/C4 are going to market with £100,000 options that are often bound into sponsorship packages’ (Magee, 2011). Alongside transactional costs for contracting and associated legal services were the costs involved in negotiating creative execution. ‘The early integration of placements into storylines is a complex task, not least due to the need for close supervision of advertising clients on the film set’ (Gibbons and Katsirea, 2012: 185). While broadcasters like ITV advocated for PP, it was unclear how the income generated should be divided between producers and broadcasters. Lack of certainty over compensation inhibited producers from pursuing placement deals. This links to the third factor, marketers’ caution towards investment in ‘new’ advertising formats, especially when those formats lacked established measurement tools to assess marketing effectiveness and return on investment (ROI). Initially, PP was measured against the equivalent ad space – a 30-second TV spot ad, with an estimated worth of 200 per cent of the ad if use of the product is integrated into the programme and referenced verbally (Magee, 2011). There was also little standardisation. According to Rogers & Cowan account director Kate Kelly, ‘Every agency has its own way of measuring it, weighing up how prominent it is on screen, whether it’s branded, how long that clip is on screen, the time of day it is on and audience figures’ (Magee, 2011). Measures of reach might be impressive. When Sweden’s most popular gardening show on TV4 featured product placement for upmarket lawnmower brand Husqvarna, it drove 180 per cent increased traffic to the brand’s website, in a deal worth around $79,000 dollars (Morris, 2011). However, paid placement lacked robust evaluation. This mattered for assessing effectiveness but also for pricing and the creation of more uniform trading

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arrangements. According to Chris Fuller, associate director at MediaCom, ‘The one single thing that I believe would accelerate its uptake is a uniform and simpler way to commoditise it’ (O’Reilly, 2014). In turn, marketers’ caution links to the fourth main factor, television industry executives’ efforts to introduce PP gradually and smoothly to enhance viewer, and regulator, acceptance. PP arose from two overlapping debates, concerning appropriate regulation and marketing effectiveness, both of which encouraged its introduction to be non-disruptive, ‘subtle’, and ‘appropriate’. Initially, the lack of effective case studies inhibited brand take-up. However, industry research improved in sophistication, aiding media advocacy to brands. Sky’s research showed increased viewer awareness of Amazon’s Kindle Fire amongst those watching Sky 1’s Got to Dance, where stars used the product, with 80 per cent awareness, only a modest achievement compared to 73 per cent awareness amongst non-viewers following the campaign, yet brand consideration was stronger at 32 per cent versus 22 per cent (O’Reilly, 2014). In the UK, after the mobilisation of opposition by civil society groups amid a volatile policy environment, there was media and marketing industry support for a gradual, incremental approach, although client caution went beyond commercial media expectations. The main terrestrial broadcasters focused on their soaps as PP vehicles, due to both their large audience size and profile, and their relatively short production turnaround of six to eight weeks (Morris, 2011). There was a similar slow start in other parts of Europe, with limited PP in the first year of liberalisation in Germany (Gibbons and Katsirea, 2012: 185). By 2013, the UK product placement market was estimated to be between £9.7 million and £29.1 million, according to New Media Group, a tiny proportion of the £4.6 billion total TV advertising market, as estimated by Thinkbox (O’Reilly, 2014). Big brands began to sign placement deals for prime time shows, such as Samsung for ITV’s X Factor, Nokia in Channel Four soap Hollyoaks and Yeo Valley and Uncle Ben’s in Jamie’s 15-Minute Meals, also on Channel 4. For Chris Fuller, associate director at MediaCom, the quality of placements was improving as production companies learned how to integrate them more effectively. He commented, ‘I think all parties expected [product placement] to grow more rapidly initially, but three years is not a long time for something that is still really in its infancy’ (O’Reilly, 2014). Now, a decade on from liberalisation, there are indications that PP is becoming more integrated into media and marketers planning. ITV’s Love Island in 2018 had ten brand sponsors, including product placement deals with its main sponsor, Superdrug’s summer range, as well as Rimmel makeup, Missguided clothing, Jet2holidays, and Ministry Of Sound, hosts for a party on the island and releasing a tie-in compilation album. ITV offers to maximise brand partners’ exposure via social media. In 2017, ITV sold over 100,000 personalised water bottles, designed like those used by the cast, through its Love Island app direct to fans. A licensing deal with Primark for Love Island-branded merchandise was also successful and sold out nationwide (Rogers, 2017). PP in the UK is becoming ‘more about bespoke deals that mix continuous onscreen exposure with tactical multichannel brand executions’ (Rogers, 2017). ITV

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senior creative manager Katherine Marlow cites the ‘Bush Scrabble’ challenge for Mattel included in the 2015 series of I’m a Celebrity Get Me Out of Here as an example of more extensive collaboration between brand and producers. She adds: This year has been crazy for us in terms of not only the volume, but the ambition for these deals … However, it all comes down to the show itself and ensuring that it remains as natural as possible. That’s still the best way for anyone. (Rogers, 2017) Brand integration has ranged from tie-ins like the 2018 film Mamma Mia – Here We Go Again in Channel Five’s Big Brother, to the weaving of brands into shows from the conception stage, such as Channel 4’s Eat The Week’s deal with Iceland in 2017 (Channel Four, 2017). In 2018, ITV announced its biggest placement deal to date, with the set for Coronation Street rebuilt to feature a Co-Op bank and Costa Coffee outlet. The show had previously incorporated a branded ATM for Nationwide, but ITV sales director Mark Trinder commented, ‘Incorporating product placement on this scale is something we have wanted to do for some time’ (Elsam, 2018). For the company, this was welcome investment in branded content, following a 9 per cent fall in advertising revenue in 2017. Further, as Gemma Butler from the Chartered Institute of Marketing noted, ‘[t]he fact that a British institution like Coronation Street has made the decision to feature brands within the show gives licence to other programmes who may have been wary of product placement to look again at its potential for advertising revenue’ (Elsam, 2018). However, the deal also drew criticism from media commentators, on social media, and notably also from actors on the show. Liberalisation of PP in the UK and Europe was advocated by media companies, in part, on the basis of global competitiveness with the more permissive regulatory arrangements in the USA and Asia. In fact, further liberalisation has continued. For instance, in July 2018, Hong Kong’s Communication Authority announced relaxation of rules on TV product placement. PP was permitted in all programmes except for those dealing with news, current affairs, education, and religion, but placement was required ‘in a natural and unobtrusive manner’ (Tsang, 2018).

Evaluation Commercial media and marketing interests lobbied for the relaxation of product placement rules but were opposed by a range of consumer, health, children’s, media reform, and other civil society groups. Creative professions were, and remain, split on the issue. For advocates, product placement makes programmes realistic, secures vital funding, and is welcomed by viewers, when done appropriately. Critics argue that product placement allows marketers to pay for presence in ways that can undermine editorial and artistic integrity and distort programmemaking agendas. Another criticism is that product placement can be used to bypass advertising controls, such as those preventing cars to be associated with speed, adrenaline highs and risk-taking, staples of television action dramas.

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The presence of brands adds realism and authenticity, it is argued. Yet, a counterclaim is that paid placements corrode realism in favour of brand-boosting depictions, such as two characters sharing an enormous bowl of chips on ITV’s Emmerdale, sponsored by the world’s largest chip manufacturer, McCain. A recent study of US drama speculated that the lack of public transport use was linked to the car placement deals (Fortunati, 2018): Black-ish and Designated Survivor have been criticized for their blatant plugs of Buick and Ford, respectively. We can’t necessarily know if product placements from carmakers are the determining factor in whether a show will feature other transportation options. But can transit agencies offer these kinds of sweet perks to studios? Nope. Unlike unpaid prop placement, which meets audiences’ desire for realism, critics argue that product placement opens the way for programme agendas to be distorted for commercial purposes (Hardy, 2010: 233–67). Such outcomes, though, depend on the interaction of a complex range of influences, from media dependence on brands to the ability of writers, directors, producers, and others to influence how deals are made and implemented. Consumer research indicates a spectrum of opinions, from outright opposition to acceptance, even appreciation, of brand placement, with tolerance greatest amongst the young and those more accustomed to commercial media fare.

Post-television and branded content If the decade 2000–10 marked the winning of an argument to allow selective product placement to help save European television, the period since has seen an explosion in the number of distribution platforms for television programmes and all kinds of TV-like audiovisual content, from the FAANGS (Facebook, Apple, Amazon, Netflix, Google) and others. We will leave our discussion of regulation at an interesting moment in which European politicians seek to extend PP disclosure rules to these platforms, in part to counter a new wave of North American cultural industries’ dominance, just as commercial media interests in Europe continue to advocate further relaxation of PP rules. TV financing is shifting to paid subscription, most notably in the US, where over 50 per cent of all age groups subscribe (Dreier, 2018). Worldwide video on demand and OTT subscriptions grew at a faster rate than cable subscriptions worldwide, with online streaming subscriptions increasing to 613 million worldwide in 2018, a 27 per cent increase on 2017 and growing at a faster rate than cable subscriptions worldwide, according to the Motion Picture Association of America (MPAA, 2018: 5). Yet, product placement is being re-affirmed as the solution to new conditions, most notably the rise of IPTV, and OTT streaming of video content. The US product placement market grew by 13.7 per cent to $8.8 billion in 2017, and was expected to continue a nine-year run of double-digit annual growth in 2018, reaching $10 billion. US television, including live and

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OTT, had the largest share ($6 billion) in 2017, representing over 70 per cent of total US brand integration revenues. While the number of product placements declined, due mainly to fewer background placements, revenues increased, ‘driven by a growing number of more valuable plot integrations in media content, primarily in live TV and OTT video’ (PQ Media, 2018). OTT was the fastest growing segment of TV overall for product placement in the US. The younger 18–34 demographic is now watching streaming video predominantly in place of live TV, so brands have been seeking product placement in original content, such as KFC’s deal for appearances in Netflix’s Stranger Things. All of Amazon’s original productions contain product placement, as do over 90 per cent of Hulu’s, and over 70 per cent of Netflix’s (Tran, 2018). The collaboration of brands in product placement is linked to wider collaboration with streaming services for branded content. Lexus, Jaguar, and Shell have all tested Amazon Prime Video as a distribution platform for long-form branded content. According to Spiros Fotinos, global head of brand management and marketing at Lexus, brands are attracted to the scale and reach opportunities Amazon offers (WARC, 2019). In 2019, Hulu, which offers both ad-free and ad-supported subscription services, announced business plans to secure half of its revenue from nondisruptive and non-traditional ad formats in future (Adams, 2019). These included its Pause Ad unit, which shows a static banner advertisement when users pause programmes and is intended to be less disruptive by not interrupting viewing. Global product placement revenues increased 14.0 per cent to $15.68 billion in 2017. Television took the greatest share ($10.50 billion), but digital media was fastest, growing 26.7 per cent (PQ Media, 2018). While the total number of TV placements is declining, PQ Media predicted growth overall in television as plot integrations become more common. In the US, major networks set targets to air fewer commercials in efforts to improve the viewing experience and compete with the appeal of adfree subscription streaming services. ‘To offset declines in ad revenue associated with this strategy, companies may choose to run more brand integrations in their shows’ (Tran, 2018). The fastest growth sector for product placement overall, though, is online and mobile, with influencer marketing on YouTube and websites engaging younger audiences in particular (Matthews, 2018). Facebook-owned Instagram’s longer-form video platform, IGTV, will allow brands to partner with influencers, especially to reach under-18s, preferring amateur content creators to traditional TV shows. Today, TV advertising comprises a mixture of traditional spot ads, addressable and interactive ads (targeted at specific audiences through internet-enabled tracking and measurement), sponsorship, and product placement and its more elaborate forms referred to as brand integration. As James Hayr (2018), head of global sales at Endemol Shine, puts it: With more platforms commissioning content than ever, brands are able to play a much bigger role in the television space. Be it through full or part-funded programming, product placement and integrations, through-the-line IP

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licensing, TV talent and celebrity endorsement, second screen gaming and apps, the list goes on. It feels like we are at the cusp of a seismic shift … and we are committed to uncovering new ways to bring brands into the mix. Storytellers and brands have everything to play for. The challenges for streaming services include competing to offer optimal (predominantly ad-free) viewing experiences for audiences, while monetising services to recoup the billions they have invested in content and infrastructure to build subscriber numbers. PP offers solutions, moving advertising into shows rather than around them, and does so in emergent forms supported by artificial intelligence. There has been a growth of virtual product placement, with brands digitally inserted into both live and recorded audiovisual content. One industry figure (Jacob, 2018) predicts that AI technology: will soon be used to automate the placement of unobtrusive ads in the background of TV shows and movies. Studios won’t have to change anything about how they film or edit their content; however, when the final video is delivered to the viewer on a smart TV or other connected device, ad servers will use surface detection technology to insert products or advertising directly into specific scenes. These AI-enabled placements will be personalised and programmatic, yet scalable and measurable like most digital advertising today. Consumers will point their smartphone at the TV to access options to buy music or clothes placed in shows, as some ‘second screen’ apps such as Zeebox (relaunched as Beamly) have begun to offer for the placements that appear today. Yet, this vision, from Ralf Jacob, head of digital media service at Oath, part of Verizon, acknowledges tensions over control between content creators and advertisers, echoing the 1950s struggles discussed above: The technology is there – it’s just a question of advertisers and content creators getting on board. Right now, many of them are still hesitant to cede control over ad placement to AI algorithms. However, with mounting pressure to make online content more profitable, it’s only a matter of time until the most forward-thinking among them begin experimenting with these types of solutions. One company developing such capability is Mirriad, whose in-video advertising system can analyse audiovisual content and insert brands or advertisements into screen space. Mirriad promises seamless, contextually relevant advertising that can be precisely targeted.

Conclusion This chapter has traced product placement and brand involvement in television and post-television. That is important in highlighting the pervasiveness of traditional

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forms of brand presence, the evolution of forms and relationships between marketers, agencies, and media, and the implications for normative and critical debates that are examined further in Part II. However, there are risks in tracing the evolution of forms, such as product placement, that broader and more significant reconfigurations are missed. The following chapters examine how identities as marketer, marketing agency, and media hybridise, dissolve, remain, and re-compose. Brands may be both clients in traditional guise for media companies at the same time as they become media companies and marketing agencies themselves. The incorporation of brands into media content has a long history, but is entering a new phase. This is multifactorial, with factors arising from changing market conditions for television and TV-like content, technological developments, and affordances for digital media and advertising, but also changes in institutional arrangements, work practices, cultures, and governing norms, as media and marketing communications merge at various levels, from corporate boardrooms to creative formats. And for businesses that depend on our willing attention, these developments are highly responsive to data, tracking what ‘works’ upon the people formerly known as the audience, as well as attendant to the wider views of stakeholders, from Coronation Street actors, to professional and general media opinion, to civil society groups. We have encountered industry predictions that product placement will become more pervasive in the commodification of TV and TV-like content, and the formidable alignment of commercial media and marketing interests makes that the most likely trajectory. Yet product placement remains contested, and vulnerable to a volatile mix of opposition from consumers, cultural workers, politicians, and campaigners. That gives value and urgency to the task of examining what is happening in media production, and following that analysis and assessment beyond the classroom, into both professional practice and civic life.

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Donaton, S. (2004) Madison & Vine: Why the Entertainment and Advertising Industries Must Converge to Survive. New York: McGraw-Hill. Donaton, S. (2007) ‘Madison & Vine: A look back, a look ahead’, Advertising Age, 11 October. Dreier, T. (2018) ‘Digital privacy, VR, product placement: What to expect in 2018’, OnlineVideo.net, 27 March. http://www.onlinevideo.net/2018/03/digital-privacy-vr-productplacement-expect-2018/. Einstein, M. (2016) Black Ops Advertising: Native Ads, Content Marketing, and the Covert World of the Digital Sell. New York: O/R Books. Elsam, S. (2018) ‘Costa and Co-Op debut on Coronation Street tonight’, British Baker, 27 April. https://bakeryinfo.co.uk/news/fullstory.php/aid/19481/Costa_and_Co-op_debut_ on_Coronation_Street_tonight.html. European Commission (2005) Issues Paper for the Liverpool Audiovisual Conference: Commercial Communications, July. Brussels: European Commission. European Commission (2016) Defining a Framework for the Monitoring of Advertising Rules under the Audiovisual Media Services Directive. Brussels: European Commission. European Parliament and the Council (2010) Directive 2010/13/EU of the European Parliament and of the Council on the Coordination of Certain Provisions Laid Down by Law, Regulation or Administrative Action in Member States Concerning the Provision of Audiovisual Media Services (Audiovisual Media Services Directive). Brussels: European Parliament and the Council. http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32010L0013. Fleischer, M. (2013) ‘“House of Cards,” or more like house of product placement?’, Los Angeles Times, 3 May. http://articles.latimes.com/2013/may/03/entertainment/la-et-st-house-of-ca rds-netflix-product-placement-20130503. Fortunati, J. (2018) ‘Two barriers that keep pop culture from embracing public transportation’, Mobility Lab, 14 February. https://mobilitylab.org/2018/02/14/two-barriers-keeppop-culture-embracing-public-transportation/. FTC (2005) ‘Letter from Mary K. Engle, Assoc. Dir. for Adver. Practices, FTC to Gary Ruskin, Exec. Dir., Commercial Alert’, 10 February. http://www.ftc.gov/os/closings/sta ff/050210productplacemen.pdf. Fujawa, J. (2012) ‘The FCC’s sponsorship identification rules: Ineffective regulation of embedded advertising in today’s media marketplace’, Federal Communications Law Journal 64(3): 549–575. Gibbons, T. and Katsirea, I. (2012) ‘Commercial influences on programme content: The German and UK approaches to transposing EU rules on product placement’, Journal of Media Law 4(2): 159–188. Hardy, J. (2010) Cross-Media Promotion. New York: Peter Lang. Hayr, J. (2018) ‘What can brands learn from the changing television landscape?’, The Drum, 25 January. Jacob, R. (2018) ‘AI is about to make video ads a lot less annoying’, Fortune, 26 June. http:// fortune.com/2018/06/26/artificial-intelligence-video-ads-augmented-reality/. Kline, S. (1993) Out of the Garden: Toys, TV, and Children's Culture in the Age of Marketing. London: Verso. Knapp, D. (2011) ‘Product placement revenue to see steady growth in Key UK, French and German markets’, news release, IHS Technology, 5 October. Lehu, J. (2007) Branded Entertainment: Product Placement & Brand Strategy in the Entertainment Business. London: Kogan Page. Magee, K. (2011) ‘Focus – a place for PR?’, PR Week, 8 April, p. 20. Marx, K. (2013) Capital: Volumes One and Two. Ware: Wordsworth.

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Matthews, T. (2018) ‘What IGTV means for brands’, Fourth Source, 25 June. http://www. fourthsource.com/instagram/what-igtv-means-for-brands-22859. Morris, J. (2011) ‘How European media companies are dealing with product placement’, Advertising Age, 13 June. MPAA (2018) 2018 Theme Report. Washington, DC: MPAA. Murdock, G. (1992) ‘Embedded persuasions: The fall and rise of integrated advertising’ in D. Strinati and S. Wagg (eds) Come on Down? Popular Media Culture in Post-war Britain. London: Routledge. Newell, J., Salmon, C., and Chang, S. (2006) ‘The hidden history of product placement’, Journal of Broadcasting & Electronic Media 50(4), 575–594. Ofcom (2005) Ofcom Consultation, in Anticipation of TWF Revision: Product Placement: A Consultation on Issues Related to Product Placement, December. http://stakeholders.ofcom. org.uk/consultations/product_placement. Ofcom (2010) Broadcasting Code Review: Commercial References in Television Programming, 20 December. London: Ofcom. Ofcom (2017) The Ofcom Broadcasting Code. London: Ofcom. https://www.ofcom.org. uk/__data/assets/pdf_file/0005/100103/broadcast-code-april-2017.pdf. O’Reilly, L. (2014) ‘Big brand case studies set to fire up product placement market’, Marketing Week, 10 March. PQ Media (2018) ‘Global branded entertainment marketing forecast 2018’. https://www. pqmedia.com/product/global-branded-entertainment-marketing-forecast-2018/. PR Week (2013) ‘Five trends for 2013 – what’s in store for 2013?’, PR Week, 11 January. Rogers, C. (2017) ‘The evolving opportunities of product placement’, Marketing Week, 21 November. Russell, C.A. (1998) ‘Toward a framework of product placement: Theoretical propositions’, Advances in Consumer Research 25: 357–362. Seagrave, K. (2004) Product Placement in Hollywood Films. Jefferson, NC: McFarland and Company. Sebastian, M. (2014) ‘“Madison & Vine” turns 10 – but how far has branded content really come?’, Advertising Age, May 13. Sinclair, J. (2020) ‘Cracking under pressure: Current trends in the global advertising industry’, Media International Australia 174(1): 3–16. The Economist (2018) ‘Technology has upended the world’s advertising giants’, The Economist, 28 March. https://www.economist.com/business/2018/03/28/technology-has-upendedthe-worldsadvertising-giants. Thinkbox (2014) ‘Screen life: TV advertising everywhere’, 9 October. https://www.think box.tv/Research/Thinkbox-research/Screen-Life-TV-advertising-everywhere. Tran, K. (2018) ‘OTT services are helping to drive product placement deals’, Business Insider, 18 June. https://www.businessinsider.com/amazon-hulu-netflix-driving-product-placem ent-deals-2018-6?IR=T. Tsang, D. (2018) ‘Rule change paves way for Hong Kong broadcasters to boost ad revenues through product placement’, South China Morning Post, 4 July. Turow, J. (2011) Media Today, 4th Edition. New York: Routledge. WARC (2019) Global Advertising Trends Report. London: WARC. WARC (2013) ‘Global product placement spend rises’, World Advertising Research Centre, 17 April. https://www.warc.com/NewsAndOpinion/News/31278. Wu, T. (2016) The Attention Merchants: The Epic Scramble to Get Inside Our Heads. New York: Vintage.

4 BRAND CONTENT DIRECT TO YOU Marketers’ ‘owned’ media

The last two decades have seen an expansion in brands’ owned media and ‘content marketing’, a catch-all term for shifts towards the creation of content and experiences by brands. With the rapid proliferation of digital marketing practices, the already blurring divisions between paid advertising, earned public relations, and owned and shared communication are in flux. This manifests in various ways, from the reorganisation of firms and marketing practices, the establishment of new professional bodies, to professional struggles over status and self-definition, to user interactions and governance activities. This chapter explores brands’ strategic involvement in contentcreation practices across digital, social, and mobile platforms. It also examines the significance of disaggregation trends as marketers decouple from paid advertising in media vehicles to use owned media, online behavioural advertising, and other means to connect marketing communications with target prospects. There is a long history of brands’ creative use of communication opportunities and vehicles. Brands have also produced media, such as annual reports, catalogues, sales promotion literature, and internal communications literature. The BBC produced an in-house magazine Ariel for its employees. Launched in 1936, Ariel reached 25,000 staff when it ceased print publication in 2011 and moved to online only. Corporate publications for internal communications to staff, or external communications to reach corporate investors or other stakeholders, has been the staple work of in-house public relations teams. Brands’ own publications have also featured across retail, sometimes as part of the core activity and identity of the brand. Argos produced its inventory in the form of a printed catalogue, begun in 1973, a rebranding of an earlier Green Shield Stamps catalogue launched in 1958, enabling shoppers to use stamps earned from shopping to buy gifts from a catalogue. When Argos announced the end of the print catalogue in 2020, it had grown to a 2,000-page volume (Hann, 2020). The production of catalogues for trading stamp purchases originated with Sperry & Huchinson’s Green Stamps scheme in the US in 1896. Yet, the involvement of brands in forms and DOI: 10.4324/9781315641065-5

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practices associated with media companies has been relatively rare until the 1980s, the late mass-media era. Up to then, few ‘non-media’ brands were periodical publishers or producers and distributors of audiovisual content. A precursor to the latest, explosive phase of branded content was the contract magazine phenomena. In the 1980s, so-called contract or customer publishing provided inhouse publications that enabled the brand to speak directly to customers or other stakeholders. Such publications were usually funded by the marketing departments of firms, and produced by established media companies, notably consumer or business publishers, or by an emerging business of customer publishing agencies that produced magazines, newsletters, brochures, catalogues in print and then digital formats, apps, and social media to be read by employees, clients, or customers of large companies. The growth of contract publishing occurred in the broader context of increasing customisation and targeting in magazine editorial and advertising, partly responding to similar developments in direct marketing in mail, telemarketing, and in-store promotions (Turow, 1997: 151–6). Redwood Publishing led the growth of ‘contract magazines’ in the 1980s and produced a brochure, ‘Redwood Publishing Solutions’, which explained the concept, telling brands people like and trust magazines and that customer magazines would enable them to communicate effectively with ‘your best customers … the ones you already have’, adding (Quinn, n.d.):  

Advertorials. Now companies have a powerful new medium to communicate. It’s more authoritative than advertising. And more controlled than public relations. ‘Publishing is partnership’ is our guiding principle … we provide a complete publishing package.

Formed in 1983, Redwood produced Expression, the UK’s first customer magazine, for American Express. The company was bought by the BBC’s commercial arm, BBC Worldwide, in 1989 to produce magazines such as BBC Good Food, Gardener’s World, The Clothes Show, and Top Gear. It was sold in 1993, as the BBC Charter Renewal process brought political scrutiny of any ‘market distortion’, and Redwood was purchased by the advertising and marketing agency Abbott Mead Vickers (Campaign, 2008). Redwood went on to produce Sky TV’s Sky Magazine, which was one of seven contract magazines in the top ten UK magazines by circulation in 2010, alongside Tesco, Asda and Sainsbury’s in-house publications, the latter produced by contract publisher Seven Squared (Baker, 2010). Contract publishing also illustrates the corporate integration of media and marketing. Some contract publishers are owned by marketing communications agencies. Publicis Blueprint set up a customer magazine for the insurance and financial services company Prudential in 2005, reaching 3.8 million customers (Quinn, n.d.).

Brands’ own content The contemporary phase of branded content is often linked to the success and influence of BMW’s innovative series of short films, The Hire (2001), discussed in

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Chapter 1. Yet, the following few years were ones of experimentation by a few brands before more mainstream adoption from the mid-2000s. The creative team at Ogilvy & Mather Toronto pitched to Unilever the idea for a series of viral films for Dove. One of the films, Evolution, first shown in 2006, went on to win a Yellow Pencil at the D&AD Awards 2007, and later won the Film Grand Prix and the Cyber Grand Prix at Cannes Advertising Awards, the first time both advertising awards had been won by the same creative execution. The films were originally created for the Canadian arm of the Dove Self-Esteem Fund, established to support organisations in Canada that help women and girls build self-esteem and promote a broader definition of beauty and positive self-image. In February 2007, Anheuser-Busch launched BudTV at an estimated cost of $15 million. Developed by one of its executives Jim Schumacker, this was a bold attempt to launch a full TV network online with long-form original programming, offering ‘a mix of original, unbranded humor, sports and reality programming’ (Mullman, 2009). The initiative was closed two years later in February 2009. According to AnheuserBusch’s VP of marketing Keith Levy, the challenges and costs of producing regular high-quality content was too much: ‘If the networks can’t continuously produce that [volume of content], how can a beer company?’ (Mullman, 2009). Anheuser-Busch had announced its hope to attract above two million unique visitors per month, but by the second month of operation traffic had declined by 40 per cent to 153,000. The site’s age verification system, which checked those registering against official records and sometimes rejected even legal-age consumers, proved a barrier, while the company was simultaneously challenged by state attorneys for failing to keep underage consumers off-site. By May 2007 traffic was too low to be measured by ComScore, and programming shifted, with reduced original content replaced by advertisements, one of which, ‘Swear Jar’, became the site’s most shared content and a viral hit. Levy said the company had learned key lessons about online marketing, including receptiveness to branded messages, especially when exclusive to online platforms: ‘Consumers want branding, and if you tell them a story they don’t see on television, they’re receptive to that’ (Mullman, 2009). Levy also reported on the site’s success at ‘stickiness’, with users spending an average of seven minutes on the site. The new strategy, Levy said, would focus future online-video efforts through Hulu, Yahoo, Facebook, and others, using established video and social media platforms.

Mapping branded content We can trace the evolution and development of brands’ own media in a number of ways. We can distinguish by media format and platform. That may appear counterintuitive, since modern campaigns are invariably multi-media and multi-platform. However, it does help to trace the connections between creatives and marketing agencies involved in media skills such as audiovisual, with clients selecting those media to lead branded content campaigns. To this day, and as the professional associations discussed below reflect, there are clusters of professional organisation, practice, and identities around publishing, audiovisual, digital-only, and outdoor. These are

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connected and interlink but also compete to lead on creative execution and spending and to offer their specific creative content skills to clients. Another entry point concerns the intended recipient of branded content. For the latter, a key distinction is between business-to-business (B2B) and business-toconsumer (B2C) marketing. HP’s The Wolf is an example of award-winning B2B branded content, winning Best in Show at the Digiday Content Marketing Awards in 2017. In a six-minute video Hollywood actor Christian Slater plays a hacker named The Wolf who accesses a company’s data by hacking into its insecure printer. With high production values, the short drama, produced by Giant Spoon, illustrates HP’s message that less than 2 per cent of printers are secure from hacking, according to its own research, and promotes HP’s line of ‘most secure’ printers. A third entry point is the qualities and purposes of branded content. A core quality is content that has value, and that offers something people are interested in and enjoy engaging with. For content aimed at a consumer market, common purposes are to create positive association with brand attributes that will be recalled and influential when purchasing decisions are made. Here marketers have identified branded content with the early stages of the marketing funnel, taking prospective consumers from general awareness to purchasing action. Branded content is also identified as relevant throughout the customer relations management (CRM) process, and so including after-sales, repeat purchases, and moving consumers from lighter to heavier users. This book focuses on the changing relationships between media and marketing communications. However, taking such a media-centric view risks missing other sets of relationships and explanations. For many marketers, ‘content’ is thought about much more in terms of customer relations management (CRM), and hence communications across the entire customer journey from awareness, to interest, desire, and action (AIDA). That CRM work has been transformed by digitalisation and datafication, but it also engages a wider set of institutionalised relationships across ‘marketing’ and ‘sales’ in the processes of identifying and satisfying customers’ needs, from initial brand awareness to after-sales loyalty. Such a broader framing also helps highlight how the focus of much media-based branded content is on the earlier stages of awareness and interest building, including establishing brand associations for younger audiences that will only generate returns on investment over the longer term when those consumers choose car brands or other expensive purchases. Brands have sought to produce or sponsor content to meet a wide range of informational or entertainment purposes. Google identifies three main types of online content engagements as hero, hub, and hygiene in a schema originally devised for YouTube video-sharing. Hero content is big-ticket, usually expensive content production designed to be shared widely and attract new viewers to your content. An example is ‘Volvo Epic Split’, first shown on YouTube, on 13 November 2013, a 77second short-form film in which Jean Claude Van Damme, astride two moving trucks, performs the splits. Hub is regular, scheduled material that keeps your audience coming back: ‘[e]pisodic or multi-part series designed to give a fresh perspective on

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your audience’s passions and interests’ (Google, 2018). Hygiene (renamed ‘Help’ in more recent YouTube guides) is informative content such as tutorials and how-to guides that target search terms and bring in an audience in a slower, more gradual way than the more immediately impactful ‘hero’ content, but can strengthen brand awareness and affinity, often near moments of purchase. Often the most celebrated branded content, by industry and consumers alike, focuses on storytelling over more overt persuasion, credible fit, and permission (Tur-Viñes and Segarra-Saavedra, 2014). Key, common features of brands’ own content include entertaining and/or informational content that may involve storytelling, and emotional engagement. Dzamic and Kirby (2018: 96–111) see branded content marketing as serving objectives of performance marketing, to drive consumer engagement and response, and brand marketing to build the brand through meaningful/entertaining (and ‘hero’) content, engaging shared cultural meanings, storytelling, and deep branding. Yet, they outline a rarely achieved combination of high intent utility and emotional resonance ‘empathic utility’ ‘at the centre of the triumvirate of forces driving modern marketing’ (Dzamic and Kirby, 2018: 104). Key qualities highlighted across the literature (Canter, 2018) include captivation and cultural resonance. Branded content activities may use, and test, a specific mix of formats, but the brand’s marketing team will seek to ensure an appropriate degree of consistency in brand identity and values. A strong example of such integration is Red Bull. A pioneer of the brand-as-media model, Red Bull’s Media House produces TV shows, including Felix Baumgartner’s Stratos jump, shown on its Red Bull TV channel, and licensed to the Discovery channel, Netflix, and others, together with Red Bull Music, supporting independent, alternative artists (Swatman, 2015; Einstein, 2016; Hardy, 2018). Red Bull creates, packages, and distributes content across its categories of sports, culture, gaming, and adventure, and has expanded into collaborative branded content, such as its tie-in with the Dubai Tourist Board, creating a film in which BMX rider Kriss Kyle drops from a helicopter to perform stunts at famous locations around the capital, securing over 240,000 YouTube views and 1,521 pieces of earned media publishing (McCarthy, 2019). Stratos remains the most viewed livestream on YouTube (Iqbal, 2020), although Holt (2016) notes that, ranked #184 on YouTube, Red Bull’s $2 billion annual budget did not prevent it being outranked by higher performing ‘crowdculture start-ups with production budgets under $100,000’. A fourth entry point is historical development, building up an account of the formation of branded content through the interaction of actors and processes in dynamic, changing conditions. In the language of 20th-century advertising, agency commission for broadcast advertising was ‘above the line’, while media spending not remunerated by commission but charged to the client was ‘below the line’ and included sale promotion, direct marketing, public relations, and sponsorship. While largely defunct as systems of payment, these terms shaped conceptualisations of marketing between paid advertising and other marketing support, with calls to combine and reinforce messaging across multiple channels (‘through the line’),

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informing strategies known as integrated marketing communications (IMC). Luke Southern (2017), CEO of DRUM agency, dates industry use of the term branded content from around 2008, but identifies much of his own work, and client briefs in the early 2000s, going beyond TV commercials that could be termed branded content, ‘just at the time it didn’t have a definition’. It became about producing communications that were the proof to the promise of advertising, validating the role of a brand in consumers’ lives and doing it in a way that wasn’t broadcast, and push messaging, but much more [about] inviting the audience in to the conversation, and, first and foremost, trying to entertain or inform them, or provide them with some sort of utility, where the brand took a secondary role, as a facilitator [of the communication]. Southern (2017) identifies the nascent branded content as mainly film-based communications, fuelled by the market growth of smartphones, following Apple’s iPhone (launched in 2007), Facebook, and YouTube. Those days of video being uploaded and distributed on YouTube probably fuelled the growth and speed at which branded content came online. It was about moving beyond the ‘behind the scenes’ ‘making of …’ films about TV advertising to stuff that was more immersive, and more rooted in what the audience cared about. In 2009, Southern, then at Cake agency, worked on Vodafone’s Who Killed Summer? – the first cross-platform online branded content drama – with 22 episodes shown across mobile and digital channels over 11 weeks to create immersive transmedia storytelling. This reflected the early BC model of creating a content hub, a destination, to attract consumers; now: where we’ve moved to, is about producing content that is relevant to an audience and is native to a platform and about going to where the audience are, as opposed to ‘broadcasting’ a message and hoping people will come and find it out. (Southern, 2017) A fifth entry point is the analysis of brands and brand culture and the shift of brands from ‘promotional devices for products’ to ‘facilitators of contexts or “platforms”’ (Aroncyky and Powers, 2010: 7; Lury, 2004). A key insight from this work is its emphasis on the communicative and relational aspects of brand value, as well as the linkages across the production of economic and social values. Brand value is ‘determined in circulation’ with ‘a growing variety of circulating discourses … mobilised in the service of the brand: all kinds of media attention, whether in the form of product reviews, news stories or consumer-generated content; word of mouth; and rumor, to name only a few examples’ (Aroncyky and Powers, 2010: 11). Those sources of ‘third-party endorsement’, with varying degrees of editorial

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autonomy, remain, and remain highly valued for trusted, authentic endorsement. Branded content represents the efforts by brands to engage in that media space with more presence, and more control, yet do so with approval and engagement from audiences.

Forms There are a range of formats of audiovisual storytelling, ranging from conventional 15- and 30-second ads, to short-form and longer-form video, frequently combined to reach audiences through online (native) advertising encouraging engagement with longer-form content. The drinks company Diageo approached its agency partner AMV BBDO to provide the brand with ‘conversational currency’ for its brand Guinness (Kirby, 2015). The agency produced a 2014 documentary telling the story of the Society of Elegant Persons, a social movement centred in Brazzaville, the capital of the Republic of the Congo. The Sapeurs are urban working-class men who dress and dance in elegantly stylish and flamboyant clothes. The campaign aimed to celebrate people with character and integrity as brand values and associations for the beer, and to counter the rising market share of independent brewers by reasserting Guinness’s brand ethos (Guinness, n.d.; Kirby, 2015). The Sapeurs campaign achieved 3.6 million online ad views, 1.7 million views for the documentary on YouTube, an estimated £4 million in earned media, and an ROI of £3.63 per £1 spend. The term ‘Sapeurs’ spiked on Google search, indicating success in stimulating conversation. The campaign was awarded a Wood Pencil in the Branded Content & Entertainment category at the D&AD Awards in 2015. However, the campaign also attracted criticism. In The Drum, Lewis Blackwell (2014), publisher and editor of Creative Review, wrote: The 1m 40 sec commercial and the 5m 6 second supporting short film try hard [yet …] not for a moment do we sense that the brand has credibility in the story. Guinness’ only role is to pay the bills and buy a gratuitous product shot or two. When the product pouring and consumption shots are shoehorned in, there is no sense of a relaxed fit. Instead, we’re choking, or perhaps laughing, on the constrictions of a pointless plug. In the commercial’s pub setting, only one branded drink is shown, and with lingering close-ups. The homage to Congolese culture is undercut by rock rhythms more resonant for its Northern target consumers than its Southern protagonists. Nevertheless, Guinness Sapeurs illustrates some key common features in much brand’s owned content. It includes video storytelling in ‘longer’ format, a five-minute documentary The Men Inside the Suits shown on YouTube, as well as shorter-form advertisements in 30-second and 90-second formats for cinema, TV, and online viewing. The online version of the advertisement included links to the documentary, functioning as a trailer for the longerform content. The content has strong storytelling features to stimulate engagement, sharing, and conversations. The campaign is designed for multiplatform delivery,

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including mobile video consumption, and involves a combination of owned, paid, earned, and shared media.

Short-form and long-form filmed entertainment Short-form usually refers to videos running from a few seconds up to a few minutes. Google (n.d.) sets the distinguishing point between short-form and long-form video at ten minutes; others refer to video under 20 minutes duration as shortform. Following the advertising formats of 15- and 30-second commercials, shortform has adapted to the mobility of users online, with evidence of users falling away the longer the video runs, and with decisions made in the first five seconds, although with variations across platforms on optimal video length. Forms are ever evolving as marketers must adapt and tailor to the arrangements and expectations of individual platforms, such as the short-form video app TikTok, downloaded more than 1.5 billion times in 2019 alone (Dowling, 2020). In 2016, Estrella Damm, the Spanish lager beer brewed in Barcelona, launched a short, 12-minute film featuring the actor Dakota Johnson. The file, Vale (dir. Amenábar, 2015), was distributed in Spain in cinemas and online, achieving more than ten million views online, and subsequently promoted in other markets including via advertising on Channel Four’s digital channels in the UK (Gwynn, 2016). Co-written and directed by film director Alejandro Amenábar, the romantic comedy-drama shows American tourist Rachel (Johnson) overcome language barriers to communicate with Victor (Quim Gutiérrez). The film and subsequent entertainment dramas created by the brand are examined by Benito (2019: 430), who notes that the ‘migration of an Integrated Product Placement to Branded Entertainment implies a substantial change in the approach to the strategy and content since the brand becomes the creator of the content, being in control of the content and participating in its essence’. The film tells a well-crafted, entertaining story in sumptuous cinematic style, yet is also a vehicle for overt and unsubtle product placement, in which a convivial dinner scene features only Estrella beer being consumed. The following year, Estrella funded another branded content drama, Las Pequeñas Cosas (dir. Rodríguez, 2016). This 16-minute long drama was directed by Alberto Rodríguez and starred French actor Jean Reno and Spanish, Barcelona-born actor Laia Costa. Longer-form branded entertainment includes the featurelength vehicles for brands, such as The Lego Movie (2014).

Documentaries In 2018, Coca-Cola produced four ten-minute episodes for a digital docuseries titled One Last Summer, which follows a group of friends as they prepare to start university degree programmes. The first two episodes were released on CocaCola’s YouTube channel on 3 July and promoted on its website, with more than 30,000 views for the first episode within two days, although only around 6,300 for the second (Mandel, 2018). The videos were a planned ‘digital amplification’ of the company’s ‘Share a Coke’ summer marketing campaign.

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Coca-Cola partnered with Punched in the Head Productions, based in New York, to source and film over 2–3 weeks a diverse group of teenagers. Katie O’Gorman, Coca-Cola’s Director of Social Media Strategy & Content, told a reporter that there was no product placement, though the company’s full Coke family was readily available, stating, ‘It was important that it wasn’t forced’ (Mandel, 2018). However, released stills show a can of Coke being consumed with no other drinks featured. Longer-form documentaries include Patagonia’s 90minute documentary Artifishal (2019) on salmon farming, distributed on Netflix.

Digital outdoor, AR, VR Branded content is also developing rapidly across spaces beyond media vehicles, some novel and some with longstanding roots in promotional practices. Branded content has been incorporated into novels, such as Fay Weldon’s The Bulgari Connection (2001), and physical books, such as Chanel’s embossed, non-ink book (Stinson, 2013). One developing area is outdoor advertising. This can be traced back to the earliest forms of advertising, symbols carved into traders’ premises, on to the proliferation of outdoor posters in 19th century cities. Many brands have experimented with outdoor and ambient promotion, much fulfilling a familiar public relations strategy of a notable, place-based ‘pseudo-event’ (Boorstin, 1962) that is then circulated widely via earned media coverage, and shared social media posts. Examples include the Fearless Girl statue originally placed facing down the bronze bull in Wall Street, commissioned by asset management company State Street Global Advisors (SSGA) to promote the launch of its Gender Diversity Index of companies, for International Women’s Day in 2017. Advertisers are already testing augmented reality (AR) formats, such as sponsored camera filters on the Snap mobile app, and 360-degree virtual reality (VR) ad formats that enable users to explore images or videos. Looking ahead, AR offers opportunities to overlay images of advertiser products and messaging onto mobile camera images – for instance, showing items in a room. VR will enable advertisers to offer immersive experiences. (Adshead et al., 2019: 34) In August 2019, Apple released augmented reality walking tours in New York and five other cities, featuring commissioned work by artists delivered via iPhones (Haigney, 2019). Ray-Ban’s ‘You’re on’ campaign produced in partnership with TikTok’s Creative Lab used AR for a virtual pinball machine experience that users could control using their eyebrows (Boorman and Skinner, 2021). Branded content now occurs across spaces and digital screens, including in retail spaces where they form part of the fashion-media nexus, enabling customers to try, style, and share clothing ideas, and bringing search, purchase, communication, and consumer experiences together. Here, too, AR offers a fusion of brand communications and

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a personalised, or pseudo-personalised, shopping experience. Brands have experimented with VR content, too, but the requirements for headsets and safe environments have restricted usage. Outdoor digital advertising, out-of-home (OOH), has developed in close partnership with branded content, with companies such as Ocean Outdoor developing digital screen advertisements and brand content. Brands use screens where the adlike status is indistinct, for instance, when a brand sponsors a digital screen weather service. Digital cinemas were early adopters of branded content, as were mobile phone brands such as Orange. In 2013, Samsung teamed up with companies to host outdoor film screenings, which also featured ads for its Smart TV products (Chapman, 2013). Large-screen events offer experiential branded content while data-driven targeting in screen messaging is on the cusp of realising the kinds of customisation fictionalised in Steven Spielberg’s Minority Report (2002). Blending brand content and customer relations management has been the growth of ‘chatbots’ (usually shortened to ‘bots’), technologies that mimic human communication exchange used in conversational marketing between companies and customers. More broadly, artificial intelligence (AI) for marketers ‘comprises systems that change behaviors without being explicitly programmed based on data collected, usage analysis and other observations for marketing use cases’ (Chaffey, 2020). Such AI technologies are driving innovation in voice marketing via smart speakers (Turow, 2021) and in company’s interactive communications and customer support. ‘AI will help marketers deliver relevant experiences to prospects and customers with increasing effectiveness and efficiency’, yet Gartner’s analysis of technology adoption is a reminder that AI hype in marketing still outweighs actual adoption (Chaffey, 2020).

Events and user experience (UX) branded content One historically deep-rooted form is brand sponsorship of live events and activities, either business-to-business (B2B), such as conferences and trade exhibitions, or consumer-facing, consumer experience (CX) activities, notably in sports, entertainment, leisure, and consumer goods. This is another space in which the distinctions between marketing and media blur, although with some important differences from the problematics of embedded advertising in publishing, television, or other content associated with an independent media provider. For instance, in UK, television rules on sponsorship mean that a brand associated with a broadcast event cannot exercise editorial control. In the games industry, however, major tournaments can provide live-event experience and programme content shown on brands’ owned media in which the brand is in creative, editorial control throughout. In such activities, distinctions made in the example of UK regulated commercial television between sponsor, funder, producer, and event-host become fused together. Mapping the emerging media–marketing ecology requires tracing the main actors, actants, and processes operating across marketers, marketing agencies, intermediaries,

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and automated processes, platforms, communication, and media services. It also needs to be refined and extended by the insights from more granular examinations of these relationships across different domains and practices, such as the fashion–media–retail nexus (Bartlett et al., 2013) or music–media–promotion nexus (Meier, 2016). In Bacardi’s B-Live events, since 2007 the brand has acted as a record label and artist management, working in partnership with bands such as Groove Armada and global DJs to curate live events and tours. Insights from those more granular studies will help to build up a better general map of relationships while continuing to highlight missing dimensions and various conceptual, empirical, and methodological challenges.

Industry (re)organisation: Marketers, agencies, and intermediaries The production of branded content is carried out by an ever-shifting range of actors, but some core agencies can be identified. A brand’s ‘owned’ content is produced by in-house teams, contracted out to external suppliers, or a mixture of both. In-house teams may be located in traditional demarcations, such as marketing or public relations, but dedicated branded content and associated terms came to define executive positions and departments. Branded content has also been only one of many reconfigurations, with positions and units for social media marketing, for instance, also vying for authority over content marketing activities. For brands’ involvement with external partners, there has also been dynamic change and instability. As discussed in Chapter 1, advertising agencies have moved into the planning and production of branded content on behalf of clients, but faced competition from other suppliers of services to those clients, as well as from the services offered directly to clients by digital platforms and adtech intermediaries (Sinclair, 2020). This space includes the range of ‘promotional intermediaries’ (Moor, 2008) that manage branding, from consultants and market researchers to designers, content creators, marketing and media agency personnel.

Professional bodies Advertising agencies and marketers have each had their own general trade bodies to advance their interests. In the UK, the lead body for marketers is the Incorporated Society of British Advertisers (ISBA), which traces its origins to the efforts of seven advertisers in 1891 to challenge newspapers’ dubious circulation claims and identify the number of people who were actually reached by the advertising they paid those newspapers to publish (ISBA, n.d.). The Advertisers’ Protection Society (APS) was formally established in 1900 and became the ISBA from 1920. For marketing agencies, the Advertising Association, founded in 1924, represents UK advertisers, agencies, media, and research services in the advertising industry. There are also associations that have brought together marketers, agencies, and media, notably the International Advertising Association (IAA), founded as the Export Advertising Association in 1938 and renamed the IAA in 1953.

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Specialist trade bodies for branded content were established in the UK and other advanced economies in contexts where existing, broader-based trade bodies were already dominant, some with roots in the professionalisation of marketing in the early 20th century and others from the development of subsequent media and marketing practices. The lead UK trade bodies for marketing communication, across the period 2000–20, are the Institute of Practitioners in Advertising (IPA), founded in 1917, and the Internet Advertising Bureau (IAB UK), launched in 1997. Alongside these are specialist sectoral bodies, such as the Chartered Institute of Public Relations, founded in 1948. The UK has sections of international organisations, many headquartered in the United States. These include the DMA, formerly the Direct Marketing Association, renamed the Data and Marketing Association. In the US, the DMA has merged with the Association of National Advertisers. Other international bodies include WOMMA, the Word of Mouth Marketing Association. The lead specialist trade bodies for branded content in the UK are the BCMA and CMA. The Branded Content Marketing Association (BCMA), established in 2002, brings together those working in audiovisual from short-form video, podcasts, and advertiser-funded programmes, to influencer marketers in video and social media. The BCMA has established a global network. In the UK, the contract publisher Redwood helped to establish the Association of Publishing Agencies (APA) in 1993, which in 2012 rebranded itself as the Content Marketing Association (CMA). So the CMA’s origins lie in contract publishing, with members from these businesses, such as Immediate Media, the producer of Radio Times and BBC Good Food (among 75 brand titles). Like the BCMA, its activities have now broadened to match the multiplatform execution of branded content campaigns, but its origins in publishing remain evident in the composition and orientation of members.

Brand–agency–media relations The qualities sought in brands’ own content may be measured and planned for, but they are also intangible, uncertain, and unpredictable. The coming together of brands and popular culture, the creation of content that is affective, engaging, meaningful, entertaining, and informative is inherently risky. Brands are complex objects, which are ‘performative, distributed and relational’; it is ‘because a brand relates to consumers, and they relate to it, that it can operate as a device to manage markets and other collectives’ (Lury and Moor, 2010: 31). Brands are forms of immaterial, informational capital that ‘work as a kind of ubiquitous managerial [device] by means of which everyday life is managed, or perhaps better, programmed, so that it evolves in ways that can potentially generate the right kind of attention (and hence brand value)’ (Arvidsson, 2006: 7). At the same time, cultural industries are a ‘risky business’, as Hesmondhalgh (2019: 31–8) discusses. Much branded content involves the conjunction of branding and popular culture, where the risks are aggregated and intensified. That is mitigated somewhat by the lower costs of execution, for para-advertising forms relative to investment in larger or longer forms of cultural production, such as films

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and TV series. Yet the tensions are worked through in relations between brands, agencies, other content creators, and media publishers to secure qualities of authenticity, appropriateness, and integrity. This is articulated around the creation of value, conceived as a balance of benefits required across the main triad of brand, consumers, and media. However, that balance, examined further in Chapter 8, may be weighted in industry discourse. Speaking from a marketing agency perspective, Luke Southern discusses the importance, and challenges, of advising brands to cede control in order for agencies to co-create with a media partner or talent and be authentic in execution, ‘not creating a situation where you have a forced tension between brand, audience interests and whatever the mechanic is’. In this formulation, attention to the qualities to safeguard in media is diminished. Southern describes two types of brand clients, those who see branded content as merely repurposing 30- and 60-second spot ads across digital channels, and those willing to embrace the differences in purposes, design, and execution. Mentioning Pepsi’s much-criticised Kendall Jenner campaign crassly appropriating Black Lives Matter, Southern (2017) states: branded content, native advertising shouldn’t be tapping into trends, movements and repurposing for the benefit of the brand – the opposite is true in branded content – you want to go where the audience are and try and make the brand relevant to the interests the audience already have. Sometimes it can’t be done.

Conclusion The latter part of this book focuses on the problems of branded content, but argues that these problems are not evenly spread across all branded content. The problems are most acute in advertising that is integrated into media forms and formats where there are grounds for, and/or expectations of, separation between media and advertising. By contrast, much of brands’ owned content does not raise, to the same degree at least, problems of identification, separation, and embeddedness. However, there are problems with brands’ owned content, too. One key feature of brands’ ‘owned’ content is just that – it is ultimately owned and controlled by brands. With the growth of the internet and digital platforms, brands can control what, when, and how their content is shown. They have considerably diminished control over whether and how consumers engage. The relatively ‘captive’ cinema audience is dissimilar to an internet user who can move relatively freely, grazing and snacking as various anxious marketing accounts outline. Branded content can also be copied and re-posted beyond the brand’s immediate control, and is susceptible to critical communicative engagements from adverse comments to creative subvertising. Yet, as well as controlling how most users will encounter brands’ own content, marketers can also track engagement, gather valuable user data, and measure the effectiveness of their communication actions, as the next chapter explores.

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Hann, M. (2020) ‘“Farewell, Book of Dreams”: Who killed the Argos catalogue?’, The Guardian, 6 August. https://www.theguardian.com/lifeandstyle/2020/aug/06/the-argos-cataloguewhy-britains-love-affair-with-the-book-of-dreams-had-to-end. Hardy, J. (2018) ‘Branded content: Media and marketing integration’, in J. Hardy, H. Powell, and I. MacRury (eds) The Advertising Handbook, 4th Edition. Abingdon: Routledge. Hesmondhalgh, D. (2019) The Cultural Industries, 4th Edition. London: Sage. Holt, D. (2016) ‘Branding in the age of social media’, Harvard Business Review. https://hbr. org/2016/03/branding-in-the-age-of-social-media. Iqbal, M. (2020) ‘YouTube revenue and usage statistics (2020)’, Business of Apps, 17 November. https://www.businessofapps.com/data/youtube-statistics/. ISBA (n.d.) ‘About ISBA’. https://www.isba.org.uk/about/. Jessop, B. (2007) State Power: A Strategic-Relational Approach. Cambridge: Polity. Kirby, J. (2015) Best of Branded Content Marketing 2015. http://bobcm.editiondigital.com/ best-of-branded-content-marketing-2015-global-edition. Lury, C. (2004) Brands: The Logos of the Global Economy. London: Routledge. Lury, C. and Moor, L. (2010) ‘Brand valuation and topological culture’ in M. Aroncyky and D. Powers (eds) Blowing Up the Brand: Critical Perspectives on Promotional Culture. New York: Peter Lang. Mandel, E. (2018) ‘Coca-Cola dips toes into reality TV with first ever “digital docuseries”’, Atlanta Business Chronicle, 12 July. McCarthy, A. (2019) ‘See Kriss Kyle helidrop into Dubai in his new BMX film’, Red Bull, 5 April. https://www.redbull.com/gb-en/kriss-kyle-exploring-dubai-on-bmx-video. Meier, L. (2016) Popular Music as Promotion: Music and Branding in the Digital Age. Cambridge: Polity. Moor, L. (2008) ‘Branding consultants as cultural intermediaries’, The Sociological Review 56 (3): 408–428. Mullman, J. (2009) ‘Anheuser-Busch pulls the plug on Bud.TV’, Advertising Age, 18 February. https://adage.com/article/madisonvine-news/anheuser-busch-pulls-plug-bud-tv/ 134701. Quinn, T. (n.d.) ‘Contract, custom and customer publishers’, Magforum. http://www.ma gforum.com/custom_publishers.htm. Sinclair, J. (2020) ‘Cracking under pressure: Current trends in the global advertising industry’, Media International Australia 174(1): 3–16. Southern, L. (2017) Interview, 13 December. Stinson, L. (2013) ‘A genius of book design creates a tome with no ink’, Wired, 11 November. https://www.wired.com/2013/11/a-beautiful-book-printed-without-ink/. Swatman, R. (2015) ‘2012: Highest Freefall Parachute Jump’, Guinness Book of Records, 18 August. http://www.guinnessworldrecords.com/news/60at60/2015/8/2012-highestfreefall-parachute-jump-392848. Turow, J. (2021) The Voice Catchers. New Haven, CT: Yale University Press. Turow, J. (1997) Breaking Up America. Chicago: University of Chicago Press. Tur-Viñes, V. and Segarra-Saavedra, J. (2014) ‘Branded content y storytelling. El arte de crear contenidos y contar historias’, in R. Ron, A. Álvarez Ruiz, and P. Núñez (eds) Bajo la influencia del “branded content”: Efectos de los contenidos de marca en niños y jóvenes. Madrid: Esic, pp. 117–136.

5 GOING NATIVE IN DIGITAL MEDIA

The internet’s evolving forms have intensified challenges to the separation of editorial and advertising that were already being felt across the legacy media of print and television. According to leading industry voices, the future lies in integrating marketing communications into the communication encounters of users. This chapter examines the social media practices connected with key buzzwords, including ‘native advertising’, ‘sponsored posts’, and ‘stories’, and the embedding of marketing communications within digital and social media. The broader context for these new forms of marketing communications is the rise of digital media platforms and apps taking an ever-increasing share of user time and attention. Yet these are not merely ‘opportunities’ for marketers, or part of an ever-expanding range of media vehicles on offer. Instead, these platforms have either arisen or subsequently developed their pitches to investors based on the monetisation opportunities of attracting advertising that will work as part of a more seamless user experience.

Digital advertising Some key features of digital advertising will be outlined first before considering native advertising in greater detail. Digital advertising types include display ads (composed of images and texts and formats including banner ads and interstitials); search engine marketing; email marketing; video ads; social media ads; mobile ads; and native advertising. With the expansion of broadband access and faster wireless interconnectivity, marketers developed so-called rich media ads, predominantly video formats. Mobile advertising carries all these forms but also others developed specifically for mobile, such as mobile wallet, moment, tile, and dynamic product ads (Verizon, 2019). Ad types include story ads (in-feed advertising linking to editorial content), video ads linking to video content, app install ads enabling app download, and product (listing) ads linking to e-commerce sites (IAB [Interactive DOI: 10.4324/9781315641065-6

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Advertising Bureau], 2015: 7). Key claims made for the marketing effectiveness of mobile video advertising include high shareability compared to all other types of content. Video scores highly for brand recall, SEO performance, and versatility, and works well across diverse mobile devices (Brannon, 2019). In-feed advertising refers to the placement of advertising within content, social, or product feeds (Borst, 2015). In-feed accounted for 92 per cent of total UK native advertising expenditure in 2017 (IAB [Interactive Advertising Bureau], 2017). Examples of in-feed are the images and carousels (collections of two or more scrollable images) used on Facebook. The remaining 8 per cent of the market is so-called ‘native distribution’, mostly content recommendations that appear in publisher pages and which promote branded content.

Platforms The US tech companies dubbed FANGS (Facebook, Amazon, Netflix, and Google) illustrate the rising power of platforms within digital communication systems. In a landmark lawsuit in November 2020, the US Department of Justice described Google as a ‘monopoly gatekeeper for the internet’ that was ‘unlawfully maintaining monopolies in the markets for general search services, search advertising, and general search text advertising in the United States’. The US government alleged that Google uses billions of dollars collected from advertising revenue to pay mobile-phone manufacturers, carriers, and browsers, such as Apple’s Safari, to retain Google as their pre-installed, default search engine, ‘creating a self-reinforcing cycle of dominance’ (Kendall and Copeland, 2020). The US digital giants have each established market dominance in their niche areas, acquiring competitors and using market power or uncompetitive behaviour to carve out quasi-monopoly positions aided by the winner-takesall dynamics of network effects. The FANGS are not dominant in all national markets and face powerful rivals. The world’s second largest advertising market, China, has its own tech giants, including Alibaba, JD.com, Tencent, Xiaomi, and Meituan. Alibaba and JD.com dominate the online retail market with Alibaba claiming to reach 881 million active monthly mobile users, more than half the population of China (BBC News, 2020). The largest social platforms in the world, including Facebook, Twitter, Instagram, TikTok, and Tumblr, offer services that are free from direct charge to users but are monetised by advertising. There is direct monetisation from advertising sales and indirect monetisation from user data capture that is then monetised for marketing purposes by platforms and sales to third-party marketers. Most of the advertising formats are ‘native’, including in-feed native ads, sponsored posts, and sponsored stories. In 2020, Google’s net US digital ad revenues fell for the first time, from $41.8 billion in 2019 to $39.6 billion, bringing its market share down from 31.6 per cent to 29.4 per cent. Google’s ad growth had been slowing compared to the growth rate in the market overall, but the company was hit by the sharp decline in retail, small business, and travel advertising during the 2020 Covid-19 pandemic

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(eMarketer, 2020). Google is the global market leader in digital advertising, with Google AdSense (61 per cent) and Google Ads’ (21 per cent) share of over 35 million websites tracked by Datanyze (2020). Google Ads is one of the leading advertising service companies for web and mobile, supporting banner ads, and in-app, video, and other ad formats. Formerly called AdWords (2000–18), Google Ads is an online advertising platform whereby advertisers bid on keywords in order for their clickable ads to appear in Google’s search results. Advertisers pay to display advertisements, product listings, video, or other content, and can generate mobile application installations to users within the Google ad network. The Google Ads programme enables marketers to place advertisements within Google search results pages or across the Google Ads network of partner sites. Google’s AdSense programme delivers those Google Ads to publishers’ websites. AdSense matches advertisements to publishers’ sites, based on data analytics covering site content and visitor user data, and delivers advertisements using an auction to automatically select the highest paying ads that appear on publisher pages. Payment to publishers is made based on user clicks or ad impressions, depending on the type of ad. Google’s Ad Manager caters for the publisher side and is a complete ad exchange platform, facilitating the buying and selling of ads across multiple ad networks, including AdSense. AdMob was acquired by Google in 2010 and is now one of the largest mobile advertising platforms, incorporating native, video, and other ads into client’s apps. It uses Google’s AdSense and other technologies and offers rich reporting and analytics to track how users engage with mobile apps and ads. Measures taken by Apple, Google, and Mozilla in 2020 to increase their browsers’ privacy controls for users will impact on the adtech models of Facebook, Google, and others, but precisely how is yet to be determined (Chaffey, 2020). Amazon Advertising includes a suite of services, including its demand-side platform, posts, audio ads, sponsored products and display, and Amazon Live, shoppable ad streams. Amazon’s sellers are obliged to spend to advertise within and through Amazon’s controlled environment, with the company accumulating behavioural surplus and market power through the data profiles of users, as it has done from its bookselling origins. The other main digital media platforms all have their own ad services: Apple Search Ads, Snapchat Ads, Twitter Ads, and so on. Snapchat introduced sponsored lenses in 2017, and the following year added features to allow marketers to sell goods with links to their websites in the lenses. Sponsored lenses enabled product marketing/ placement, such as for the Galaxy S9 and DC’s Superman lens for Action Comics #100 (Heater, 2018). With ‘Shoppable AR’, advertisers could now add a button to Snap Lens which lets users ‘click and buy the product being advertised without leaving the Snap experience’ (Heater, 2018), with eCommerce opportunities added. In 2020, Snapchat and Gucci launched ‘the first global sponsored augmented reality shoe try-on Lenses’, allowing users to purchase shoes directly from the Lens (Hutchinson, 2020). Facebook offers ad formats, including ‘photo, video, stories, messenger, carousel, slideshow, collection, and playable ads’ (Grover, 2019). Owning Instagram and Messenger, Facebook offers cross-platform integration, enabling marketers to run ads across these apps, and thousands more via Audience Network. Marketers can use self-service tools to select objectives, such as raising brand awareness and

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generating leads, use target audience selection tools, monitor performance, and adjust campaign elements accordingly. Facebook Business also offers Instant Experience, which marketers can use to offer a mobile-only, full-screen experience for storytelling in any of the formats of Facebook Ads. The platforms are not only the main beneficiaries of digital advertising spending but have established control over the advertising market, advertising data, and the connections between brands and marketing opportunities, including influencers. In particular, Google and Facebook own the major ad exchanges, Facebook Exchange and AdX, Google’s programmatic advertising platform. Altogether, Google controls nearly 70 per cent of the online tech market (News Media Alliance, 2020). The powerful duopoly of Facebook and Google accounted for an estimated 56.4 per cent of the global online ad market in 2018, predicted to grow to 61.4 per cent in 2019 (WARC, 2019). Google and Facebook are expected to hold over half of the total US market for programmatic ad revenues in 2019 and increase market share further by 2021. ‘Even with Amazon ramping up its advertising practices, as well as an influx of mobile, over-the-top (OTT), and connected TV ad inventory entering the space in the next 24 months, the duopoly will still dominate’ (Fisher, 2019). Three-quarters of US internet advertising revenue in Q4 2018 was concentrated in the hands of ten ad-selling companies (IAB [Interactive Advertising Bureau], 2019b: 11). As the IAB puts it, euphemistically: In more mature market segments, the fight over the existing eyeballs is heating up. Large players that service both their own properties as well as offering sophisticated ad platforms that serve the ‘open’ internet continue to put pressure on stand alone publishers and smaller ad networks and platforms. (IAB [Interactive Advertising Bureau], 2019b: 4) If the new digital giants are biting hard into the market share and activities of marketing agencies, the latter face further massive erosion based on the same digital affordances. The first actor-group, marketers, are enabled and incentivised to bring more digital marketing activities in-house. For instance: Marketers’ internal programmatic ad buying is the fastest-growing category programmatic spending, according to ad-tech company Index Exchange. At the end of 2013, 11% of the ads bought through Index were from brands’ inteams. At the end of 2014, the number had grown to 15%. (Kantrowitz, 2015)

Social media Social media advertising is ‘delivered on social platforms, including social networking and social gaming websites and apps, across all device types, including

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desktop, laptop, smartphone and tablet’ (IAB [Interactive Advertising Bureau], 2017: 14). The social media platforms Facebook, Facebook-owned Instagram and WhatsApp, Tumblr, and Twitter were early adopters and now depend on native advertising revenues as their primary source of income. The vast majority of social media advertising is native (Benes, 2019a; 2019b). Native ads are considered to be less invasive and disruptive than formats such as banner ads, and integrate better with other content and scrolling on mobile. However, the supposed distinctiveness of ‘native’ is misleading, with a more complex process of naming occurring. The characteristics of being ‘native’, meaning seamlessly integrated, are being stretched to apply to a wider range of ‘new’ advertising formats, including those that are indistinguishable from ‘interruptive’ display or video ads. Native is a more palatable, contemporary term to cover a broad category of advertising, or indeed all advertising, on selected social or mobile platforms. In addition, older and more derided formats, such as banner ads, have themselves continued to evolve and hybridise with ‘native’. Banner ads have continued to improve on mobile sites, while remaining, in the words of one analyst, ‘fairly intrusive’ (Ho, 2017). So, the extent to which advertising is ‘native’ is a matter of variation and dispute, but social media are at the leading edge of formats for content funded or produced by brands. Branded content is integral to the business practices, cultural practices, and communication exchange in organised social media.

Sponsored stories In October 2013, Snapchat launched Snapchat Stories, enabling users to combine their single snaps in a narrative format that friends could view for up to 24 hours (Wiltshire, 2018). The stories format was then adopted and developed by other social media platforms, most notably Instagram. The IAB identifies brand storytelling as a growing trend across platforms: ‘consumers, especially Gen Z, are adopting social stories at warp speed [such that] social stories may surpass social feeds in becoming the prevalent way consumers engage with advertisements on social media’ (IAB [Interactive Advertising Bureau], 2019b: 5). Video-sharing platform TikTok tested and developed sponsored videos that direct users to an advertiser’s website. In one of the first reported uses, a video clip featured a ‘Sponsored’ label from retailer Specialized Bikes and a blue ‘Learn More’ button to tap (Williams, 2019). Sponsored videos formed part of wider efforts by TikTok’s Chinese parent company ByteDance to intensify monetising the usergenerated content posted by millions of its users. TikTok took off rapidly in the US, with the app downloaded over 80 million times by November 2018, and nearly 800 million times worldwide. TikTok was then the only app of the five most popular US downloads not owned by Facebook.

Social media revenues Social media advertising grew strongly, at a 46.6 per cent compound annual growth rate in 2012–18 before slowing (IAB [Interactive Advertising Bureau], 2019b: 17). The rate of growth continued to outpace the digital advertising market

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overall, with revenue of $28.9 billion in 2018, a 30.6 per cent growth over 2017 (IAB [Interactive Advertising Bureau], 2019b). Since 2007, brands could use Facebook’s Fans pages to create a page for their company or organisation, amass fans, and post unlimited messages to their fan base. They did so on the assumption that fans would see those messages in their News Feed. Organic reach, referring to the number of users that can see a post organically, without paid media behind it, declined during the 2010s. According to Facebook, this decline was due to the increasing amount of content created daily, making it harder for content to gain exposure in News Feeds (Boland, 2014). However, studies showed that only a fraction of fans were seeing organic posts in their news feed; a study by Edgerank Checker found that between 2012 and 2014, organic reach per fan fell from 16 per cent to 6.5 per cent for the average Facebook page (Bernazzani, 2018). Subsequent changes to Facebook’s algorithm contributed to the company’s successful efforts to steer more brand promotion from (unpaid) self-publishing content to paid advertising. In 2018, almost three-quarters of US native display ad spending was on social ads, partly because almost all social advertising is native … Paid social is the name of the game for content distribution/native advertising and organic engagement is more difficult to achieve with publishers desiring greater reporting transparency from the social platforms. (IAB [Interactive Advertising Bureau], 2019a: 4) Facebook India Director, Sandeep Bhushan, promotes branded content ads on Instagram as giving ‘advertisers the ability to promote creators’ organic branded content posts as feed and stories ads, thereby reaching new audiences and measuring impact’ (Farooqui, 2021). Paid social is also increasingly important for influencer marketing: ‘Thanks to extremely granular ad targeting provided by social media platforms, not only can brands ensure that their high-performing influencer content gets seen despite tricky algorithms, but they also can greatly amplify their overall campaign impact’ (Wiley, 2021). The Native Advertising Institute reported native display advertising revenue in the US of $59.35 billion in 2018, more than double the growth rate of digital advertising overall. That year, US digital ad revenues exceeded $100 billion for the first time ($107.5 billion), increasing 21.8 per cent over 2017 (IAB [Interactive Advertising Bureau], 2019b: 2). Native advertising was expected to be two-thirds of the total US display advertising market in 2020, up from 54.2 per cent in 2017 (eMarketer, 2019). eMarketer (2019) also predicted that native advertising in the US market will become more programmatic and more mobile than in 2018, with reduced spending on social media. Mobile native was predicted to grow to 88.8 per cent of all digital display, with 87.7 per cent also being programmatic, but with the share on social media falling from 76.7 in 2018 to an estimated 73.5 per cent in 2020. Figures for high rates of growth of native can be misleading unless placed in the wider context of marketing spending. The eMarketer report cites MediaRadar’s H2 2018 analysis, which shows that the number of advertisers using native for the first time has not risen, indicating a mature

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market. Only 11 per cent of online advertisers were using native ad formats in 2018, according to MediaRadar (2018). For eMarketer analyst Nicole Perrin, ‘The US native ad market is still growing, but the “typical native ad” isn’t changing much: It’s bought programmatically from a social network and served to a mobile device’ (Benes, 2019a). Overall, native advertising is ‘succeeding’, argues Adyoulike Europe CEO Julien Verdier (2016), ‘because it answers a lot of the issues with display ads: creative, high-quality content is delivered in-feed in a way that works perfectly on mobiles and smaller screens’.

Programmatic advertising A simple definition of programmatic advertising by the Display Trading Council is ‘the use of automation in buying and selling of media’ (Rogers, 2017). In fact, automation extends more widely across processes, affecting how ads are constructed, sold, selected, placed, tested, formatted and reformatted, tracked, and evaluated. A subset of programmatic advertising involves Real-Time Bidding (RTB), a set of market transaction practices that are dependent on the application of advertising technology (adtech). Adtech refers to the software, tools, and processes used to select, create, bid for, purchase, and place digital advertising opportunities. The actors involved include the core triumvirate of marketers, marketing agencies, and media, but with the latter two joined, and displaced, by platforms and digital advertising service intermediaries. Adtech is used for the buying and selling of advertising inventory and describes the ‘tools that analyse and manage information (including personal data) for online advertising campaigns and automate the processing of advertising transactions’ (ICO [Information Commissioner’s Office], 2019: 8). This covers the entire advertising delivery process, which often involves several intermediary third parties, although some transactions are conducted directly between advertiser and publisher. Advertising Exchanges are ‘[p]latforms for comparing the price and quality of impressions, the “location” where the bidding aspect occurs. They serve as mediators and connectors between advertisers and publishers and operate on both the demand and supply sides’ (ICO [Information Commissioner’s Office], 2019). Data Management Platforms (DMPs) collate and analyse incoming data from sources such as desktop and mobile websites and apps, social media, data analytics, and offline data, including bid requests, to support the personalisation and targeting of adverts to users. Demand Side Platforms (DSPs) buy advertising inventory (space on websites) ‘based on behavioural, and often personal data. If the impression matches the advertiser’s target audience then a bid is placed via the DSP’; Supply Side Platforms (SSPs) aid the sale and management of advertising by publishers; and Consent Management Platforms (CMPs) ‘serve as a tool for publishers, for example to enable them to manage user consent, and to facilitate the operation of frameworks such as the IAB Europe’s Transparency and Consent Framework’ (ICO [Information Commissioner’s Office], 2019: 11–12). Programmatic advertising takes various forms, but the most common is an automated auction that occurs when users select and load a web page, in which

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advertisers bid to place an ad on the page. Typically, such bids are made based on what an advertiser knows about you, the user. In such transactions, the website publisher puts the ad space up for auction, advertisers (or their ad agencies) bid on it, and intermediaries known as adtech firms handle the details (Thomas, 2018). A user visiting a site makes an ad impression available. The SSP sends a bid request on behalf of the publisher site. The DSP (native DSP in the case of native advertising) responds with metadata and bids for the space on behalf of marketers. RTB is based around a potential advertiser accessing information about users. As a site loads, the publisher auctions space on the page and this is bought by an advertiser seeking to reach users based on specific information about them. Such information may be basic, such as the country location or the type of device used to access the site. It may also be highly detailed information enabling the targeting of specific user profiles with precision. A publisher or operation of an online service usually collects user data by using cookies and similar technologies whenever a user visits the site or service, including information about themselves, their device, and the visit made to the website or app. The process of RTB can involve many companies across the value chain and involves the rapid transfer of data and transactions: ‘the collection of the user’s information, the creation of the bid request, the auctioning, bidding and securing of the advertising space and subsequent presentation of the advert to the individual all take place in milliseconds’ (ICO [Information Commissioner’s Office], 2019: 11). ‘Millions of bid requests are processed every second, utilising automation, which involves the leveraging of multiple data sources into user profiles shared throughout the ecosystem’ (ICO [Information Commissioner’s Office], 2019: 11). The information collected by the publisher is incorporated into a ‘bid request’. This is circulated in the RTB system so that advertisers can bid to insert their ad into the space auctioned so that it is presented to the individual user. Data is also collected for the advertising. Banner ads are composed of a single data file. For native programmatic, by contrast, ‘the ad unit is made up of multiple components that must be transferred in the process of bid request and bid response and are considered by both the advertiser and publisher’ (Sharethrough, n.d.a). These components include metadata and usually include the headline, thumbnail image, brand name, brand logo, and description. The Native SSP receives metadata and selects the winning bid, and then assembles the native ad from components to fit the design, format, and layout of the site or app. US spending on programmatic advertising in 2018 was forecast at over $46 billion, representing more than 82 per cent of total digital display ads, rising to $60 billion in 2019 (eMarketer, 2018; 2019). More than 85 per cent of native display ads were expected to be transacted programmatically in 2018, and 88 per cent by 2021 (eMarketer, 2018; 2019).

Native advertising formats The IAB Native Advertising Playbook, first published in 2013 and revised in 2019, provides an authoritative classification and description of native advertising types. The 2019 edition removed four categories: in-ad (with native elements); custom;

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paid search; and promoted listing. The new classification schema identified three native advertising types, two retained from 2013: in-feed/in-content and content recommendation ads; and one new type: branded/native content (IAB [Interactive Advertising Bureau], 2019a: 5). In-feed/in-content is the most prevalent native ad format and includes ads appearing within the feed of content on publisher, commercial, and social media sites and apps. Another common format is content recommendation ads (formerly widgets). As the ASA (2020) notes, ‘Native advertising is not limited to “advertorial”-style materials. It may include links to other websites; for example, where brands have paid for content aggregators (or “Content Discovery Networks”/“Content Recommendation Engines”) to serve ads for their products to readers under a heading such as “from around the web” or “you may also like these”’. The third type, Branded/Native Content, is described by the IAB (IAB [Interactive Advertising Bureau], 2019a: 7) as ‘paid content from a brand that is published in the same format as full editorial on a publisher’s site, generally in conjunction with the publisher’s content teams themselves’. The IAB notes that such content requires disclosure to the consumer that it is paid for: ‘[t]he content itself, therefore, should be considered as a native ad type’ (IAB [Interactive Advertising Bureau], 2019a: 7). In-feed and content recommendation are adverts for content located elsewhere; branded/native content is the substantive content itself. According to the IAB (IAB [Interactive Advertising Bureau], 2019a: 13), there are three primary types of feeds where native ads typically appear: Content feeds typically include articles, images, or video branded/native content, e.g. publisher content sites and news aggregators such as CNN and Yahoo. Product feeds typically include product, services, or app-install branded/native content, e.g., retail sites and app listings such as Amazon, Etsy, and eBay. Social feeds typically include social content, articles, videos, stories, images, and music branded/native content, e.g. social networking and messaging apps such as Facebook, Instagram, and Twitter. The IAB definitions are used for ad unit identification purposes and inform the openRTB protocol established for programmatic advertising. The openRTB standard was established in 2011 and continues to be updated. OpenRTB 2.0 brought together display, mobile, and video advertising. Open RTB 2.3 introduced in 2015 added a new top-level object native to the existing banner and video objects. The native object, the advertisement, was described in the communication between SSPs and DSPs in two main ways: ad unit ID and layout ID. OpenRTB 2.3 ‘ushered in an era of standardization for native advertising: programmatic native’ (Larson, 2016). In 2016, an updated specification for buying and selling native ads was developed for the IAB Standard, known as Native 1.1. The original Native 1.0 spec had defined the native object (by ad unit ID and layout ID) so that a supply source (SSP/exchange) could request the specific items needed as part of the ad, such as thumbnail size and headline lengths. A demand source (DSP/bidder) could then respond with assets matching the specifications of the SSP. However, there was no specification concerning what those assets themselves looked like. ‘Each

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supply source was free to define their own standards for things like image size, aspect ratio, headline length, brand name length and more’ (Larson, 2016). This created particular problems for the demand side in managing different supply side requests, notably ones requiring resizing for thumbnails, headlines, and so on. The second key challenge concerned ad unit definition. The original Native 1.0 specification used the IAB Playbook (2013) definitions which lacked precision and mixed context and layout descriptors, hampering classification, measurement, and scalability. So, the new Native 1.1 specification classified native inventory in two ways: context and placement type, drawing on the revised IAB classification, first set out in In-Feed Deep Dive (IAB [Interactive Advertising Bureau], 2015).

Mobile native formats The Mobile Marketing Association (MMA [Mobile Marketing Association], 2015) distinguished mobile native from content marketing as follows: ‘Where content marketing aims to match content and format, native advertising, at least on mobile devices, is primarily an ad format that matches the style of the site or app where it serves. Moreover, native advertising can be bought programmatically, whereas content marketing usually requires editorial involvement.’ One of the fastest growing mobile advertising sectors has been in-app native ads, displayed within a mobile app, usually within gaming apps. The global in-app advertising market was valued at $82 billion in 2017 and was projected to grow by 20 per cent from 2019 to 2025, when it would reach $258 billion (openPR, 2019). Key players include Apple, Amobee, Groupo Mobile, Phone Valley, Mobile Dream Factory, AOL, Tapjoy, InMobi, Google AdMob, among others (openPR, 2019). Native ad growth has occurred in the context of increased in-game spending with Facebook, Google, Snap, and other ad-dependent companies investing heavily in the gaming market, and creating gaming platforms, such as Google’s Stadia (Williams, 2019). In September 2018, YouTube unveiled plans to offer vertical video ads as well as sell video ads based on users’ personalised home feeds. The Drum reported that ‘[a]dvertisers can now snap up slots that fill up a users’ screen when they’re viewing content on YouTube’s mobile app in a similar way to the ads served by the likes of Instagram and Snapchat’ (Stewart, 2018). According to the IAB (IAB [Interactive Advertising Bureau], 2019b: 5), marketers and influencers ‘ are rushing to push-out [sic] ads in a vertical video format in an effort to turn consumer interaction into actual conversions’, but noted that social media companies needed to convince advertisers of the efficacy of the story ad platform for growth. Combining video with native advertising, argues Verizon (2019: 7), ‘is compelling to both advertisers and consumers. People engage with native video ads more than traditional display ads, showing fixation rates up to 90% for native video on mobile’. Both vertical and horizontal video formats on mobile work effectively in split screen mode, Verizon states, enabling ‘contextual material to run alongside video, making this an attractive vehicle for links to brand communications and e-commerce’ (Verizon, 2019: 7).

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Native advertising market actors The IAB is one of the key participants in the global native advertising market together with the content recommendation firms Taboola and Outbrain, and native advertising platforms and providers such as Sharethrough, Adyoulike, AdsNative, TripleLift, Nativo, Instinctive, Polar, OneSpot, and Livefyre, among others. Sharethrough, OpenX, PubMatic, rubicon, and MoPub are Native SSPs, while Appnexus, MediaMath, Turn, and theTradeDes are among the leading Native DSPs. Adyoulike is a leading Native SSP, serving 33 million video ads in the first four months of 2018 (Sullivan, 2018). In 2019, it announced a new mobile ad service, Native Stories, in an exclusive deal with GMC, publisher of Marie Claire and other magazines. Developed as a response to the growth of ‘stories’ formats across Instagram, Snapchat, and other social media, Native Stories ‘allows premium publishers to create … a content carousel at the top of all their mobile pages … and monetize it with advertising sold in a Stories format’ (PR Newswire, 2019). Across the fast-developing market, new native ad platforms have been created by specialist firms such as Sharethrough and MoPub, but with the major digital firms, including Google and Yahoo!, involved in supply and increasing market share.

Native advertising effectiveness One of the key measures for video ad effectiveness is the view through rate (VTR), the number of completed views of a skippable ad over the number of times it was rendered. Adyoulike (2018) reported an in-feed native video VTR average of 40 per cent worldwide, slightly higher at 42 per cent in the US, UK, and Ireland. The broader case for native advertising effectiveness is advanced by key industry actors. A Sharethrough/IPG Media consumer survey and eye-tracking study found native ads attracted more attention (25 per cent) and consumers ‘looked at native ads two times more than editorial content and spent the same number of seconds viewing’ (Sharethough, n.d.b). Verizon Media (2019: 11) reported its research finding that native advertising achieved higher engagement, with click-through rates (CTR) of 11 times greater than for display ads. Verizon Media’s Native Mobile Format Analysis (2018), based on a survey of 8,700 US adults 18–54, found that users viewed native video longer than native banner ads (5.9 seconds on average) with positive associations (high quality 81 per cent; entertaining 76 per cent). Two -thirds stated native ads tested were not disruptive. Industry actors have also invested in psychosocial and in neuroscientific research to act on findings concerning engagement in the competitive struggle for the economic resources derived from attention. A neuroscience study conducted by the Association for Online Publishing (AOP) and the UK national news brands trade body Newsworks examined how the brain responds to advertising in social media versus premium editorial environments. The results, in line with Newsworks’ marketing campaigns, were that ‘while social media is better at delivering ad attention, premium editorial environments deliver higher long-term brand value and 50% higher engagement’

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(Verizon Media 2019: 13). Sharethrough (n.d.b) concludes from one of its own neuroscientific studies: ‘[a]s mobile adoption and usage grows, consumer attention will become increasingly elusive. Native ads command focus and attention. They can be an effective method for marketers to share their brand’s stories and narrative to the highly distracted mobile consumer.’

Native advertising: Evolving forms and practices Open audio platform Soundcloud operates a partnership with digital audio advertising firm Targetspot in the developing space of audio marketing. In 2019, it expanded into 14 new national markets countries, launching an ad-free premium subscription service (SoundCloud Go+) alongside its free, ad-supported service (SoundCloud) with audio, video, and in-stream native advertising (Stewart, 2019). RTB is most commonly used to sell visual advertising inventory, but the techniques are being applied to audio streaming, as well as facial detection/recognition technology on digital outdoor billboards and screens (Digital out-of-home – OOH) (ICO [Information Commissioner’s Office], 2019). Branded content is now integrated into the voice assistance services, such as Google Assistant, Amazon’s Alexa, and Apple’s Siri, which manage the interface of brands and consumer purchase decisions. This voice intelligence industry has grown rapidly across Europe and North America, so that in 2019 Amazon’s Alexa was available on more than 100 million devices, and Google Assistant on more than a billion (Bohn, 2019). Through voice profiling and data harvesting, these companies can extend knowledge about people’s lifestyle and consumption choices, activities, conversations, and articulated thoughts, including in the most intimate and private parts of their lives. Turow (2020: 6) links the development of voice profiling to an underlying dynamic of ‘the unending spiral of personalization’. Previous forms of digital personalization have been based on demographics, psychographics, geodemographics, internet behaviours, and lifestyle. Going forwards, in order to identify, know, and target audiences more effectively, marketers will be open to technologies – voice profiling, for example – that promise new forms of information through progressively greater intrusions into people’s lives. These practices will also turn out to be unsatisfying, though, and the drive for deeper ways to know the customer will continue – for instance, by linking voice intelligence to even more intrusive technologies. (Turow, 2020: 3; 2021) Voice profiling creates new means to select, assess, stratify, and discriminate by selecting but also by creating tools to de-select and exclude and to discriminate against people by algorithms and operations that will influence access to resources and social opportunities. Focusing on categories of ‘media’ services, and ‘advertising’ or promotional communications, risks downplaying the scope of innovations in commercial and corporate integration undertaken to create economic value for capitalist enterprises.

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One example is companies’ development of their own branded mobile apps. Recognising that consumers spend the majority of their mobile internet time within apps, brands have developed apps to provide services, like banking or ecommerce, but ‘many of these apps have untapped potential […] as powerful video delivery mechanisms that increase engagement and brand loyalty’ (Hurwitz, 2019). Under platform capitalism, brand marketing and brand-shaped communications are integrated into the interface between users, search, and services throughout their personal space and interactions. Digital marketing, including branded content, is the funding source, model, and driver for the development of digital services and datafication. The current developments are only indications of the extent to which much greater integration is possible across communications content services, marketing and promotion, e-commerce, tracking, and data analytics.

Social media influencers ‘Traditional modes of publishing now sit alongside vast international online platforms where people and brands alike publish their own content’ (ASA, 2019). The early internet created opportunities to publish and distribute content without at least some of the barriers that shaped traditional modes of publishing. From the early bulletin boards to web pages and weblogs (blogs), the Internet enabled organisations, movements, and individuals to have ‘voice’. The platforms for user-generated content, from YouTube to Instagram and TikTok, have vastly expanded the opportunities for mass self-communication (Castells, 2009), and for self-promotion. The relationship between advertisers and the emergent communication spaces and communicators is a rich and complex one, but very crudely follows an arc from antagonism to accommodation. The commercialisation of the internet was contested at all levels, from infrastructure and governance to advertising messages (Schiller, 2000; Simpson, 2004; Curran and Seaton, 2018). Influencer marketing (IM) developed in the conditions of an already thoroughly commercialised internet, yet contestation over commercialisation remains a vital element. Likewise, the constitution of the promotional is a complex story, as advertising develops within and alongside the self-promotion and crosspromotion of those producing and publishing content (Chapters 6, 11). An influencer is an individual who produces regular or recurrent communications content that reaches an audience via digital media platforms. Influencers may have already built, or concurrently be building, their public profile through traditional means (film or television) but more often they have found their fame purely online. Crucially, they speak directly to these online audiences generally without the editorial control that exists in traditional forms of media by, for example, publishers. (ASA, 2019) Some influencers post on specialist topics only, such as craft-making or cookery, but many post about their daily lives, including mentions for products and services

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they purport to like and use. Such mentions can include hyperlinks to online locations such as a brand’s Twitter handle or Instagram (ASA, 2019). ‘Influencers, by definition, inspire and empathize with the same consumers that marketers seek to engage. They bridge the gap’, says Liz Gottbrecht, VP of marketing at Mavrck (Nickalls, 2018). The rise of influencers from the 2000s has occurred during a period of unprecedented upheaval for established marketing practices using mass media channels. Brands have responded to the new opportunities offered by influencer marketing, especially to reach younger demographics (Yesiloglu and Costello, 2020). Influencer marketing activities range from brands’ supply of free products or services in the hope of favourably mentions, to elaborate contractual relations specifying content to be posted, and other arrangements, in exchange for payment. Influencer marketing falls under the IAB UK’s (2018) designation of ‘[p]ublisher-hosted and/or made advertising content: commercial content that is advertiser controlled or jointly publisher/advertiser controlled […]. In this context, a “publisher” includes content creators such as influencers, bloggers and vloggers and advertising content includes paid promotions on social media.’

Origins and development The history of ‘influencers’ is rightly extended to encompass the social and cultural organisation of human societies from its earliest formation. The growth of professional public relations and ‘third-party endorsement’ in the early 20th century built upon the attributes of influence demonstrated by rulers, monarchs, celebrities, artists, and opinion leaders, but connected these with the developing mass media channels and brand marketing (Bernays, 2004 [1928]). In the digital age, however, a much more diverse range of communicators could reach audiences, without the costs and barriers of professional, institutionalised communication, creating the conditions for micro-celebrities (Marwick, 2013). Blogging took off in the early 2000s, YouTube launched in 2005, Instagram in 2010. By 2016 an estimated $570 million was spent on influencer marketing on Instagram alone (eMarketer, 2016). An AdWeek survey in 2018 found that over 50 per cent of influencers had only started producing content since 2016, a third only since 2017 (Nickalls, 2018). Most (90 per cent) wanted free products or services from brands in exchange for their posts; 63 per cent said they were looking for monetary compensation, while 44 per cent said their motivation in creating content was to share a passion (Nickalls, 2018). According to a report on influencer marketing based on surveys with 181 marketers and agencies (Linqia, 2018), 86 per cent used influencer marketing in 2017 and 39 per cent planned to increase spending in 2018. A majority saw measuring ROI as the main challenge. The issues of disclosure of brand support, misinformation and fakery, consumer protection, and brand safety are examined in Chapter 7, but form part of the turbulent as well as meteoric rise of influencer marketing. Swedish YouTuber Felix Kjellberg, known as PewDiePie, rose to prominence with his Let’s Play gaming

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videos, which he started in 2010, becoming the first person to reach 100 million subscribers on YouTube. Leveraging his enormous audience base, Kjellberg secured lucrative brand deals, yet a series of anti-Semitic, alt-right, racist, and misogynist comments drew controversy that spread to brands who paid or were slow to cease dealings. Some brands continued to engage with Kjellberg during the controversy; an LG spokesperson ‘confirmed that its home electronics division had sponsored the video that was uploaded on 22 June but was unaware of the controversy surrounding the YouTube star’ (Peterson, 2018). Together with the volatility inherent in brand engagement with celebrities and micro-celebrities, there are pressures and incentives for monetisation that pose risks for brands both at the situational level of interaction with specific influencers and at the broader level of reputation and trust for influencer practices and platforms. These include being associated with the promotion of fake merchandise, illegal products, or promotions that breach advertising rules and codes. Such reputational damage occurred when the infamous sham event, the Fyre Festival in 2017, was promoted almost exclusively through influencer marketing. Brands have turned to influencer marketing to reach aggregated audiences beyond declining mass media; eMarketer (Williamson, 2021) forecast that 68 per cent of US firms with 100-plus employees will use paid or unpaid brand partnerships in 2021. In the early phase, brands tended to focus on established celebrities but have since invested in fast-growing micro-celebrities. There has been a growth in spending on so-called micro-influencers, with closer and stronger relationships with their target audience in contrast to the macro-influencers, top YouTube stars with reach, but socio-culturally more remote. Brands have experimented with supporting nano-celebrities, recognising the qualities of trust and influence between influencers and audiences in the hundreds rather than millions. A commercial survey by Influenster (Bazilian, 2017) of 13,000 women in US found that 87 per cent saw branded content in a positive light; the company’s president Elizabeth Scherle declared, ‘[Consumers] prefer content featuring real people way more than celebrities, so align your content creation accordingly and keep it real’.

Influencer marketing actors and processes Platforms Google YouTube content creators are ranked by subscribers, with silver for 100,000+, gold for a million +, diamond for 10 million, and Custom Play Button awarded for 50 million. In 2019 there were more than 2,000 channels in the million+ subscriber bracket of top-tier influencers. The YouTube Partner programme (YPP) links content creators to brands and advertising payments through AdSense. This provides a route for display advertising, but such ad revenue tends to be modest for the majority of UCG creators. Profitability depends on advertisers’ willingness to pay and a host of factors, including popularity of video content and the location and value of viewers for the brand. In 2019 earnings as low as 0.32

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cents per 1,000 views were recorded, with the highest rate up to $5 dollars per 1,000 and the average around $1 (Zine, 2019) Research by Mathias Bartl found that those in the top 3 per cent of most-viewed YouTube channels could achieve income from advertising of $16,800. The remaining 97 per cent of people would not make enough money from advertising revenue to surpass the US poverty line. However, the study relied on estimated ad revenue and did not calculate the brand sponsorship and product placement revenue that enhance the revenues of popular YouTubers (Settembre, 2018). One YouTuber, Joey Gatto, with just under 200,000 subscribers, earned approximately $5,000 for a 30-second product plug, but estimated earnings of only around $100 from a video viewed by 100,000 people (Settembre, 2018). Advertising rates usually range between $0.10 to $0.30 per view, with an average of $0.18 per view, according to Influencer Marketing Hub (2019). The principal alternative to monetisation through display advertising is paid promotions and sponsorship: influencer marketing. Of course, YouTubers have diverse motivations and varying reliance on income from postings. Yet, the context for influencer marketing is the limited scope for digital advertising earnings for many. As Influencer Marketing Hub (2019) advises: In reality, only a small percentage of your viewers will click on the ads surrounding your videos. Even the CPM ads in the video itself require more than just a cursory glance. For it to be counted for payment, a viewer must watch them for at least 30 seconds (or half the ad for a very short video). Think how many people skip past the ad at the start of a video, thus wiping out any chance of payment to the channel. If viewers do click on or view your ads for long enough to earn income, you share any advertising revenue with YouTube. You will only get paid once your AdSense account reaches $100. Google (2020) defines paid product placements as ‘pieces of content that are created for a third party in exchange for compensation, or where that third party’s brand, message or product is integrated directly into the content’. In Google’s updated requirements, from September 2020, content creators must click a box stating, ‘My video contains paid promotion like a product placement, sponsorship or endorsement’ to notify YouTube, who will display a disclosure, remove the video (if on YouTube Kids), and ‘may replace an ad that conflicts with your brand partner with an alternative ad’. A 2018 survey by influencer platform Zine (Chadha, 2018) found that Facebook-owned Instagram was by far most popular platform for social media influencers, with a 78 per cent share. In contrast to the photographic images and micro-videos of Instagram, YouTube videos needed more time and resources to complete, Facebook’s news feed prioritised family and friends, while Pinterest was used more for pinning personal interests than following influencers. By 2019, Instagram had over a billion active monthly users. Amongst the pre-eminent platforms, influencer marketing on Instagram was expected to be a $2 billion market in 2019, according to influencer agency Mediakix. Instagram, like the other major platforms (YouTube and Twitter), ‘are developing ways to control

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the market that connects brands to their platforms’ power-users’ (Sloane, 2019). From 2014, Instagram introduced enhanced business tools offering brands data analytics to track their own and others’ brand communications. In March 2019, Instagram created a new format – ‘branded content ads’. Previously, ‘brands could hire popular Instagram users to work on ad campaigns and promote products with branded content, but the posts would only reach the followers of the influencer’; now branded content ads enable marketers to ‘promote these Instagram posts just like they would any other ad’ (Sloane, 2019).

Influencer marketing agencies The agencies rooted in advertising and public relations have vied for market share within the growing spending on influencer marketing, making this a key, contemporary space for conflict, convergence, and reorganisation within the industries. Influencer marketing has been associated with PR/communications and involves key features of ‘third-party’ endorsement in ‘editorial’ content that is not designated advertising, for purposes of extending reach and awareness. It encompasses ‘earned’ media, unpaid publicity, ‘genuine’ endorsement, and promotion. Yet, influencer marketing refers to planned and organised promotional activity that is usually the outcome of payment and contractual arrangements: paid communication. One industry survey found a clear shift in ownership: 38% of influencer marketing owners are on advertising/media teams, whereas only 15% are with PR/communications, a notable decrease from 31% last year. Media teams are taking ownership of influencer marketing as targeting capabilities evolve and budgets continue to increase, and are managing programs with the same rigor that they use to manage other digital advertising channels. (Linqia, 2018: 5) Specialist agencies have also developed. Talent agencies support influencers but also provide the intelligence and interface for clients, to match marketers and influencers. A huge industry has built up around managing celebrities’ and micro-celebrities’ media plans to bring in advertiser revenue, with agencies such as Izea, MyLikes, and Ad.ly managing paid endorsements. Influencer management companies include God & Beauty (Hotchkiss, 2019). StyleHaul was created as a multichannel network connecting brands with influencers for sponsored content, with a roster of famous influencers including Zoe Sugg (Zoella), Joey Graceffa, and Bubzbeauty (Bishop, 2019). Talent agencies include Gleam Futures (UK), whose CEO went from managing sisters Nic and Sam Chapman (known as Pixiwoo), their brother Jim Chapman, Jim’s then-girlfriend, Tanya Burr, and Zoe and Joe Sugg, amongst numerous others. Against the myths of egalitarian, creative access, such close, even nepotistic, networking creates exclusionary barriers, as does the selection of a shared look: ‘white, Bambi eyes’ (Bishop, 2019).

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Media publishers Publishers including Condé Nast, Group Nine, and Refinery29 have all created influencer marketing hubs (Barber, 2019). One of the more successful has been BuzzFeed, which can offer brands influencers as extensions of their own editorial staff and so provide greater brand safety, although as discussed in Chapter 4, some of its cultivated staff writers have moved to become entirely independent. Accompanying the growth and value of influencer marketing, there has been a proliferation of software tools to support the sector and make brand–influencer relationships simpler and more effective, or to reduce risk and improve brand safety. One such tool is The Eye, launched by StyleHaul in 2017, to monitor ‘real-time, creator-fueled social conversations about products’ (Bishop, 2019). The tool measures campaign success via post engagement and creator characteristics such as influencer age, ethnicity, and face shape. Such algorithms are susceptible to racial bias in their construction and training data, with The Eye’s categorisation software having an error rate up to 35 per cent for dark-skinned women, compared to 1 per cent for white men (Buolamwini, 2019; Bishop, 2019).

Influencer contractual arrangements According to one insider account (Lorenz, 2018): Negotiation usually takes place entirely over Instagram direct message, and teens rarely sign formal contracts. Some companies send an article of clothing for the teen to wear in a picture; others just send images of items to be worked into a post. Sometimes they offer guidance on how they’d like their product featured and when the post should go up, but most brands trust the teen to create and post something that will resonate with their peers. Helen Boogzel, CEO of Boogzel Apparel, describes a steady volume of requests from young teenage girls seeking to make extra money with companies paying around $5 to $20 dollars per post, depending on the teen’s audience and experience (Lorenz, 2018). Another seller of accessories describes working with teens on Instagram as ‘striking gold from an advertising standpoint’ and has shifted to paying around $20 dollars for those with fewer followers who ‘do it way better’ than the more established influencers charging $150 (Lorenz, 2018). Brands working with influencers need to comply with legal requirements and regulations on advertising and disclosure, discussed in Chapter 7. Marketer–influencer relations are also shaped by risk management, from the stipulation of contractual terms, to insurance cover for the various parties involved. One US lawyer (Mathes, 2018) advises marketers to specify the channels, number of posts required, details of content and specific deliverables, compliance requirements, and: 

Clarify what influencers will receive from your brand (free product to give away, links to guide consumers to a brand’s site, etc.).

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Specifics about how your brand can use, re-use, or modify content and the influencer’s name, photo, etc. Remedies if the influencer doesn’t follow through, does something that could get your brand in trouble, or gets arrested.

Brand authenticity and consumer response Influencer activity has thrived upon and cultivated visual tropes surrounding intimacy, spontaneity, unguardedness, and authenticity. In reality, major influencers operate closer to independent television production companies combined with the resources for media entertainment celebrities, whose ranks they join. ‘The most visible and successful influencers have management teams that include personal managers and assistants, literary agents, PR help – and the list goes on’ (Bishop, 2019). Overall, there is mass precarity amid a smaller number of proficiens, whose visibility and success distorts perceptions and drives more to join. Yet, the attractions of influencing are not only personal but socially and culturally configured. While dominated by those with class advantages, influencer communication has appeal for those whose routes to careers and advancement are restricted by barriers of class, race, and gender; and discrimination and structuring inequalities in societies and creative industries. Groups such as Black British Bloggers and Black Creatives: The Global Network for Multicultural Talent attest to the creative self-organisation and appeal of influencer communications, and the brand patronage that sustains it. Against the powerful economic and commercial drivers to extend brand reach, whether via native advertising or influencer marketing, are countervailing forces. How powerful and effective these are now is examined in Part II; but alongside regulatory controls are the more market-based controls of cultural acceptability. For influencer marketing, that may be measured by market reach and engagement, but the qualitative measures of how sections of followers respond to brand promotion will also be influential. The qualities of authenticity are in play as both a value and source of tension between influencers, agencies, and brands. Brands often seek authenticity as the quality underlying the connection between influencers and followers, yet much commentary from influencers highlights their self-declared efforts to safeguard their authenticity against pressure from agencies to work with brands or from brands directly.

Promotional diffusion and reflexivity Another of the issues affecting regulation is pertinent here. In general, regulation of marketing communications has sought to define and delimit its scope, separating paid advertising from ‘earned’ media or from ‘normal’ editorial content. Influencer marketing, most notably, involves the conduct of a regulated activity (paid advertising) by actors including non-professionals. The relative absence of the training, professional advice, legal guidance, and compliance found in the institutional organisation of legacy media has been part of the affordances of influencer marketing, exploited by brands, agencies, and influencers. Yet, influencer promotion

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also realises the circuits of promotional reflexivity that cultural analysts such as Wernick (1991) identified in an early phase of postmodernity. Influencers are engaged unavoidably in self-branding (Marwick, 2013), albeit in varying ways. In a branded world where lifestyles and identities are constructed by brand choices, influencers incorporate brand references as central or ancillary features. Branded goods serve in all varieties of prop or product placement positioning (whether paid or not). In regulated UK television (Chapter 3), broadcasters have to ensure that discussions of brands, including media and entertainment branded goods, are editorially justified. In influencer marketing, the dividing line between a microcelebrity showing the contents of their shopping haul as editorial or promotion are less clear and less rule-governed. Well-established YouTubers’ activities include the product unwrapping or the ‘haul’, a video posting showing and describing recently purchased items. In one month, Zoella featured five of these style videos, including ‘Best Friend Does My ASOS Shop’ (Westoby, 2018). Brands are inserted in (without control) as well as purposefully engaged in (from full to no control) these more complex promotional communications. Brands engage with the promotional activities of publisher–users on a sliding scale of professional/amateur status, levels of monetisation, and accompanying visibility and support within a commercial-promotional nexus. Social media provides a space for advertising and paid promotion by third parties, but also for consumer-generated content, including influencer content, that is not directed or controlled by brands and which may promote or counter brand communications, brand image, and ‘value’. The encountering by brands of a mix of controlled communications (advertising) and ‘uncontrolled’ editorial is a feature of legacy media. Certainly, the opportunities for opposition to brands to circulate online challenges brand power, as a host of crisis PR case studies attest, such as the 2012 video of a FedEx worker throwing a computer monitor over a fence. Yet influencer marketing is not merely a form of ad spending but an effort to shape the ordering of discursive space, to present an ordering that harnesses authenticity but is underpinned by payment and brand control.

Conclusion This chapter has examined native advertising and influencer marketing in two halves, yet it is their interrelationship and convergence that is most illustrative of developing trends. The platforms for influencer marketing are those seeking to attract and develop brand marketing and financing. One key area is the fashion– media–retail nexus (Rocamora, 2016). Snapchat expanded beyond its augmented reality filters to create Shoppable AR in 2018, which ‘allows advertisers to market and sell goods by using sponsored lenses, which come embedded with buttons/ links that direct users to a product page on a shopping portal, present an app install prompt and lets users watch videos without leaving the app’ (Sarwar, 2018). Shoppable ads combine ‘product photos with one-to-one targeting as well as sophisticated search capabilities within an ecommerce platform are turning clicks into veritable conversions’ (IAB [Interactive Advertising Bureau], 2019b: 5). This

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returns us to the main theme of advertising value creation, capture, and control. Described as a ‘direct brand economy’ (IAB [Interactive Advertising Bureau], 2019b: 4), platforms ‘continue to add features, making it easier for advertisers to target audiences ready to buy and convert searches into purchases’. Combining datafication with AI innovations, ‘publishers and advertisers alike are able to extrapolate lucrative insights across the complete consumer journey and create a unique opportunity for advertisers: ad targeting according to anticipated purchase intent’ (IAB 2019b: 4). An example is click-through purchasing within mobile native campaigns, and native integration with mobile loyalty cards, which help brands to track ROI in relation to consumer activity (swiping and other gesturebased functionality) and purchasing (Singer, 2019). Likewise, Verizon Media (2019) describes developments in ‘native’ advertising, including shoppable catalogues, AR showrooms, and interactive gaming previews. This chapter has discussed forms of brand communication from native advertising to influencer promotion. There is a common effort to ensure control over paid-for communications, but this varies by context and client–agency–creative relationships. Brands have learned to trust professional marketing agencies to get creative and media strategies right. They now navigate trusting these agencies and new intermediaries to manage the delicate configuration of harnessing influencer creativity and deep knowledge of their audience, with control over messaging and all aspects of brand safety.

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6 MEDIA AS MARKETERS

Convergence This is a story of convergence, the coming together of media and marketing communications. To understand and appreciate this, it is vital to identify, if not fully trace, the many ways in which those constituent elements – communications and promotion – have been combined historically across media, and the features and significance of their combination in the contemporary, digital age. There is the history of media as a vehicle for the promotion of goods and services, organisations, and individuals who are ‘external’ to the media organisation. That is the history of paid advertising. It is also the history of the media relations aspects of public relations, of ‘earned’ media and the complex matrix of transactions, exchanges, supply, and ‘information subsidies’ (Gandy, 1982), and the serving, and cultivation, of consumer interests shaping what and who is promoted. As well as promoting ‘external’ interests of advertisers, or sources, media can promote ‘internal’ interests and actors: owners, star ‘talent’, employees, and so on. These categories of internal and external interests get us some way but are too crude to capture the range of economic ties, contractual relations, mutual benefits, and mutual interests that characterise relations between ‘sources’ and ‘media’, especially in relation to the various aspects of media power: resource power, access (to communications), definitional power, and so on (Street, 2011; Freedman, 2014; Hardy, 2014). Those positioned across the internal/external border, depending on specific arrangements, include shareholders and investors, suppliers, and those in the value chain, from content creation to circulation and consumption. Media can serve and promote the special interests of owners, as centuries of press criticism attest (McChesney and Scott, 2004; Hardy, 2014). However, more neutrally, all media are vehicles of self-promotion (Wernick, 1991). Media promotion is integral and inseparable from media communication. The sign-carrying activity is at once communicative and self-referential. Then, more specifically, there are the elements DOI: 10.4324/9781315641065-7

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and methods used to promote content. In print or online publications, this includes the masthead and may include bylines identifying writers, with hyperlinks to crosspromote their profile and other work for the publication. The home page may include promotions for content carried on other pages, with extensive intra- and extra-publication promotion throughout, via text, graphics, and images. Similarly, content such as documentary or reality TV programmes on free-to-air commercial TV is usually structured to promote its own content, with visual and audio announcement, teaser content, and recapitulations all shaped by efforts to retain audiences when delivered on channels with advertising breaks. Mass media, at least from the period in which its ‘modern’, popular forms were established, is self-promotional across several levels, from individual content items to issues/editions. Broadcast promotion from the early 20th century included programme promotion and station/channel promotion, developing into programme strand, genre, and other (cross-) promotions to retain and guide users across scheduled content. Other well-established forms include the promotion of media brands held under common ownership, or ‘corporate level’ promotion. The cross-promotion by media companies of their media and other interests is longstanding, but intensified in the latter half of the 20th century as increasing conglomeration, market concentration, and corporate convergence combined with the competitive pressures and affordances of commercial media expansion (Hardy, 2010). Such intensification and professionalisation of television branding increased across PSM as well as commercial services (Johnson, 2012; Grainge and Johnson, 2015).

Overview: The rise of media promotion and cross-promotion When UK television began, so-called interludes were filled with sequences filmed from a static camera designed to provide a soothing pause between programmes, amongst them a potter’s wheel showing a never-completed pot being shaped (Meech, 1999). Television incorporated the promotional patterns of radio, with ‘announcers’ informing viewers of the next programme by voice over images. In 1953 the BBC had launched its first ident, a moving logo, (which became known as ‘the bat’s wings’). Previously the BBC had shown a ‘random selection of testcards in between the programmes’ but decided it needed a more consistent and exciting way to identify its new television service to viewers (Higham, 2013). When commercial public service television began in 1955, the new Independent Television (ITV) comprised four regional companies, all with their distinct corporate idents. Programme promotion became gradually more sophisticated as competition grew between the BBC and ITV services. With the launch of BBC 2 in 1964, the BBC began cross-media promotion, trailing and announcing the schedule of programmes on the other channel. Then, from 1982, the ITV companies were required by statutory law to cross-promote the new Channel Four service, by making programme announcements and carrying trails and promos. Martin Lambie-Nairn, creator of Channel Four’s animated logo in 1982, took charge of the BBC’s on-screen look in 1991, creating visual and auditory idents for BBC 2,

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including one featuring metallic and electronic sounds accompanying blue paint gushing horizontally across the screen to splash a metallic ‘2’. Another ident for BBC One showed organic unity, with images of hot air balloons depicting the globe floating over UK landscapes, and later cultural diversity, depicting different troupes of red-clad dancers performing a range of global dance styles. Into the 1980s, however, most programme promotion remained directed at forthcoming programmes on the same channel (known as ‘trails’) (Eastman et al., 2002: 5– 6). In the UK, television branding and promotion took off from the late 1980s, as the formerly highly regulated public service system underwent deregulation and marketisation. In addition, waves of new technologies, from cable TV to satellite to digital and online, ‘displaced broadcasting as the central experience of television’, while ‘the emergence of branding as a broader cultural strategy … extended well beyond consumer goods into areas of public life’ (Johnson, 2012: 6). Channel branding became more important and sophisticated with the rise of multichannel television services across cable and satellite platforms, notably Rupert Murdoch’s Sky Television from 1989, competing with the limited terrestrial offering. In the late 1990s digital satellite services, dominated by British Sky Broadcasting (BSkyB), competed with new digital terrestrial television services. Rupert Murdoch had a controlling interest in BSkyB and owned a dominant share of UK newspapers from The Times and Today to the topselling popular daily the Sun and Sunday market leader the News of the World. His newspapers heavily cross-promoted Sky TV services, together with extensive promotion across Sky channels (Hardy, 2010).

Promotion in the post-broadcasting era Branding ‘has emerged as a central concern of the television industry in the age of digital convergence’ (Caldwell, 2004: 305; 2008). The companies involved in television and television-like services have brand strategies throughout various levels, from corporate identity to suites of channels, individual channels, programme strands, and programmes (Johnson, 2012). TV channels themselves are constructed with brand identities conveyed through logos, slogans, and trailers. Branding has become ever more important for the industries involved in television and post-television, from linear services where content flows within channels to non-linear audiovisual content that is streamed or downloaded by users. Increasingly, programmes are conceived and constructed as brands designed to encourage audience loyalty and engagement beyond the act of television viewing. Arvidsson (2006) describes the development of new marketing practices across electronic media and in particular television, designed to communicate and establish shared values between producer, product, and consumer. An early pioneer, Viacom, branded MTV, launched in 1981, to build loyal relationships with viewers who were invited to identify with the values of the US network, with a blending of global tropes and localisation strategies as MTV expanded into Europe, Africa, and beyond. Such changes reflected broader shifts in marketing, from an emphasis on product and pricing to ‘carefully targeted emotional, therapeutic, and relationship branding strategies’ (Caldwell, 2008: 245). US multimedia conglomerates

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were among the first to extend their channel brands to the web and to shift to marketing programme brands as multimedia resources that could be cross-promoted, repurposed, and monetised across a variety of platforms and purchase points. Promotional communication ‘has emerged as a fundamental component of the converged digital media environment as media companies have been obliged to find new ways of reaching and engaging increasingly fragmented audiences’ (Johnson and Grainge, 2013). In their groundbreaking study of the promotional screen industries, predominantly in the UK and US, Grainge and Johnson (2015) identify the growth and interconnections between three sectors: screen advertising; film and television marketing; and corporate and organisational promotion. In screen advertising, multiple advertising forms and formats replaced the formerly dominant 15- and 30second spot ads, including the rise of search advertising and content marketing, amid shifts from ‘push’ marketing to ‘pull’ content, from interruption to engagement. US television channels multiplied, fragmenting audiences, such that by the mid-2000s the risks for marketers to move beyond 30-second TV ads was outweighed by risks of declining mass audiences (Lotz, 2007). Film and television marketing saw the growth of cross-platform, transmedia marketing with commercial content increasingly required to be ‘adaptable, malleable and able to be re-versioned as they travel across platforms (Grainge and Johnson, 2015: 33). Audiovisual marketing become more professionalised and sophisticated to meet the challenge of ‘content discovery’, helping people find information and entertainment through multiple distribution sites and platforms, and more shareable to respond to the participatory nature of digital media. The multiplication of forms of promotional content, from trailers to spin-offs, minisodes, and other paratexts has led to blurring between a ‘primary’ urtext (the filmed entertainment, documentary, and so on) and ‘secondary’, ancillary forms of media used to promote them. The third, converging, area of activity is corporate and organisational promotion. This is the domain of public relations material such as corporate videos, company showreels, recorded meetings and events, conferences, and product launches. It is also the space of brands’ owned media, as it has expanded from specific audiences, such as internal communications or B2B, to more widely distributed and promoted B2C material. As well as converging sectors of promotional practice, Grainge and Johnson (2015: 12) also highlight the mobility and integration of professional skills derived from marketing and content creation, the ‘[i]ntersection of client work and integration of skills between advertising and media agencies, film and television marketing companies, and digital media design agencies’.

Corporate integration – media and marketing convergence The expansion of promotional activities involves the core triad of actor-types: marketers, marketing agencies, and media companies, together with developing sectors of specialist firms providing creative and connective services. The latter includes a lead trade body, PROMAX, the global association for the entertainment marketing industry. This brings together Promax, established in 1956 as an association for

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promotion and marketing professionals working in broadcast media, with the Broadcast Designers’ Association (BDA). Promax (2020) ‘represents more than 10,000 companies and individuals at every major media organization, marketing agency, research company, strategic and creative vendor and technology provider’. In 2009, the then PROMAXBDA represented over 3,000 companies and individuals in over 70 countries, with a number of regional and country-wide branches, including PROMAX UK, established in 1989, now with over 700 members. There is significant integration between enterprises involved in media promotion, media content production, and branded content. An example is Somethin’ Else, which started life as an independent radio and television production company, then expanded into work for brand clients. In 2020, Somethin’ Else was the UK’s largest independent audio producer, creating factual and entertainment content for radio and podcasts. It describes itself as an ‘audience business and a content company. […] Our clients are brands and broadcasters and the audience themselves’ (Somethin’ Else, 2020a). The company’s activities include strategy, creative production, post-production, distribution, data analytics, and research. With television, radio, and social studios, Somethin’ Else describes its work as building audiences on behalf of clients, who are broadcasters and brands, as well as publishing its own content directly to consumers. It began in 1991, producing the DJ Giles Peterson Show for Independent Local Radio and grew to become a major multiplatform supplier for BBC shows. Its branded content work has been produced for Red Bull, Boots, Top Man, Rolls Royce, among many others. It produces podcasts and audio content for clients such as Audible, Penguin Random House (The Penguin Podcast), the BBC, and The Economist, and in 2018 launched its own original programming division, Sound Directions (Tan, 2018). From the 2000s there has been a proliferation of companies specialising in branded content production (Grainge and Johnson, 2015: 40). Many startups have been shortlived (Hampp, 2010), while others have moved from independence to acquisition, or joint-agreements, with major companies. Somethin’ Else entered into a joint agreement with Sony Music in 2020: ‘As a partner in podcasting, Sony Music will provide its expertise in content creation, marketing and monetisation to help enhance the scale and scope of Somethin’ Else’s work’ (Somethin’ Else, 2020b). The innovative agency Unruly, a pioneer since 2006 in branded content video production, neuromarketing research, and predicting shareability, was acquired by News Corporation for an estimated $90 million in 2015, and then sold to Israeli video adtech firm Tremor in 2020. Somethin’ Else is an example of a media production company that moved into branded content. Another, reverse route, has been advertising agencies moving into content production. From the 1980s, advertising agencies set up divisions for advertiser-funded programming (AFP) and other content production, but this expanded in the 2000s. In 2006, WPP-owned Ogilvy & Mather created Ogilvy Entertainment, specialising in advertiser-funded programming, notwithstanding the agency founder David Ogilvy’s pronouncement: ‘I do not regard advertising as entertainment or an art form, but as a medium of information. When I write an advertisement, I don’t want you to tell me that you find it “creative.” I want you to find it so interesting that you buy the product’ (Ogilvy, 1985: 1).

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In 2007, the new division created a 12-episode web series ‘In Search of Real Food’ on Yahoo for Unilever’s Hellmann’s mayonnaise, followed in 2008 by ‘Real Food Summer School with Bobby Flay’. In 2012, Ogilvy launched its Branded Entertainment Assessment ModelTM (‘BEAM’) at MIPTV, a: four-step process … rooted in established brand business ambitions and includes identifying a primary program objective, a lead content platform, determining the right mix of entertainment, exposure and brand integration, and finally, using a checklist of tactical considerations for maximizing the program across multiple, integrated channels. (PRNewswire, 2012) JWTE, the entertainment division of leading advertising agency JWT London, was created in January 2010. It was formed in the context of increasing investment in advertiser-financed television (for which JWT was an active promoter) and as part of a response to the threat from ad-avoidance technology such as TiVo and Sky+. It was also created in anticipation of the relaxation of UK product placement rules, which ‘enabled advertisers to exert more influence in the co-creation of multiplatform and off-air content’ (Grainge and Johnson, 2015: 40). It would be inaccurate to suggest a world of discrete media and advertising businesses that was subsequently transformed. As discussed (in Chapter 3), marketing agencies produced soap operas for radio in the 1920s. Corporate convergence across marketing and media activities is also longstanding. The expansion of transnational corporations from the 1970s led to multisectoral media conglomerates with marketing and media assets. It is valuable to trace, recover, and review the complex co-mingling of media and marketing in the historical record, which contemporary media-advertising convergence prompts. Yet, the specific conditions in which this convergence has occurred over the last two decades must also be analysed. The expansion and intensification of media and marketing integration in the 2000s does represent key shifts in corporate strategy and activity. Major conglomerates, their subsidiaries, and independent businesses took strategic decisions to establish, or purchase, units for activities that complemented and extended core business activity: adding media to marketing, or marketing to media.

Marketing agency transformations The increasing globalisation of communications and liberalisation of transnational corporate activity from the 1980s was the context for profound changes across marketers, media firms, and the advertising industry. Advertising agency businesses became highly globalised. For Sinclair (2015: 45), ‘The real crucible of the present era was the 1980s, when the UK-, France-, and Japan-based agencies rose to challenge US industry domination at a global level’. British advertising agencies bought up Madison Avenue agencies. This occurred in the wider context of increasing financialisation, providing the inflated asset values or debt leveraging that enabled such merger and

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acquisitions activity. The outcome was that the major holding companies, representing the top level of ownership and control, held portfolios of owned agencies operating within and across national and regional markets. This represented the creation of ‘a completely new stratospheric level of ownership and management … in the form of the global advertising group, or “mega-group”’ (Sinclair, 2015: 45). These integrated holding groups incorporated a diverse range of services to capture value and efficiencies across marketing. Sinclair (2015: 45) describes how these ‘complexly integrated holding groups’ incorporate creative advertising and media buying agencies as well as businesses in related ‘disciplines’, including public relations, market research, direct mail, and other marketing services; these ‘structures are a manifestation of how “integrated marketing communications” have eclipsed the mediacentric advertising of the past’. However, from the 2010s this edifice of holding companies experienced crisis and retrenchment. Disruption arising from the dominance of platforms as major beneficiaries of shifts in ad spending and from the reorganisation of marketers’ creation and placement of digital advertising led to reduced revenues for these debt-laden conglomerates and erosion of the level of control they once enjoyed (Sinclair, 2020). The major holding groups have not been slow to invest in adtech and programmatic advertising, but these are market activities increasingly controlled by the major platforms. The major holding agency groups are under pressure to deliver increased shareholder value in the context of falling revenues from the once highly lucrative television advertising spending. Most of all, marketers can bypass agencies, buying space directly from platforms, managing more of the processes in-house or with assistance from agencies other than the rapidly reformatting marketing agencies. Ad agencies are squeezed in the middle: ‘Because advertisers can now buy space directly from these and other digital platforms, advertising agencies now find themselves “disintermediated”: they are the middle men who are being cut out’ (Sinclair, 2020: 4). Economic and market conditions have also influenced brand marketers to rein in costs and to cut or scrutinise marketing budgets. While advertising spending recovered fairly quickly following the global financial crisis (GFC) of 2008, marketing agencies encountered increasing disciplining and constraint in spending: ‘To the extent that the GFC has made the large global advertisers more circumspect about their expenditure on advertising, the groups have had to accept the cost disciplines imposed upon them and to consolidate how they offer their services’ (Sinclair, 2020:12). For some of the largest advertisers, the pricing and distribution advantages enjoyed by large manufacturing brands have also been under increasing pressure from online selling and direct-to-consumer enterprises, causing the major brands to review costs and cost-effectiveness of advertising ever more closely (Sinclair, 2020: 8). As part of the corporate financialisation, a trend for ‘procurement’ had developed in which brand marketers assigned advertising media expenditure and even creative marketing services to their procurement departments rather than to their marketing departments, who traditionally liaised with external marketing agencies. In doing so, they ‘commoditised’ advertising

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and the agencies that produced it, but this also exposed to the glare of the accountants and other staff working in procurement the levels of agency fees and media expenditure agencies were charging their clients. Into this mix of structural trends and eroding trust between clients and agencies fell an incendiary exposé. Jon Mandel, former CEO of MediaCom, gave a speech to American advertisers in 2015 in which he denounced his own industry’s practice of demanding ‘kickbacks’ from media in exchange for the paid placements made with clients’ money, with some agencies buying up advertising space in bulk to sell on to clients at undisclosed profit margins. The agencies that clients trusted to work on their behalf were adding to their clients’ bills to increase their own revenues (Auletta, 2018). For a mixture of motives, including cost savings and control, marketers have set up their own creative agencies and media planning and buying units. Advertising agencies find themselves cut out and disintermediated (Sinclair, 2020). The US Association of National Advertisers (ANA) found that 78 per cent of its members had created an inhouse advertising facility (WARC, 2019) driven by shift to creation and placement of digital, especially programmatic, advertising. The major groups WPP, Publicis, and Omnicom faced declining rates of profit and shareholder value over 2017–20, with the exception of IPG who explained its relative success as derived from less reliance on fast-moving consumer goods. Holding groups also retrenched by selling off past acquisitions to pay down debt and consolidating assets. For instance, WPP sold its majority share in a major strategic asset, its marketer research division Kantar, in 2019, while a year earlier it merged full-service agency J. Walter Thompson, founded in the US in 1870 and acquired in 1987, with a key digital division, Wunderman. Similarly, WPP merged another iconic advertising brand, Young and Rubicon, with digital agency VML, acquired in 2001. Both mergers represented a ‘fusion of traditional advertising expertise with Internet-era specialism … presented to the groups’ clients as an integrated organisational platform’ (Sinclair, 2020: 7). Marketing agencies also faced the challenge of new competitors in the form of global management consultancies, who moved into advertising industry activities as they expanded the range of services they offered their client companies. The consultancies expanded their range of services from accounting, taxation, auditing, and related to data management in marketing and into programmatic advertising. Professional services company Accenture, for instance, launched a new digital marketing arm, Accenture Interactive, in 2009. The North American, European, and Japanese firms that dominated the global advertising industry in the 20th century (Springer, 2018) now face increasing competition from companies dominating regional markets and expanding internationally. The locus of this growth is Asia. Some of these firms, such as Dentsu in Japan, Wieden + Kennedy, and DDB China, are integrated with the global expansion of Western-based holding companies, but others, such as Tencent in China, represent alternative networks in the second-largest advertising market. There are also ongoing but intensifying reconfigurations across the more traditional demarcations of advertising agencies and public relations agencies. Within the former, the traditional demarcations between creative agencies/activities and media agencies/activities – between those creating ads and those placing ads – have

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led to various arrangements over the last half century, from moves towards integration and ‘full-service agencies’, to more distinctive separation and specialisation. The struggles, cooperation, and co-opetition between creative agencies, media agencies, PR agencies, and ‘new’ digital marketing agencies is also a key location for the birth and development of branded content. In addressing how and why branded content developed in the UK, Canter (2017) identifies media agencies as leading actors. The loss of ITV’s monopoly on TV advertising and the expansion and fragmentation of commercial TV led to ever more intensive trading and negotiation and a squeeze on commission. Branded content enabled ‘agencies to finds another revenue stream that actually had a much higher margin’. Media agencies began to operate and rebrand themselves as ‘content producers or content agencies’, and moved into the territory of creative advertising agencies: I know that a lot of creative ad agencies would think that media agencies were eating their lunch. Well, actually they have been (laughs), in a way because the ad agencies really hadn’t taken up this challenge and they probably still haven’t now. They are still behind the curve. (Canter, 2017) Digital agencies and PR agencies joined in branded content production, the latter ‘very well positioned to do this, but again they have been left a little bit behind the curve’, with the platforms later advancing into branded content and ‘trying to own the space as well’ (Canter, 2017). PR professionals expressed frustration that core skills of storytelling, and conversational and narrative skills that should enable them to lead content marketing, were not being fully recognised by clients, or advanced by PR agencies (Rogers, 2014). Canter’s explanation is partly institutional inertia (‘the PR industry grew up on relationships [interpersonal PR-journalist] and that is really where it got stuck’) but also that brand spending is focused on communications that can be controlled over earned media stories that are ‘editorial-led’. More recently, agencies specialising in branded content in social media have asserted their advantages over creative agencies rooted in television commercials (TVCs). Dylan Davenport, managing director of The Wild, a creative agency within Jungle Creations (owner of social media channels including VT and Twisted), states: ‘Adam&Eve [his former employer] and all the other big traditional agencies not so long ago started investing in content and social teams but the truth is, they’re always one step removed from what is going on in our space because the starting point is always what’s the big campaign TVC’ (McCarthy, 2020). Altogether, this is an account of trends and pressures but it would be misleading to infer that the advertising industry, and agency market share, has or is collapsing. Rather, the conditions of disruption and reconfiguration are important parts of the contexts in which branded content has developed. This includes the corporate ownership and control of advertising agencies and services. As with corporate ownership of major communications companies, there are evident trends of consolidation, concentration, and corporate convergence. Six major transnational ‘holding’ companies own a majority of global agency

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activity, having bought up agencies operating in national and regional markets. Transnational capital has bought up ‘national capital’. There have been counter-trends of deconvergence, influenced by changing financial and market conditions. The requirements of matching brands to users across emerging, often micro, media spaces create advantages for ‘local’ expertise for agencies and intermediaries. Finally, there are shifts in corporate, economic, and cultural power, as the second-largest advertising market, China, expands and as advancing economies influence new orderings of transnational corporate ownership from those of Western and Japanese corporate hegemony in the mid- to late 20th century (Sinclair, 2012; 2018; Springer, 2018). The changes in advertising and ad spending also need to be assessed carefully, especially when the emphasis in both industry and academic writing is on the novel and leading edge of emergent practices, including through common drives towards ‘thought leadership’ status, albeit for differently ordered goals and benefits. Television advertising still commands a major share of advertising spending because it still works. It brings vivid storytelling to large aggregate audiences in ways no other single medium or media vehicle can yet achieve. Outdoor advertising is routinely neglected yet also commands a significant share of advertising spending. The expansion of outdoor advertising though digital screens is an important aspect of branded content, but it needs to be understood in the context of the position and growth of ‘analogue’ outdoor billboards, posters, adshells, and ambient media.

Corporate integration: Brands and media Ultimately, marketing value is derived from the expenditure decisions of advertisers, dominated by major advertisers whose decisions structure provision across platforms, media, and marketing industries. According to the global ranking for 2018 by Adbrands (2020), top brand advertisers by spending, identified by rank order, include:           

FMCG manufacturers: Procter & Gamble (1), Unilever (4) Vehicle manufacturers: (12) Volkswagen, Toyota (15), Ford (17), General Motors (18), Fiat Chrysler (21) Consumer electronics firms: Samsung (2), Sony (26) Internet platforms and services: Amazon (5), Alphabet (9) Media and communications: Comcast (6), AT&T (10), Walt Disney (14) Food and drink: Nestlé (7), ABinBev (11), Coca-Cola (16), McDonald’s (19) Clothing/Luxury goods: LVMH (8), Nike (22), Adidas (23) Cosmetics: L’Oréal (3) Online travel: Booking Holdings (13), Expedia (24) Financial services: American Express (20) Retail: Walmart (25) By ranking, Netflix is 45, Baidu 74, and Apple 83.

The integration of brands with media in product placement, advertiser-financed programming, and branded entertainment has been discussed in Chapters 3 and 4. At

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corporate level, brand marketers have also formed joint agreements or acquisition arrangements with media entertainment companies, such as Hollywood film and TV production companies. The CEO of influencer marketing company Reelio (acquired by Fullscreen), Pete Borum (2016), describes such combinations as ‘a match made in heaven: You have studios strapped for cash, struggling to get their original movies made, and you have advertisers being squeezed out of their existing industry due to ad-free restrictions’. This section has outlined the adoption of content creation by brands (marketers) and marketing agencies, as well as the movement of firms involved in media production, and firms involved in media promotion, into branded content. As with other sectors of media convergence, however, such integration has also been a source of tension as different corporate cultures and purposes seek to join. Examples studied include the convergence of film hardware and software, such as the acquisition of Columbia Pictures by Sony corporation (Negus, 1997). The management of the inherently fractious relationship between brand clients and their commissioned marketing communication agencies is also a relevant and long-standing topic, with legendary tales of battles for creative control. With combined ownership or joint agreements, there was little reason to think such tensions would resolve and disappear. Simon Daglish, ITV group commercial director, speaking in 2014, said, ‘The thing about [branded] content is 90% of it is crap […]. Most people do not want a one-to-one relationship with a brand’ (Plunkett, 2014). ITV had experimented with advertiser-funded programmes (AFP) but Daglish argued it had not succeeded ‘because it interfered too much in the relationship between the broadcaster and viewer’ (Plunkett, 2014). Daglish warned: the game is producing great content and that is fabulously difficult […]. For a brand just to leap in and go, ‘Here I can do content now, here it is, isn’t it great?’ No, actually. You have to be really, really good at it. There’s a warning sign to numerous brands out there. For all the great successes we could name – Nike, Red Bull, a bit of Guinness – there are millions of examples of appallingly produced content by people who think they can do it. The professional expertise of television content creation is asserted, amid an appeal for brands to spend directly on television production talent and resources: ‘We have been doing it for 57 years … If you are a brand … talk to people who produce content. Britain’s Got Talent is 10 years old and we are getting it right, we are spending millions and millions of pounds on that product. It takes that sort of investment and knowledge to get the content right’. (Plunkett, 2014) However, AFP had significant limitations for brands, too, with huge investment required, high barriers for entry, and with brand presence and influence, but from a brand perspective lack of full control over content and distribution. Professional and regulatory governance maintained obligations for ITV to retain editorial

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control. Today, by contrast, the branded content opportunities of video ads/content in Video on Demand (VOD) enables full control, while content on digital platforms such as YouTube can be produced by brands alone or in partnership absent any such editorial governance arrangements, such as the YouTube dating show Does the Shoe Fit? developed in partnership with Foot Asylum.

Media-marketing mobility and convergence in labour The expansion of media promotion outlined at the start of this chapter has involved an increased workforce but also significant movements of skills, knowledge, values, and of companies, groups, and individuals across the domains of media and marketing. Of course, media-marketing has been a connective, shared space, but the movement of personnel with brand marketing experience into senior executive roles in media companies is another key phenomena. Likewise, marketing in general but branded content in particular has recruited talent from media production, journalism, and wider media and creative industries’ experience and specialisms. However, this is not a simple story of growth in volatile, fast-changing sectors where marketing, whether inhouse or external activity, is a comparatively soft cost compared to core production. Periodic expansion and job losses have characterised developments across both legacy and digital native media. The public service BBC, faced with a frozen licence fee settlement as part of government austerity measures, announced in October 2011 the loss of 2,000 jobs amid 20 per cent budget cuts, with losses at the 185-strong comms team expected to lead to fewer shows being promoted (Cartmell, 2011). A month earlier the BBC sacked three PR agencies who each worked on flagship drama, including Doctor Who, with the BBC Vision communications head, Sam Hodges, stating ‘The comms have been brought in-house as part of our dedication to securing greater efficiencies’ (Cartmell, 2011).

Media as marketers: Practices Film marketing Prometheus, Ridley Scott’s prequel to Alien, exemplifies the multimedia promotional strategies adopted for modern blockbusters, including viral videos, teasers, and elaborate additional stories and content for transmedia storytelling. A viral video showed a mock TED Talk by the founder of the Weyland Corporation (the corporation driving the plot in Prometheus and in the original Alien franchise). A social media campaign included elaborate Facebook pages based around the fictional corporation, another focused on the David 8 android, played by Michael Fassbender. In the UK, the film trailer first aired on Channel Four, during Homeland, on Sunday, 29 April 2012, and included a Twitter feed with the hashtag #areyouseeingthis. Some of those who visited the site and responded saw their tweets feature in the following ad break. The trailer was played simultaneously online, on Channel Four and on Zeebox, the powerful social TV app. According to one of the agencies involved, word-of-mouth consultancy 1000heads, the campaign reached

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15 million Twitter users, with more than 4,000 tweets posted about the film on that first night. A similar technique was used for the trailer for Planet of the Apes, shown on 9 July 2014 on ITV1 during a World Cup football semi-final match between Argentina and Holland. Viewers were invited to comment on the trailer with some selected Twitter comments then shown in the following ad breaks. Prometheus is an example of a synergistic entertainment franchise and strategy for ‘total entertainment’ (Grainge, 2008). It illustrates the integration of media and marketing through synergistic efforts to achieve visibility for media brands and maximise profits from transmedia super-narratives (Wolf, 1999). Whether such corporate promotion is viewed as enabling immersive pleasure or as strategies for exploitation, or a complex mixture of both, are important issues for analysis (Hardy, 2010; 2011). They illustrate aspects of the broader interlinking of media and marketing within the logics of multimedia production and promotion. However, such integration now involves, if not leads on, social media strategies. In 2015, Disney promoted The Force Awakens, across its vast media empire, and across the extensive product tie-in that provided brand-led promotions and ‘touch points’ around breakfast cereal (Honey Nut Cheerios) and make-up (Cover Girl) for shareable social media promotion, but also through influencers to reach its younger target audiences, including five who generated ten million views for their promotion of a BB-8 droid toy (Burgess, 2015). Talent agencies such as Digital Fox (2020) partner entertainment influencers with brands, working with Disney, cinemas, and retailers on Star Wars-themed promotions. Major film promotion still encompasses traditional promotional forms but has shifted towards social marketing campaigns and influencers, and with it content generated from corporate, paid promoters, prosumers, and users, combining media brands, brand partners, entertainment content, and related services. Multimedia content production, advertising finance, and promotion needs all drive a logic of ‘collaboration’ between content providers and marketers.

Media, marketing, and retail In her MacTaggart Speech at the Edinburgh Television Festival in 2012, Elizabeth Murdoch, chairman of independent television production company Shine, admonished the lack of commercial innovation by public service broadcasters: It is astounding just how little social media functionality or e-commerce partnerships feature on any of the PSBs’ players or websites. … If we don’t have the confidence to collaborate between producers and broadcasters, advertisers and second screen services – we are in danger of losing the battle when we could be winning. If we are still having debates about product placement, taking intractable positions over distribution windows or splits or back ends … then we are completely missing the point. (Campaign, 2012) She highlighted the similarly slow reaction of the US major networks to emergent YouTube channels in the US: ‘Machinima, Makers Studio and Big Frame stunt

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schedule, cross-promote, cross-sell and commission content – and they are now commanding audiences of up to 120 million subscribers across their channels’. She called for the whole production sector to follow the lead of All3Media and FremantleMedia in creating so-called direct-to-audience channels, and argued that new skills in audience development were required so that broadcasters deliver oneto-one relationships with their viewers. Second-screen marketing, linking viewing with advertising and selling via phone and tablet apps, has also generated considerable interest, although apps such as Zeebox (renamed Beamly) have not yet built the larger market forecast.

Media firms’ ‘branded content’ The production and circulation by media brands of promotional contents for self-promotion or cross-promotion is commonplace and unremarkable, yet stretches and bends the conceptual-institutional categories distinguishing ‘marketers’ and ‘media’. Of course, media are both. Media are brands, advertising vehicles for themselves, for their ‘contents’, vehicles for corporate-level promotion, and cross-promotion of closely connected, or loosely allied, content and services. Amongst the proliferation of promotional forms and ‘paratexts’, media brands are key agencies for the production of ‘branded content’. Some of this long pre-dates the current ‘digital’ era of branded content. Media companies have sponsored events and activities in arts and music, sports, education to engage audiences, create income streams, and offer corporate philanthropy and corporate social responsibility. Some cross-media forms have long histories, such as BBC books and magazines connected to radio and television services (Hardy, 2010). Most distinctive in the recent period has been audiovisual storytelling for media brands in short-form creative content. An illustrative example is i-D magazine’s A–Z of Music (2017), a collection of short video clips featuring a variety of music styles, stars including Cardi B and Roy Ayers, and video presentation and editing styles. Directed by filmmaker Sam de Jong and sponsored by Marc Jacobs, the video features the writing and musical composition of Dave Harrington, a multi-instrumentalist music producer, and one-half of Darkside. The piece stitches together 26 live performances into a collective composition, with each artist selecting a word as a personalised description for their musical style.

Conclusion This chapter, and Part I of the book, has sought to outline the key features of the convergence of media and marketing and the expansion of forms of branded content. We cannot fully identify this emerging space using old categories of media, marketing agencies, and media alone, but nor can or should we abandon those categories altogether. The arguments developed in Part II hinge on the importance of managing the relationship between marketing communications and media to safeguard the qualities of both. We do not need to abandon an analysis of complex intermingling and

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hybridity to do that, and in fact need to be guided by that analysis in order to advance suitable rules for the separation of media and advertising across 21st century media.

Bibliography Adbrands (2020) Top Global Advertisers Ranking for 2018. https://www.adbrands.net/top-globaladvertisers.htm. Arvidsson, A. (2006) Brands: Meaning and Value in Media Culture. New York: Routledge. Auletta, K. (2018) Frenemies. London: Harper Collins. Borum, P. (2016) ‘How branded entertainment can save advertising’, Chief Marketer, 21 June. http://www.chiefmarketer.com/how-branded-entertainment-can-save-advertising/. Burgess, E. (2015) ‘Star Wars: The Force is strong with social media and influencer marketing’, Influencer Orchestration Network. https://www.ion.co/star-wars-the-force-isstrong-with-social-media-and-influencer-marketing. Caldwell, J. (2004) ‘Branding’ in H. Newcomb (ed.) Encyclopaedia of Television: Vol 1, A-C, 2nd Edition. New York: Fitzroy Dearborn. Caldwell, J. (2008) Production Culture: Industrial Reflexivity and Critical Practice in Film and Television. Durham, NC: Duke University Press. Campaign (2012) ‘Elisabeth Murdoch’s full MacTaggart Speech’, 24 August. https://www. campaignlive.co.uk/article/elisabeth-murdochs-full-mactaggart-speech/1147079. Canter, A. (2017) Interview, 7 June. Cartmell, M. (2011) ‘BBC axe falls on the PR agencies of Doctor Who, Holby City and Casuality’, PR Week, 8 September. https://www.prweek.com/article/1089727/bbc-axe-falls-pr-agenciesdoctor-who-holby-city-casualty. Digital Fox (2020) ‘Star Wars influencers’. https://www.digitalfoxtalent.com/brands/star-wa rs-influencers/. Eastman, S., Ferguson, D., and Klein, R. (2002) Promotion and Marketing for Broadcasting, Cable and the Web. London: Focal Press. Freedman, D. (2014) The Contradictions of Media Power. London: Bloomsbury. Gandy, O. (1982) Beyond Agenda Setting: Information Subsidies and Public Policy. Norwood, NJ: Ablex. Grainge, P. (2008) Brand Hollywood: Selling Entertainment in a Global Media Age. London: Routledge. Grainge, P. and Johnson, C. (2015) Promotional Screen Industries. Abingdon: Routledge. Hampp, A. (2010) ‘How Madison & Vine moved to Silicon Valley’, Advertising Age, 15 March. https://adage.com/article/madisonvine-news/entertainment-madison-vine-moved-siliconvalley/142787. Hardy, J. (2010) Cross-Media Promotion. New York: Peter Lang. Hardy, J. (2011) ‘Mapping commercial intertextuality: HBO’s True Blood’, Convergence 17 (1): 7–17. Hardy, J. (2014) Critical Political Economy of the Media: An Introduction. Abingdon: Routledge. Higham, N. (2013) ‘60 years since ‘bat’s wings’ became first BBC TV symbol’, BBC News, 2 December. https://www.bbc.com/news/uk-25168633. IAB (2012) IAB Internet Advertising Revenue Report, 2011 Full Year Results, April. http:// www.iab.net/insights_research/industry_data_and_landscape/adrevenuereport. Johnson, C. (2012) Branding Television. London: Routledge. Johnson, C. and Grainge, P. (2013) Meccsa Conference abstract. Lotz, A. (2007) The Television Will Be Revolutionized. New York: New York University Press.

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McCarthy, J. (2020) ‘How publishers are getting around the branded content slump’, The Drum, 1 October. https://www.thedrum.com/news/2020/10/01/how-publishers-are-getting-aroundthe-branded-content-slump. McChesney, B. and Scott, B. (2004) Our Unfree Press. New York: The New Press. Meech, P. (1999) ‘Television clutter – the British experience’, Corporate Communications: An International Journal 4(1): 37–42. Negus, K. (1997) ‘The production of culture’ in P. Du Gay (ed.) Production of Culture/Cultures of Production. London: Sage. Ogilvy, D. (1985) Ogilvy on Advertising. New York: Vintage. Plunkett, J. (2014) ‘ITV commercial boss warns brands that 90% of content is “crap”’, The Guardian, 31 March. PRNewswire (2012) ‘Ogilvy creates planning and measurement model for branded entertainment’. Promax (2020) ‘About’. http://brief.promax.org/page/about. Rogers, D. (2014) ‘From the editor-in-chief: The death of PR agencies – as we know them’, PR Week, 9 July. https://www.prweek.com/article/1302688/editor-in-chief-death-pragencies-know. Sinclair, J. (2012) Advertising, the Media and Globalisation: A World in Motion. London and New York: Routledge. 2012 Sinclair, J. (2015) ‘Advertising, the media, and globalization’, Media Industries 1(3): 42–47. Sinclair, J. (2018) ‘Advertising across the BRICS’, in J. Hardy, H. Powell, and I. MacRury (eds) The Advertising Handbook, 4th Edition. Abingdon: Routledge. Sinclair, J. (2020) ‘Cracking under pressure: Current trends in the global advertising industry’, Media International Australia 174(1): 3–16. Somethin’ Else (2020a) ‘We are an audience business’. https://somethinelse.com/. Somethin’ Else (2020b) ‘Somethin’ Else and Sony Music join forces in podcast venture’, 4 February. https://somethinelse.com/news/somethin-else-and-sony-music-join-forces-in-podcast-venture/. Springer, P. (2018) ‘Advertising, agencies, and globalisation’, in J. Hardy, H. Powell, and I. MacRury (eds) The Advertising Handbook, 4th Edition. Abingdon: Routledge. Street, J. (2011) Mass Media, Politics and Democracy, 2nd Edition. London: Palgrave. Tan, E. (2018) ‘Somethin’ Else moves into original content production with podcast studio launch’, 7 June. https://www.campaignlive.co.uk/article/somethin-else-moves-originalcontent-production-podcast-studio-launch/1484237 (accessed 20 December 2020). WARC (2019) Global Advertising Trends Report. London: WARC. Wernick, A. (1991) Promotional Cultures. London: Sage. Wolf, M. (1999) The Entertainment Economy. London: Penguin Books.

PART II

Policies and problems

7 REGULATING CONVERGENT MEDIA AND MARKETING COMMUNICATIONS

In the 20th century, all Western media systems had rules requiring the separation of media and advertising in at least some media. This chapter discusses the main varieties of regulation in place and how these have changed over recent decades. The scope and limitations of existing laws and regulation of advertising and media are outlined, focusing on the US and Europe. How branded content is developing in different national and regional contexts is influenced by formal laws and regulations, corporate decision-making, civil society advocacy, and by the cultures and practices of media and marketing practitioners and users alike. This chapter outlines a framework for analysis of governance and proposes this as a way to advance the integrated study of media and marketing industries.

Overview Advertising has long been the major patron of commercial media. Yet various regulatory and market mechanisms set limits on that patronage. Regulations and industry norms upheld principles of separation of advertising and editorial. Market arrangements tended to work against advertisers exercising direct, instrumental power over editorial content. Marketers controlled adverts (paid media) but not the content around them. Public relations professionals pursued ‘earned’ media coverage that they could not fully control. The separation principle was generally upheld by self-regulatory codes across media and advertising industries, with stronger, statutory regulation in sectors such as European broadcasting. The shifts we are seeing certainly pre-date digitalisation, but increasingly marketers’ control is extending from advertising forms to integrated editorial forms. This involves a mix of instrumental and structural power by advertisers, but also complex attenuation, as decision-making spreads across digital advertising networks and into programmatic advertising buying and other forms of automation, such as the contentrecommendation engines used to place branded content onto publishers’ websites. DOI: 10.4324/9781315641065-9

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A key principle enshrined in international codes and in nationally imposed regulation is that advertising should be readily identifiable: ‘[m]arketing communications must be obviously identifiable as such’ (CAP, 2014; rule 2.1). Many countries have rules requiring a clear demarcation between marketers’ sponsored content and the media’s own editorial content. Yet, increasingly, advertising is ‘native’, blending commercial messaging so that sponsored content ‘is often indistinguishable from news, feature articles, product reviews, editorial, entertainment, and other regular content’ (FTC, 2015b: 2). The blurring of editorial and advertising is becoming a significant challenge for regulators. Branded content, native advertising, and other fast-evolving forms have intensified the challenges to the separation of editorial and advertising that were already being felt across the legacy media of print and television. This chapter addresses key questions arising: how is the blurring of media and marketing communications addressed across regulation and governance? Are the existing regulatory arrangements appropriate and effective? What are the challenges for regulatory arrangements?

Critical governance analysis My aim is to offer a theoretical, analytical, and empirical mapping of the contested governance of branded content, and in doing so advance a contemporary critical political economy approach. This section introduces an analytical framework developed over the following chapters. Governance refers to all processes of governing and rule wherever they occur (Bevir, 2012). For Rosenau (1992: 4f), ‘Governance […] is a more encompassing phenomenon than government. It embraces governmental institutions, but it also subsumes informal, non-governmental mechanisms […]. Governance is thus a system of rule that is as dependent on intersubjective meanings as on formally sanctioned constitutions and charters.’ One attraction of governance as a concept is that it encompasses the range of informal as well as formal processes by which practices are ordered and regulated. Such a mix of laws, regulatory agencies, industry and professional self-regulation, evolving standards, and looser ‘rulemaking’ is a general feature within contemporary, dynamic, adaptive (communication) systems. Governance analysis examines how practices and processes shape, and are shaped by, the distribution of resources and power. A criticism made of some governance studies is that they attend to specific operations of power without an adequate account of the macro-level influences of state–capital relationships. To remedy this, critical governance analysis draws on efforts to theorise and examine the interacting relations of power across macro-meso-micro levels, without reproducing a rigid deterministic account. Analysis, argues Benson (1977: 5), ‘must deal with the complex interlocking through which components are built into each other. This involves a search for dominant forces or components without resort to a deterministic argument.’ Benson’s (1977) dialectical network analysis has influenced more contemporary analyses by Jessop (2007), Davies (2011), and others, whose work demonstrates efforts to examine how practices are organised materially and discursively, and trace connections between

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the influences of political and economic forces on those practices. This critical tradition asks how power inequalities are sustained, and contested, and what social implications arise. Applied to branded content, that includes the task of examining power shifts between marketers, marketing agencies and intermediaries, media, platforms, and consumers. It also requires analysis of the broader influence of neoliberalism on the organisation and liberalising re-regulation of communications markets and on increasing ‘hypercommercialism’ (McChesney, 2013), marketisation, financialisation, and commodification affecting communication services and content (Berry, 2019). The discussion below illustrates some resources for critical governance analysis, including the influence of new institutionalism, and concepts of path dependency (Mahoney, 2000), and neo-Gramscian analysis of hegemony (Davies, 2011), to study processes of normalisation and contestation. In recent years, communication scholars have developed governance analysis, especially within media policy studies (Puppis, 2010), but also comparative media systems analysis (Ginosar, 2013). Freedman (2008: 14) defines media governance as ‘the sum total of mechanisms, both formal and informal, national and supranational, centralized and dispersed, that aim to organize media systems according to the resolution of media policy debates’. The concept has been most developed in media policy analysis to encompass the dynamic range of rule-shaping activities. This has occurred alongside renewed attention to the influence of communications processes within communications (and wider) policy-making. This includes the discursive production and ordering of power, drawing on discursive institutionalist approaches (Schmidt, 2008). Regulatory institutions have internal communicative processes through which norms and policy goals are developed, and they engage in external communications with policy stakeholders and wider publics as part of securing legitimation and support (Schmidt, 2008; Popiel, 2020). Hancher and Moran’s (1989: 271–99) work on ‘regulatory space’ examines the discursive and non-discursive space in which regulatory issues are identified, framed, and enunciated. The critical governance analysis proposed here follows these insightful approaches, but argues, inter alia, for an expansion beyond the policy domain to engage with wider discursive production within practitioner/professional and public-mediated communications, from industry trade media and general media coverage to social media exchanges. Lukes’ (2005) three dimensions of power as decision-making, non-decision making and ideological domination and acquiescence map the dimensions of governance as the ordering of decision-making power over actions (policies, production practices) on behalf of purposes and values (such as ‘market freedom’) and the interlinked ordering of discourses that advance, accept and contest such actions, purposes and values. The selection of issues to be addressed, including their discounting or removal (leading to ‘non decision-making’), are manifestations of ideological power as the capacity to shape decision-making agendas and to mobilise and advance particular sets of interests over others. Lukes’ (1974/2005) domination-based conception of power has been challenged and corrected by analyses of power as productive, pervasive, and multidimensional (Foucault, 1980). Drawing on these, critical scholars’ attention to the ordering and framing of policy issues in regulatory space has been advanced to show

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that while power is diffused in complex ways, ‘it is a capacity distributed unequally in society and … is characterized in the sphere of policy making not just by the ability to make decisions but also by the facility to prevent alternative ones from emerging’ (Freedman, 2010: 357–8; Popiel, 2020). This is not an open contest of ideas but a ‘space’ (whether at macro, meso, or micro levels of analysis) structured by power asymmetries that include, but invariably also exceed, the distribution of economic, political, social, and cultural power in the social formation. It is also a space that is always, but to varying degrees depending on the precise configuration, dynamic, unstable, complex, and contested. Governance analysis requires study of the organisation of practices and social arrangements, including power dynamics arising from ownership and control, commercial and other managerial pressures, employment status, and other factors affecting decision-making power, and their working out in the practices and perceptions of actors. This requires theories of the relationship, and synthesis, of structure and agency, such as Giddens’ structuration theory. Giddens (1984) proposes three kinds of structure action rules in social systems: signification, where meaning is coded in discourse; legitimation, the embedding of normative perspectives in norms and values; and domination, the way power is exercised, particularly over resources. While there are ongoing debates concerning the interaction of agentic and structural elements across Giddens’ structuration theory, Jessop’s (2007) strategic relational analysis, and others, these approaches can be complemented and enhanced by theories of the maintenance of professional domains and boundaries (Chapter 8). Governance analysis faces a further challenge of addressing the influence of automated processes on rule-shaping (Chapter 10). Now, automated decisions occur across all stages of marketing communications, including the buying, selling, assembling, and displaying of programmatic advertising. While it is essential to recover the human activity at all points, from highly-paid programmers to precarious, low-paid piece workers, the ramifications of datafication need to be addressed. In turn, these technosocial processes need to be reincorporated into critical analysis of how capitalist economic and social forces shape the social orders emerging through datafication (Couldry, 2020). Conceptually, governance is helpful in addressing the interacting range of formal and informal regulatory mechanisms, the proliferation and liquidity of actors, the significance of automation and AI, and modes and sites of contestation. Governance offers a means to integrate political economic, policy, and cultural analysis, by addressing connections across macro-meso-micro levels, including: state–capital–market relations; industrial organisation and arrangements; regulatory institutions and processes; socio-cultural practices; norms and attitudes across producers, users, and other actors; communicative action; and discursive interaction across all relevant stakeholders and media. Governance is analytically encompassing and can connect studies of policy and regulation with studies of the organisation and performance of media industry practices. We might approach this with a holistic awareness of the influence of all these elements in the dynamic ordering of multiple forms of power, even if we choose to focus on specific areas of interaction for more manageable research design. In his

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groundbreaking study, Serazio (2013), drawing on Foucault and Gramsci, examines the governance of the consumer subject in relations between marketers and communication users. This forms a vital part of the broader governance analysis I have outlined, which concerns the conditions for the production and circulation of marketing communications. However, even this broader scope is certainly not offered as a sufficient or total approach for analysis. Governance analysis inevitably privileges some features over others – so the aspiration to recognise, if never deliver, a fully holistic and comprehensive account means considering the links to other dimensions, and other disciplinary and cross-disciplinary approaches, such as cognitive psychology, that can further illuminate issues and phenomena.

Key sources of governance The task of mapping governance requires examining the range of actors and processes through which relations of power are produced, sustained, and contested. The main sources of governance are:    

Formal regulation (regulatory agencies directed by state or supranational law; independent regulatory agencies; co-regulation between public authorities and industries) Industry self-regulation (codes and standards; technology-assisted rule application) Market power (including consumer action) Civil society (including institutionally organised and loosely networked actors)

These sources are examined over the following chapters with an overall analysis and assessment offered in the concluding chapter. The focus for the remainder of this chapter is on the first two sources: formal regulation and industry self-regulation. There are three main types of advertising regulation: statutory regulation, derived from legislation; self-regulation by industry (with varying degrees of nonindustry oversight); and a blend of both (co-regulation). In most countries, advertising is regulated by a mixture of legislation and self-regulatory codes of practice (Ikonen et al. 2017). The following analysis includes international and comparative examples but focuses on the US and UK. This provides more integrated elements to pursue the critical governance analysis outline, which must always be contextspecific. Building the resources for better comparative analysis is a key aspiration for future work, to which I hope this book may contribute, and encourage.

United States At federal level, most laws governing advertising are administered by the Federal Trade Commission (FTC), established by the Federal Trade Commission Act of 1914, codified in 15 U.S.C. §§ 41–58. The FTC Act empowers the Commission to prevent ‘unfair or deceptive acts or practices’ (15 USC section 45) and unfair

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competition affecting interstate commerce, and to protect consumers, among other duties. A century on, there is a framework of federal and state laws affecting marketing communications and consumer protection, many of the latter modelled on the FTC Act. Regulatory agencies with authority over marketing in specific areas include the US Food and Drug Administration (FDA). Alongside this formal statutory regulation (regulation and regulatory agencies governed by statutes), there is an extensive range of self-regulatory bodies that administer codes of practice, many of which are adopted by or influential on industry bodies beyond the US. According to the OECD (2006: 34), ‘Self-regulation involves a group of economic agents, such as firms in a particular industry or a professional group. This group voluntarily develops rules or codes of conduct that regulate or guide the behaviour, actions and standards of its members.’ For clarity, industry self-regulation refers here to industry-governed professional bodies that set and apply their own voluntary rules and standards with no formal legislative or government responsibility for the scheme. These are included in the broad category of self-regulatory organisations (SROs), non-governmental bodies with powers to create and enforce industry and professional regulations, but the latter includes national regulatory agencies with delegated statutory powers, and organisations that are formally independent of the industries they regulate. The Advertising Self-Regulatory Council (ASRC) was the lead self-regulatory body for the US advertising industry until 2019, when it came under the National Advertising Division of the Better Business Bureaus National Programme (BBB NP). Formerly the National Advertising Review Council (NARC) until its name change in 2012, the ASRC was established in 1971 and brought together the American Advertising Federation (AAF), the American Association of Advertising Agencies (AAAA), the Association of National Advertisers (ANA), and the Council of Better Business Bureaus (CBBB). In 2009, the Direct Marketing Association (DMA), Electronic Retailing Association (ERA), and Interactive Advertising Bureau (IAB) joined. The BBB provides third-party oversight and examines code breaches, but the system is voluntary and their recommendations are not binding. The system is also weighed against complainants, with the burden of proof in false advertising litigation falling on the plaintiff, the person bringing the claim to court. Advertising self-regulatory agencies within BBB include the Children’s Advertising Review Unit (CARU), which applies the CARU Self-Regulatory Guidelines for Children’s Advertising. The Data and Marketing Association issues guidance, such as the Guidelines for Ethical Business Practice. Other bodies include the Mobile Marketing Association, the Brand Activation Association, and the Word of Mouth Marketing Association (WOMMA) (Kurnit and Taylor, 2019).

Federal Trade Commission native advertising and influencer regulations The FTC has identified native advertising as a priority area, and the period since 2013 has been one of increasing activity, although with questionable effectiveness. By 2013 nearly three quarters of online publishers in the US offered native

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advertising. A variety of US self-regulatory bodies, including ASRC, upheld principles of disclosure, but had not agreed consistent disclosure requirements. The FTC had existing rules, including its advice that it would be deceptive to publish advertising in the format of a news article unless ‘clearly and conspicuously’ disclosed (FTC, 1968). The American Society of Magazine Editors (ASME, 2015) advised its members that: magazines and advertisers that attempt to disguise advertising as editorial content risk action by the Federal Trade Commission as well as the National Advertising Division of the Advertising Self-Regulatory Council. The United States Postal Service may also fine publications that fail to label editorial-like advertising. In 2013 the FTC held a workshop, ‘Blurred Lines: Advertising or Content’, with invited practitioners from industry, academia, and regulatory agencies. This was followed by action in December 2015, when the FTC issued an Enforcement Policy Statement on Deceptively Formatted Advertising, and a Guide for Business, calling for clearer identification and disclosure (FTC, 2015b; 2015c). The new rules set out how the FTC intended to build on existing law and on its rulings and guidance. For instance, in 2012, the FTC had advised that it was potentially deceptive, a ‘misrepresentation or omission likely to mislead the consumer acting reasonably to the consumer’s detriment’ under Section 5 of the FTC Act, for an advertiser not to disclose that its content was not pure editorial content but was instead advertising (FTC, 2012; FTC, 1968). Yet, the new policy statement explicitly addressed native advertising and sponsored content and set out a framework to address these new formats that are ‘integrated in ways not previously available in traditional media’ and which ‘mask the signals consumers customarily have relied upon to recognize an advertising or promotional message’ (FTC, 2015b: 2). So the comparatively lightly regulated United States leapt ahead of standard-setting, providing detailed and advanced standards which have had global reach and influence. The guidance restates a core principle: ‘an ad shouldn’t convey that it’s anything other than an ad.’ There should be no ‘implied or express representation that [a native ad] comes from a party other than the sponsoring advertiser’ (FTC, 2015c). The FTC (2015b: 10) states that native advertising is deceptive when it misleads consumers about the ‘nature or source’ of the content, such that they do not realise that the content is supplied on behalf of an advertiser. The more similar a native advert is to the form and content on a publisher’s site, the more likely it is that a disclosure is required to ensure that deception is avoided. Disclosure notices may be required on both the publisher’s site and on linked pages where the content appears. The FTC reiterated existing requirements that disclosure must be clear and conspicuous and will be assessed on its performance, namely whether consumers noticed and understood the disclosure. Disclosure for paid content-based advertisements should be:  

In clear and unambiguous language As close as possible to the advertisement to which they relate

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The FTC advised that disclosure should appear close to where consumers would look first when encountering the content. While the FTC did not set out requirements for common usage and consistency in disclosure statements, it did issue guidance on acceptable and unacceptable terms. Frequently used terms like ‘promoted’ or ‘presented’ did not adequately convey that a sponsoring advertiser was involved in the creation of the content and so were unlikely to be acceptable. The FTC (2015c) declared that terms such as ‘promoted by’ and ‘sponsored by’ implied payment by a brand, but failed to communicate editorial control: ‘consumers reasonably may interpret [these] terms … to mean that a sponsoring advertiser funded or “underwrote” but did not create or influence the content’. Phrases that included the word ‘advertisement’ were preferable, it said, to counter any risk of misleading consumers. When an article that is not itself an ad is promoted by a company, it becomes an ad and must comply with the rules on advertising such as substantiation of claims. The new rules posed a set of tactical and operational challenge for industry groups seeking to maintain their self-presentation as responsible self-regulators while pushing back against ‘overly prescriptive’ rules. Industry engagement, including both levels of adherence to the rules and organised lobbying, is examined in the next chapter, but here the focus is on formal regulatory action and enforcement.

Enforcement action In the five years since the December 2015 guidelines, there have only been ten cases involving undisclosed commercial communications in third-party media. Of these few, the first FTC action against an inadequately disclosed native advertising article came in the first year of the new rules. The FTC (2016b; Campbell and Grimm, 2019: 114) ruled that fashion retailer Lord & Taylor failed to disclose that it paid for an article in Nylon magazine, or that 50 online influencers had been paid to post photos of a dress. The FTC alleged that Lord & Taylor gave each influencer a free paisley dress and paid them between $1,000 and $4,000 each to post a photo of themselves wearing it on Instagram or another social media site. Under the contractual arrangements, Lord & Taylor pre-approved each proposed post, and the influencers were obliged by contract to tag ‘@lordandtaylor’ as part of the posts and to use the hashtag #DesignLab in the caption of the photos. The influencers’ posts reached 11.4 million individual Instagram users over two days, leading to 328,000 brand engagements with Lord &Taylor’s own Instagram handle. The FTC ruled that Lord & Taylor had failed to require the influencers to disclose that they received the dresses for free or were paid by Lord & Taylor for their posts. The company was given a consent order and agreed a financial settlement and future monitoring arrangement with the FTC. In 1972, the FTC invited public comment on draft guidelines, which were subsequently developed and consolidated in 1980 as Guides Concerning Use of Endorsements and Testimonials in Advertising (16 CFR section 255 et seq.). The FTC Guides cover the use of consumer, celebrity, expert, and organisational endorsements in advertising. Endorsements must be truthful, non-deceptive, and capable of being substantiated by the advertiser. ‘Any connection between the endorser and the advertiser that might

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materially affect the weight or credibility of the endorsement (in other words, a relationship not reasonably expected by the audience) should be disclosed (16 CFR section 255.5)’ (Kurnit and Taylor, 2019; FTC, 2015b: 9). In 2015, the FTC (2015a) brought enforcement action against Sony’s advertising campaign for PlayStation Vita after the FTC alleged the advertising agency working with Sony, Deutsch LA, paid employees to tweet about the gaming console’s features without disclosing their connection to the brand. The FTC took action against gaming website Machinima, concluding the company had used deceptive advertising by paying influencers to post YouTube videos endorsing Microsoft’s Xbox One system and several games (FTC, 2016a). The influencers paid by Machinima failed to adequately disclose that they were being paid for their seemingly objective opinions. The first case taken against individual social media influencers, settled in 2017, concerned Trevor ‘TmarTn’ Martin and Thomas ‘Syndicate’ Cassell, who deceptively promoted CSGO Lotto without disclosing their ownership interests in the company, and paid other influencers to promote CSGO Lotto without sponsorship disclosures (FTC, 2017). In April 2017, the FTC sent warning letters to 90 US influencers and marketers reminding them that they should clearly disclose any relationships to brands when promoting or endorsing products in social media. Follow-up warnings were sent in September 2017 to 21 of those originally contacted. The FTC re-affirmed its requirements that influencers ‘disclose anything “material” that is not obvious to the reader … and disclosures must be included in all media, including Twitter’ (Mathes, 2018). The FTC (2017) advised that ‘many consumers will not understand a disclosure like “#sp,” “Thanks [Brand],” or “#partner” in an Instagram post to mean that the post is sponsored’. Altogether, there have only been 51 FTC cases and proceedings (in 2016–20) concerning endorsements, influencers, and reviews. Of these, over half (31) concerned misleading or deceptive marketing claims, of which seven included fake or misleading testimonials, made in designated advertising or self-published media (FTC, 2021). Six concerned restrictions placed on consumer reviews, one failure to disclose paid customer reviews, one robocall, one undisclosed affiliate marketing, and one paid placement ranking. Of the remaining ten, seven involved undisclosed promotion by contracted influencers whose material connection through payment required disclosure, as did promotion by those with a material connection to the company or product promoted, as in the CSGO Lotto case. In two other linked cases (Inside Publishing and Creaxion), paid endorsements for a mosquito repellent promoted during the 2016 Zika outbreak by influencers, including top athletes paid several thousand dollars, were not disclosed and Inside Publishing’s Inside Gymnastics carried ads presented as independent journalistic content. Ads presented as radio news stories and infomercials as talk shows occurred in two cases, with the tenth case involving a publisher, Victory Media, charging schools to feature in listings and presenting paid commercial advertising as editorial content. Of the cases involving undisclosed commercial communications, one involved a major marketer (Microsoft) and one major media, involving the final stage of proceedings for a case in which Warner Brothers failed to disclose payment to online influencers, including PewDiePie, to promote its

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video game, Middle Earth: Shadow of Mordor, released in 2014. So, enforcement action against undisclosed commercial communications in third-party media has occurred in a bare handful of instances since the 2015 policy statement. The lack of enforcement action has undermined the promise of the native advertising rules. A more fundamental problem is that the FTC is concerned to address the potential damage arising from consumer deception, but not with the impact of sponsored content on the quality and integrity of communication services. Once the requirement of consumer recognition of native ads is passed there is little left in the prevailing regulatory arsenal to act against the impact of branded content on media channels themselves, and hence on the quality of our communications services.

European Union Within the European Union there are competition, consumer, communications, and data laws governing branded content, much in the form of directives incorporated into member states’ domestic law. Under EU law, you have the right to be informed if a newspaper article, TV programme, or radio broadcast has been ‘sponsored’ by a company as a way to advertise its products. This must be made clear by images, words, or sounds. The Audiovisual Media Services Directive (AVMSD) 2010, revised in 2018, requires that audiovisual commercial communications are readily recognisable, and extends product placement rules to video sharing platforms, especially to address Netflix, Amazon, Apple, and other US-based providers taking an increasing share of European audiences. There has been a European Parliament-led political effort to level up standards for video sharing, while supporting Commission-led efforts to relax rules for European TV companies in respect of the amount of advertising, sponsorship, and product placement. For published branded content, the most important regulation is the Unfair Commercial Practices Directive (UCPD) 2005, which states that if a trader has paid for promotion in editorial content, that must be made clear to consumers. The Directive (European Parliament and Council, 2005, Directive 2005/29/EC, Annex 1, Item 11) prohibits: ‘Using editorial content in the media to promote a product where a trader has paid for the promotion without making that clear in the content or by images or sounds clearly identifiable by the consumer (advertorial)’. In addition, the prohibition on hidden marketing is reaffirmed in Article 7(2) and point 22 of Annex I to the Directive. In a European Parliamentary answer (European Parliament, 2016), the European Commission also stated that a: high level of consumer protection in this area is also ensured by Article 6(a) of Directive 2000/31/EC\l ‘def2’ (2) and Article 9(1)(a) of [AVMSD] Directive 2010/13/EU\l ‘def3’ (3), which require commercial communications to be clearly identifiable as such, in information society services and audiovisual media services respectively. Responding to a query about the adequacy of the 2005 advertorial rule to address influencer advertising disguised as editorial, the Commission highlighted its ongoing

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review of consumer and marketing law, but added that ‘[c]urrently, the Commission is not aware of evidence suggesting that the rules on advertorials under Directive 2005/ 29/EC should be revised’ (European Parliament, 2016). The 2005 Directive was subsequently amended by the Directive (EU) 2019/2161 (European Parliament and Council, 2019), designed to address ‘the better enforcement and modernisation of Union consumer protection rules’. This addressed payment for search results listing, prohibition of fake consumer reviews, and endorsements by traders, but did not amend the rules on advertorial. The Unfair Commercial Practices Directive is valuable, but limited and outdated. It applies when the content is obviously promotional, but is not sufficient to cover all forms of brands involvement in editorial; for instance, paid or sponsored content by brands may not promote the brand; it may not even mention the brand at all. So, this raises a key question: should the involvement of a brand in publisher-hosted content be declared in all circumstances?

United Kingdom The UK regulatory system continues to exert a strong influence on European and other systems. While its particularities are of more local interest and will only be outlined here, it also illustrates wider issues in governance, including problems of definition, demarcation, and lack of regulatory convergence. There are a range of regulatory agencies, including statutory agencies, Ofcom, and the Competition and Markets Authority (CMA), and self-regulatory agencies, notably the Advertising Standards Authority (ASA), and industry professional bodies. There is a legacy of separate regulation, and demarcation, of advertising, public relations, and editorial that has been ill-equipped for rapid convergence across marketing communications and publishing. Although this is changing, regulatory arrangements still lag far behind industry practices. The Competition and Markets Authority is the UK regulator responsible for consumer protection regulation. The main regulations relevant to branded content are the Consumer Protection from Unfair Trading Regulations 2008 (known as CPRs), which incorporate into UK law the EC Unfair Commercial Practices Directive (2005). The UK has been a European Union member state for 47 years until Brexit was completed on 31 December 2020, so European Directives, including the amended AVMDS 2018, have been incorporated into domestic law. The 2005 Directive is a maximum harmonisation instrument, meaning that member states are not permitted to adopt stronger measures for consumer protection (Pflücke, 2020). From 2021 the UK government will be able to introduce divergent legislation. Schedule 1 of the CPRs contains a list of practices which are always unfair and includes the requirement to disclose payment and differentiate editorial and ‘advertorial’ as set out in the UCPD.

Branded content in UK (self-)regulation In the United Kingdom, growing criticism of advertising methods led to several Acts of Parliament in the 1950s imposing controls on such issues as poster sites and aerial

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advertising. Pressure grew when, from its inception, commercial TV advertising was subject to regulation by the Independent Television Authority, established by the Television Act 1954. A short advertising code, barely a page, was created, which has expanded in length ever since. The new statutory regulation for TV advertising increased the pressure for stronger oversight of non-broadcast advertising. In 1959, the Labour Party established an Advertising Enquiry Committee to investigate ‘socially harmful ads’, and supported recommendations for a statutory National Consumer Board (Brierley, 2002: 215). Responding to mounting criticism, the Advertising Association launched the British Code of Advertising Practice in 1961, drawing on both its existing codes, such as those for medicines and treatments drawn up in 1948, and the International Chamber of Commerce (ICC) Code. In 1962, the Advertising Standards Authority (ASA) was created to administer the Code. This new ‘watchdog’ of the self-regulatory system saw off the immediate threat of government legislation. The Committee of Advertising Practice (CAP) is the industry body responsible for writing the advertising codes that the ASA applies. The CAP Code sets out a key principle of advertising regulation: ‘[m]arketing communications must be obviously identifiable as such’ (CAP, 2014; rule 2.1). Both the CAP and ASA have issued guidance on advertorials, native advertising, and other forms of branded content, social media marketing, and influencers. In fact, they have done so, revising and reissuing guidance, with increasing frequency since 2015 and in the context of increased regulatory activism domestically by the CMA, and internationally, including by the European Advertising Standards Alliance (EASA), which the ASA co-founded in 1991. The ASA has been active in adjudicating on breaches of identification and disclosure, for instance ruling that the labelling ‘in association with Michelin’ on an online advertorial for Michelin tyres was ‘insufficient to identify the content specifically as an ad’ (ASA, 2015). A year later, the ASA (2016a) found BuzzFeed and Henkel in breach for a paid native advertising listicle for Dylon entitled ‘14 Laundry Fails We’ve Experienced’, ruling there was insufficient identification that this was marketer-controlled content when accessed via a social media feed. This was significant, as BuzzFeed’s VP agency strategy, Perelman, had told an audience in 2013 that ‘70% of our traffic comes in via social’ (Caines, 2013).

Problems and limitations The separation of editorial and advertising matter has been a long-standing issue; the ASA (2019b: 4) notes that ‘[a]s far back as 1964, the ASA’s annual report stated, “A reader has a right to know whether he is reading independent editorial opinion, or a news item, or advertising matter. For advertisements to appear as either editorial or news matter is clearly misleading”.’ In its report on influencer marketing, the ASA (2019a: 4) affirms, ‘[d]rawing a clear line between advertising and editorial content is as important today as it was then, but now the explosion of online marketing channels raises significant new challenges’. However, the ASA/CAP advertising self-regulatory system has always asserted that its non-broadcast rules apply to marketing communications but not editorial content, news, or public relations material in ‘earned’ media, justified on the grounds of non-interference

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with freedom of expression and editorial freedom. This approach was tested as complaints grew about communications on marketers’ websites (‘owned’ media) which fell outside the Code. From March 2011, the ASA’s digital remit was extended to include marketing communications in marketers’ owned media, covering for the first time claims directly connected with the supply or transfer of goods or services appearing in non-paid-for space on a company’s own website. However, the Code does not apply to much that is commonly regarded as ‘content marketing’ in which no such claims are made. In addition, the CAP Code does not apply to PR-sourced material that is deemed to be editorial matter. The Code allows payment to a publication to cover stories, without requiring disclosure to readers, provided the editorial content is not ‘controlled’ by the brand. CAP (2017: 4) guidance states: For example, a company might provide information to a journalist that is then used as the basis for an article, or a publication might ask for a fee to reproduce a photograph or cover a story, but neither scenario would necessarily make the resulting article an advertorial within the remit of the CAP Code. CAP (2017: 4) gives the example of a travel journalist provided an all-expenses-paid holiday by a travel company in the hope of a favourable review and states that ‘the resulting article would not be considered an advertisement feature if the company had not agreed its content’. It would be subject to the Code only if the company had copy approval. Covering a brand-sponsored event where ‘journalists decide to write about it of their own accord’ is editorial and outside the Code. Further, CAP (2016; 2017) states that ‘contextually targeted branded content … isn’t a problem in and of itself, but marketers must be cautious that in seeking to make ads more inviting they do not camouflage advertisements’. The CAP warns against any labelling that disguises advertising or is otherwise unclear to consumers. So, terms like ‘sponsored by’ and ‘brought to you by’ are not permitted where the relevant content is controlled by brands. However, there is a significant gap in enforcement. The CAP’s (2017) rules allow brands to pay for content without that being disclosed to readers, based on the distinction between brand control (marketing) and publisher control (editorial). Undisclosed payment for ‘advertorial’/brand-sponsored editorial is not permitted under the CMA’s consumer protection regulations. Yet the CMA does not pursue individual enforcement action but rather investigates activities sector-wide, while working with local trading standards enforcement. For the ASA, as the self-regulatory agency that does take action over CAP Code breaches, the approach taken is significantly different. The ASA applies a dual test of whether the brand pays and exercises content control. As the IAB UK (2018) advises its members: Editorial content that a brand has paid to be associated with but over which the publisher has full editorial control does not fall within the remit of the CAP Code or this guidance. This content may, however, be subject to other legislation, regulatory codes or industry codes.

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Content supplied or paid for by brands can be published without identification to notify readers, or ASA oversight, where no ‘control’ over editorial is exercised by marketers. This lacks sufficient transparency and provides a means whereby if publishers and advertisers have an interest not to disclose sponsored content, they can rest upon a claim of the publisher retaining editorial control that is difficult for regulators, much less readers, to assess. Further, the ASA rules apply to paid advertising but not public relations, and so do not cover so-called ‘organic’ mentions in ‘earned’ rather than ‘paid’ content. Yet that division is becoming increasingly blurred as reciprocal deals, bartering, and other transactional arrangements abound across digital publishing and influencer marketing. The regulatory divisions between advertising, editorial, and public relations have been established in the discursive, regulatory, and institutional organisation of UK communications governance. These are proving to be insufficient to address converging media and marketing. Understanding why such regulatory inertia persists requires analysis of the forces and interests shaping governance arrangements, examined in the following chapters.

Influencer marketing regulation Increasingly brands seek endorsements from influencers who can reach desired audiences in far greater numbers than traditional media across their YouTube, Instagram, Snapchat, and other social media channels. These pose challenges to existing regulations and to regulators. In August 2016, the ASA introduced new guidance for vloggers’ brand endorsements to make clear when content is, in fact, advertising (ASA, 2016: 12). This followed several rulings, including that a paid promotion for Oreo biscuits by YouTube vloggers, including Phil Lester and Dan Howell, failed to clearly identify the content as advertising (ASA, 2014; Pflücke, 2020: 306–7). The ASA upheld a complaint concerning a video post on Millie Mackintosh’s Instagram account on the basis that the message, ‘“More of my #BlendRecommends with @drinkj2o Spritz to come! #sp” did not sufficiently indicate the post was an ad as opposed to a sponsored post with the creator retaining editorial control’ (CAP, 2016). On apps like Instagram, where images may appear before texts, the CAP recommends that hashtags such as #ad are used so that the nature of the content is clear to followers. The UK’s Competition and Markets Authority (CMA) has also carried out investigations under its consumer enforcement powers and warned marketers and publishers ‘that helping to arrange or publish advertising or other marketing that is not clearly distinguishable from the opinion of a journalist or blogger may result in them breaking the law’ (CMA, 2016). From 2015, the CMA became increasingly active in addressing influencer marketing, in turn forcing the pace and rigour of the ASA’s response. The CMA issued a call for information on online reviews and endorsements in February 2015 following concern over misleading practices, including ‘businesses paying for endorsements in blogs and other online articles without this being made clear to consumers’ (CMA, 2015). Following its investigation into online reviews and endorsements, the CMA published guidance for marketers setting out the existing legal requirements and began to take enforcement action against undisclosed paid endorsements on social media.

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In March 2016, the CMA took enforcement action against a marketing firm responsible for writing over 800 fake positive reviews for small businesses published across 26 different websites. Then in April, the CMA (2016) wrote to 13 marketing companies, 20 businesses, and 33 publishers of online articles and blogs to ‘warn them that helping to arrange or publish advertising or other marketing that is not clearly distinguishable from the opinion of a journalist or blogger may result in them breaking the law’. The CMA (2016) guidance letter stated that: Online publishers and bloggers should make sure that, if they are paid (whether financially or otherwise) to feature products in the content on their sites, then the paid promotions are clearly labelled or identifiable as paid-for content. This is more than just a question of good practice: consumer protection law does not allow for the use of editorial content in the media to promote a product where a trader has been paid for the promotion, unless this has been made clear to the consumer. The CMA (2016) guidance advised, ‘If someone who publishes content accepts payment to endorse something, they need to make sure that the content is clearly identifiable as being paid-for. For example, they could label posts or videos as “advertisement feature” or “advertisement promotion”.’ In 2018 the CMA launched a further ‘investigation into concerns that social media stars were not properly declaring when they have been paid, or otherwise rewarded, to endorse goods or services’ (CMA, 2018). Announcing the review, the CMA (2018) said it had seen examples of posts which appear to:  

promote or endorse products without clearly stating if the post has been paid for offer the celebrity’s personal opinion on the benefit of a product without clearly disclosing if they are being paid by the brand

However, the CMA has no set requirements for labelling; ‘Each social media platform is different and constantly changing, and individual influencers have diverse creative styles’ (Goodship, 2019). Disclosure must be ‘clear, prominent and upfront’, ‘viewers or followers must see and immediately understand the disclosure before they start to view or read [an IM] post. This applies regardless of the platform you post on or the device that your viewers or followers may use’ (Goodship, 2019). In 2017 the ASA castigated Instagram for failing to label paid-for content (Stewart, 2017). According to Instagram’s own guidelines, when a blogger is paid to promote a product, the post must be clearly identified as being an advertisement by using the hashtag #ad. The ASA banned an Instagram post from make-up blogger Sheikhbeauty. The blogger shared an image promoting herbal brand Flat Tummy Tea with her 350,000 followers without making it clear it was an ad. The sponsored post, on 7 December 2016, advertised a 20 per cent discounted promotion the tea brand was running; showing a selection of the brand’s products with prominent logos, the blogger’s tag read: ‘@flattummytea 20% off guys! If you’ve been following me you’ll

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know I used this and I genuinely feel less bloated and a flatter tummy … oh yessss’. The ASA investigated, following one complaint, and upheld the complaint that the ad was not adequately identified (ASA, 2017). Flat Tummy Tea’s parent company Nomad Choice submitted correspondence between Sheikhbeauty and their agent, which stated that she must post in accordance with all applicable laws and guidelines. After it was flagged, the company also edited the post to include #ad. However, the ASA ‘concluded that since Flat Tummy Tea and Sheikhbeauty had entered into a financial agreement, the marketing fell within the remit of the CAP Code, which the post failed to comply with since it was not obviously identifiable as a marketing communication’ (Goodfellow, 2017). In a 2019 ruling (ASA, 2019a), the ASA upheld one complaint that a post by TV personality Olivia Buckland was not obviously identifiable as a marketing communication. The visible caption on the post stated, ‘The V-Day prep is well underway and I’m topping up my tan with my fave @cocoabrowntan by @marissacarter 1 HOUR TAN MOUSSE … more’. Once the caption was clicked, additional text stated ‘Original – it gives me such a natural glow with no streaks and is the perfect accessory for date night with bae [heart eye emoji]. Get yours now @superdrug #TeamCB #CocoaBrownTan #ValentinesDay #BrandAmbassador.’ Buckland defended her use of ‘brand ambassador’ as sufficient clarification, but the ASA ‘considered that it was unlikely to convey that Cocoa Brown had both paid for and had a level of control over the content of the post’. The ASA also found that the post, appearing in-feed, included no identification, ‘such as “#ad” placed upfront, that made clear to those viewing it that it was an ad’ (ASA, 2019a). The ASA’s report, Labelling of Influencer Advertising (2019b) concluded, ‘Our findings dispel any argument that labels aren’t needed, and re-emphasise the importance of influencers being upfront and clear with their followers about when they are advertising’. In the first ruling concerning TikTok, a post containing a video of Emily Canham using a GHDbranded hairdryer and straighteners, was found to have been unlabelled as an advertisement. The company who contracted with the influencer argued, as others have done, that the post fell outside of a contractual agreement; however, the ASA ruled the promotion was linked to the agreement and that the commercial nature of the communication should have been made clear (ASA, 2020).

National and regional influencer marketing regulations Various efforts have been made at national and supranational levels to formulate guidelines for influencer marketing (IM). The ICC Code (2018: 10), which is at the basis of most national advertising codes, states that marketing communications: should be clearly distinguishable as such, whatever their form and whatever the medium used. When an advertisement, including so-called ‘native advertising’, appears in a medium containing news or editorial matter, it should be so presented that it is readily recognisable as an advertisement and where appropriate, labelled as such.

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As well as the UCPD advertorial rule mentioned, influencers may also breach the same Directive’s prohibition against ‘Falsely claiming or creating the impression that the trader is not acting for purposes relating to his trade, business, craft or profession, or falsely representing oneself as a consumer’ (Section 22 Annex I; Pflücke, 2020: 309). The European Advertising Standards Alliance (EASA), bringing together advertising selfregulatory organisations (SROs), created good practice guidelines for digital marketing communications (DMC) in 2008, setting out the extension of SROs to all forms of digital marketing. However, the growth of influencer marketing and concerns about its usage targeting children led to further pressure for action, and EASA members began to draw up national guidelines from 2017 (EASA [European Advertising Standards Alliance], 2020). Then they issued its Best Practice Recommendation on Influencer Marketing, advising SROs on issues including definitions of influencer marketing, editorial control, payment and other material connections between advertisers and influencers, recognisability and disclosure, responsibility of stakeholders, training, and education (EASA, 2018). These guidelines have subsequently been incorporated into other advertising regulators codes. EASA member the Advertising Standards Authority for Ireland introduced new guidance on Recognisability of Marketing Communications in 2016, while other advertising SROs in the Netherlands, Austria, and France introduced IM codes (SRC, 2019; Woller and Hofmarcher, 2019; ARPP [Authorité de regulation professionelle de la publicité], 2019). The International Consumer Protection and Enforcement Network produced guidelines on online reviews and endorsements in 2016, re-launched in 2017 (ICPEN, 2017). In July 2020, the Australian Influencer Marketing Council (AIMCO, 2020) launched a code of practice on influencer marketing. There are some important differences across codes. Some rules restrict disclosure obligation to what AIMCO (2020: 7) describes as a ‘contracted engagement’ (for payment, value in kind, gifts of free products) set out in any verbal recording, email documentation, digital, or other document that defines an engagement between an influencer and client/provider/brand. Such formulations will cover ‘legitimate’ marketing but enable, and arguably incentivise, evasive ‘undocumented’ agreements to benefit marketers and influencers. The measure seeks to address the problem of distinguishing independent editorial from advertising, yet enables a defence of non-contracted engagement that will be difficult, and costly, to contest in regulatory enforcement. A complaint would have to be based on the possibility that undisclosed brand control over editorial might have occurred, but most complainants will have no access to the actual arrangements negotiated between brands, agencies, and media. The FTC (2017) rules are stronger, requiring that endorsers must ‘clearly and conspicuously’ disclose any ‘material connection’ with the product being endorsed or its producer. A ‘material connection’ between an endorser and the marketer of a product is any connection that might affect the weight or credibility consumers give the endorsement, including employment, business, family, or personal relationships, cash payments, or free products. FTC rules on endorsements also protect ‘honest’ opinion but require accurate experience and substantiation: ‘You can’t make claims about a product that would require proof the advertiser doesn’t have. [A] blogger is subject to liability for making claims without having a reasonable basis for those claims’. (FTC, 2017)

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Converging media, converging regulation? There have always been differences in the way communication services have been identified and regulated. These reflect the historical origins, institutional arrangements, governing values, purposes, and decisions associated with different media. These can be understood according to theories of path dependency whereby decisions become embedded in institutional practices and arrangements such that they influence, and often constrain, how changed conditions are responded to. As Starr (2004: 4) describes in his historical study of US media governance: at times constitutive choices come in bursts set off by social and political crises, technological innovation, or other triggering events, and at these pivotal moments the choices may be encoded in law, etched into technologies, or otherwise embedded in the structure of institutions. For McChesney (2007), the outcome is periods in which structural or institutional change is slow until a ‘critical juncture’ occurs where settled arrangements cannot hold and what Starr calls ‘constitutive choices’ establish new or at least modified paths. For McChesney, critical junctures have occurred for communications when at least two of three conditions pertain: new communications technologies undermine existing arrangements, there is rising dissatisfaction with media content, and a wider political crisis, with the ongoing ‘digital revolution’ marking the latest such juncture. Communications regulation has been disrupted and reorganised to respond to the digital revolution, yet the regulatory arrangements for the treatment of advertising and media remain marked by the path dependencies established in the mid-20th century. The separate regulatory treatment of advertising and editorial remains pre-convergent and de-converged. Despite ongoing convergence across media and in regulation, significant differences remain. These are subject to a range of explanations and justifications that need to be recognised and considered. However, the argument of this book is that the lack of regulatory convergence has served powerful marketers and media at the expense of consumers and the public interest. This has been outlined by examining the specific arrangements in UK regulation but advances a broader argument that draws on evidence and is applicable, in modified form, to other media systems. There is deep bifurcation in UK communications policy rooted in the differential treatment of broadcasting, subject to statutory regulation affecting all content, and the press (and other media) subject to self-regulation based on principles of editorial freedom and non-interference by the state. With the growth of converged media, there has been increasing pressure, from the 1980s, to converge regulation, partially achieved by the creation of super regulator Ofcom in 2004. Yet this has occurred in a period of ascendency for market liberalism, creating a complex set of negotiations across governments, regulators, competing industry actors, trade unions, and civil society over the balance of market freedoms, consumer welfare, and public interest considerations. The contradictions of communications policy-making, and regulatory arrangements, are rooted in the long histories of policy formation, required for explanation, yet the anomalies

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themselves can be sharply identified in their contemporary forms. The institutionalised separation of regulatory scope in the UK means that the ASA regulates ‘advertising’ only, paid marketing communications but not editorial or public relations. Publisher self-regulation (Independent Press Standards Organisation; Impress) regulates editorial only, and the Chartered Institute for Public Relations and Public Relations Consultants Association self-regulate PR but not editorial or advertising. The standards code of the UK press self-regulator, Impress (2018), states that ‘[p]publishers must clearly identify content that appears to be editorial but has been paid for, financially, or through a reciprocal arrangement, by a third party’. Impress monitors 100-plus members, mostly online publications, yet most major news publishers are not members of Impress but of the Independent Press Standards Organisation (IPSO), whose Editors Code has no provisions concerning editorial/advertising relations. The CAP/ASA system has repeatedly re-affirmed its non-involvement with ‘editorial’ as upholding principles of freedom of expression and non-interference in editorial freedom. For instance, in 2012, the Daily Express and Daily Star both published, as frontpage news, the story that the owner of both papers, Richard Desmond, was launching a Health Lottery. The ASA rejected a complaint that the articles were advertorial promotions, arguing that ‘…we were satisfied that editorial control did not rest with the marketer…. The articles were not therefore ‘advertisements’ for the purposes of the code’, and restated that editorial content was outside its remit (Ponsford, 2012). The joint CAP–CMA (2020: 10) guidance on influencer marketing states, ‘ASA enforcement applies where a brand 1. “paid” you in some way (same as CMA, doesn’t have to be money), AND 2. had some form of editorial “control” over the content, including just final approval (different to the CMA, for whom the issue of control doesn’t matter)’. The dual test of payment and control is re-affirmed, although influencers are advised, ‘if you weren’t completely free to do and say whatever you wanted whenever you wanted, then there could have been some level of editorial “control” by the brand’ (CAP–CMA, 2020: 10). However, here the guidance (CAP–CMA 2020: 6) recognises that the ad/editorial distinction is usually not clear and so requires disclosure when it is not otherwise obvious: Most influencer marketing appears alongside organic/editorial content and is presented in a very similar style, so it usually isn’t immediately obvious to a consumer when something is or isn’t an ad from the context alone. Both you, the brand and any agents involved in creating or publishing the content are responsible for ensuring that it makes clear when it’s advertising or has a commercial message. Ultimately, if it’s not obvious from the context that something’s an ad, a clear and prominent disclosure is needed.

Differential treatment product placement and other branded content There are glaring inconsistencies in regulatory treatment of commercial communications in media content. Product placement in television is treated as legitimate marketing (subject to restrictions), but must be identified by common, consistent

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labelling. Brand-sponsored content in print and online is regarded as misleading unless clearly labelled, but is not obliged to comply with common, consistent labelling. The AVMSD (European Parliament and Council, 2010) extended the prohibition on surreptitious advertising to a wider category of: ‘surreptitious audiovisual commercial communication’ [which] means the representation in words or pictures of goods, services, the name, the trade mark or the activities of a producer of goods or a provider of services in programmes when such representation is intended by the media service provider to serve as advertising and might mislead the public as to its nature. (Article 1 [1] j) This will be considered intentional where done for payment or similar consideration. Paid product placement is subject to significant restrictions on programme type, product type, and form. There must be no editorial interference, no undue prominence, and ‘promotion’ is restricted, albeit unclearly. Ofcom’s rules (9.1–9.5) apply to all commercial references that appear within programmes, ‘irrespective of whether a reference is featured solely for an editorial reason or as a result of a commercial consideration. These rules help maintain a clear distinction between editorial and advertising content by limiting the impact commercial arrangements can have on editorial content’ (Ofcom 2016: 4-5). So, for Ofcom, the rules apply based on the presence of commercial references in output, irrespective of transactional relationship, agency, purpose, or motivation (although those considerations are relevant to the application of rules). By contrast, CAP/ASA requires that readers only need to be made aware of sponsored content when marketer ‘control’ is exercised. For CAP/ASA, the presence of commercial references is not governed by rules except where it falls within the scope of marketing communications. Editorial matter and public relations material are explicitly excluded. In television and radio programmes advertisers can have ‘input’ but ultimate editorial control must lie with the broadcaster. In addition, marketers cannot speak on their own behalf outside of advertising (minutage) except when permitted in accordance with relatively strict criteria. Marketers can pay for placement in entertainment programmes but, in doing so, cannot make promotional claims about their products or services. Ofcom (2016: 12) states in guidance on the product placement rules (television): the rules permit the paid-for placement of references in programmes to products, services and trade marks only (subject to various restrictions). They do not permit the paid-for placement of references in programmes to the aims, objectives, beliefs etc. of third party funders. By contrast, brands can pay for presence and editorial control in publishing and other non-broadcast media. The resulting communications need to be identified, and marketing claims are subject to the CAP Code, but there are no comparable limits on references to the ‘aims, objectives, beliefs … of third party funders’. Sponsorship of news or current affairs programmes is prohibited by the EU (AVMSD) and Ofcom,

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but permitted in non-broadcast media by CAP/ASA, IPSO and Impress. Ofcom’s Code (2017: 51) states, ‘Broadcasters must ensure that editorial content is distinct from advertising’. That ‘separation’ rule does not apply across non-broadcast content. Marketing communications must be identifiable, but do not need to be distinct. Arguably, the separation rule is also already breached by paid product placement in broadcast and on-demand programme services (ODPS).

Complaints processes and remedies Rules prohibiting ‘undue prominence’ for commercial references remain after PP liberalisation, although they have become harder to maintain alongside permitted brand promotion. Nevertheless, the undue prominence rules have other important qualities for governance. They allow viewers to identify and raise complaints based on the evidence of the content itself. It is not necessary to know contractual relationships that are usually confidential and legally and operationally protected from public scrutiny. It is not necessary to know the motivations, intentions of those involved, or any informal deal-making. It is sufficient to see how products or services are featured in the content. Lingering close-ups, zooms to products, verbal mentions, and auditory, visual, or combined brand references are the common indicators. It may well be that regulators disagree with complainants about whether such brand inclusion constitutes undue prominence. Yet, the basis for a complain requires no more than viewing the content. Of course, access to the content itself may itself be restricted, yet where users do have access, only the capabilities to read and decode the elements and conventions of audiovisual content are required. Such media literacy skills certainly vary across users by age and many other factors, yet are common capabilities for most able-bodied adults. As the DCMS (2009: 8) noted, ‘it is easier to see from a programme whether a product is “unduly prominent” than to be able to demonstrate that money has changed hands to secure the inclusion of a product in a programme’. The ASA’s dual test of payment and control for branded content opens up regulatory gaps, as discussed above. Further, the burden of regulation arguably falls too heavily on the consumer. In many cases a complaint would have to be based on the possibility that undisclosed brand control over editorial might have occurred, but most complainants will have no access to the actual arrangements negotiated between brands, agencies, and media. For a system that currently relies heavily on notification of code breaches via complaints, that is problematic. There is a palpable risk that power shifts back to the parties to the transaction, and away from regulators and public alike. The CAP/ASA rules do not cover so-called ‘organic’ mentions, namely ‘earned’ media coverage as distinct from ‘paid’ (or transactional) advertising. This is becoming increasingly untenable, as all kinds of transactional relationships can evade the rules by placing the transaction at some distance from the particular endorsement made. The ASA is seeking to expand evidence of marketer control in recent IM adjudications, yet is resisting the moves to ensure any payment and any material connection, including previous paid partnership, is declared effectively.

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The analysis of the ASA partly fits an explanation of ‘regulatory capture’, a dependent agency, with a two-year operating loss and uncertain future income, physically housed alongside the industry body whose code it regulates. Yet, the performance of the ASA is more varied and complex, reflecting its structure, purposes, and institutional history in relation to consumer protection regulation, co-regulation with Ofcom, and legitimacy derived from ‘independence’. The ASA has been interventionist on branded content, partly reacting to CMA action and a wider political and policy configuration attendant to consumer protection online, whose post-Brexit make-up is uncertain. Yet the regulatory system has accommodated the powerful commercial and cultural drivers propelling the ‘native’ blending of advertising and editorial. The interventions made on behalf of disclosure, in rulings, reports, and statements, have been important and influential in communicating standards, yet their effectiveness is questionable in the light of evidence of non-compliance, and they have allowed discretion in disclosure, which has facilitated evasion and created confusion (both discussed in Chapter 8). Above all, they have been developed in a manner that is carefully circumscribed and de-convergent.

Conclusion Historically, media have been subject to very different regulations. Many differences still persist but are coming under strain with the expansion and convergence of media and marketing communications. As we have seen, product placement in the UK and EU remains tightly regulated, yet there is no such equivalent UK (or EU) rules on standard identification of commercial content, or retaining editorial control, applying to publishing, or indeed radio. Classic defences are that regulations have developed to advance and protect certain values. Regulatory convergence should proceed with caution and care to respect those different values and goals. That has been a rallying argument for cultural protection and left/progressive media reformers challenging the convergence policies of market liberalism within the European Union as well as the UK (Marsden and Verhulst, 1999). ‘A film is not a fax’ was a rallying call against the regulatory convergence of telecommunications, computing, and broadcasting at the expense of the cultural and content provisions governing the latter. Yet, media and marketing de-convergence has remained, to the advantage of powerful market actors. The next chapter seeks to answer why, by addressing the wider context of governance, including lobbying, influence within policy networks, and the asymmetrical power dynamics of actors and interests.

Bibliography AIMCO (2020) Australian Influencer Marketing Council Code of Practice. https://www.auditedm edia.org.au/aimco. ARPP [Authorité de regulation professionelle de la publicité] (2019) ‘L’arpp réalise avec influence4you une infographie a destination des influenceurs sur les règles de transparence en matière de marketing d’influence’, 12 September. https://www.arpp.org/actualite/arpp-realise-avec-

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influence4you-infographie-a-destination-des-influenceurs-sur-regles-de-transparence-en-ma tiere-de-marketing-influence/. ASA (2014) ‘ASA adjudication on Mondelez UK Ltd’. 26 November. London: ASA. https:// www.asa.org.uk/rulings/Mondelez-UK-Ltd-A14-275018.html. ASA (2015) ‘ASA ruling on Michelin Tyre plc and Telegraph Media Group Ltd’. 30 December. London: ASA. https://www.asa.org.uk/rulings/michelin-tyre-plc-telegrap h-media-group-ltd-a15-311916.html. ASA (2016a) ‘ASA ruling on Henkel Ltd t/a Dylon’, 13 January. London: ASA. https:// www.asa.org.uk/rulings/Henkel-Ltd-A15-315653.html. ASA (2016b) Advertising regulation: The balance is shifting. Annual Report 2015. London: ASA. ASA (2017) ‘ASA ruling on Nomad Choice Pty Ltd t/a Flat Tummy Tea in association with Sheikh Beauty Ltd t/a Sheikhbeauty t/a Flat Tummy Tea’, 5 April. London: ASA. https:// www.asa.org.uk/rulings/nomad-choice-pty-ltd-a16-366862.html. ASA (2019a) ‘ASA ruling on Cocoa Brown in association with Olivia Buckland’, 7 August. London: ASA. https://www.asa.org.uk/rulings/cocoa-brown-A19-561238.html. ASA (2019b) The Labelling of Influencer Marketing. London: ASA. ASA (2020) ASA Ruling on Jemella Ltd t/a GHD. 4 November. https://www.asa.org.uk/ codes-and-rulings/rulings.html?q=Emily+Canham. ASA [European Advertising Standards Alliance] (2018) Best Practice Recommendation on Influencer Marketing. Brussels: EASA. https://www.easa-alliance.org/coverage/issues/influencermarketing. ASME (2015) New ASME Guidelines FAQ. https://www.asme.media/editorial-guidelines. Benson, J. (1977) ‘Organizations: A dialectical view’, Administrative Science Quarterly 22(1): 1–21. Berry, M. (2019) ‘Neo liberalism and the media’, in J. Curran and D. Hesmondhalgh (eds) Media and Society. London: Bloomsbury, pp. 57–82.Bevir, M. (2012) Governance: A Very Short Introduction. Oxford: Oxford University Press. Brierley, S. (2002) The Advertising Handbook, 2nd edition. London: Routledge. Caines, M. (2013) ‘You are more likely to summit Mount Everest than click on a banner ad’, The Guardian, 23 October. https://www.theguardian.com/media-network/media -networkblog/. Campbell, C. and Grimm, P. (2019) ‘The challenges native advertising poses: Exploring potential federal trade commission responses and identifying research needs’, Journal of Public Policy & Marketing 38(1): 110–123. CAP (2014) The CAP Code: The UK Code of Non-broadcast Advertising and Direct and Promotional Marketing. 12th Edition. London: Committee of Advertising Practice. https://www. asa.org.uk/codes-and-rulings/advertising-codes/non-broadcast-code.html. CAP (2016) ‘Is your ad “obviously identifiable?” Here’s why “Spon” is not “ad”’, 27 October. https://www.asa.org.uk/news/is-your-ad-obviously-identifiable-heres-why-spon-isnot-ad.html. CAP (2017) ‘Guidance on the remit, presentation and content of advertisement features’, 13 March. https://www.asa.org.uk/resource/advertisement-features.html. CAP–CMA (2020) ‘Influencers’ guide to making clear that ads are ads’, 6 February. https:// www.asa.org.uk/resource/influencers-guide.html. CMA (2015) ‘Online reviews and endorsements’, 26 February. https://www.gov.uk/gov ernment/consultations/online-reviews-and-endorsements. CMA (2016) ‘CMA tackles undisclosed advertising online’, press release, 4 April. CMA (2018) ‘Celebrities and social media stars investigated for not labelling posts’, press release, 16 August. https://www.gov.uk/government/news/celebrities-and-social-media-stars-inves tigated-for-not-labelling-posts.

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Couldry, N. (2020) ‘Recovering critique in an age of datafication’, New Media and Society, 22(7): 1135–1151. Davies, J. (2011) Challenging Governance Theory: From Networks to Hegemony. Bristol: The Policy Press. DCMS (2009) Consultation on Product Placement on Television, November. London: DCMS. EASA [European Advertising Standards Alliance] (2020) Best Practice Recommendation on Influencer Marketing. Brussels: EASA. European Commission (2005) Issues Paper for the Liverpool Audiovisual Conference: Commercial Communications, July. Brussels: European Commission. European Parliament (2016) Parliamentary Questions P-006787/2016, 18 October. https:// www.europarl.europa.eu/doceo/document/P-8-2016-006787-ASW_EN.html. European Parliament and Council (2005) DIRECTIVE 2005/29/EC of 11May 2005 Concerning the Unfair Business-to-Consumer Commercial Practice, ‘Unfair Commercial Practices Directive’. Brussels: European Parliament and Council. European Parliament and the Council (2010) Directive 2010/13/EU of the European Parliament and of the Council on the Coordination of Certain Provisions Laid Down by Law, Regulation or Administrative Action in Member States Concerning the Provision of Audiovisual Media Services (Audiovisual Media Services Directive). Brussels: European Parliament and the Council. http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32010L0013. European Parliament and Council (2019) DIRECTIVE (EU) 2019/2161 of 27 November 2019. Brussels: European Parliament and Council. Foucault, M. (1980) Power-Knowledge: Selected Interviews and Other Writings, 1972–1977. Brighton: Harvester. Freedman, D. (2008) The Politics of Media Policy. Cambridge: Polity. Freedman, D. (2010) ‘Media policy silences: The hidden face of communications decision making’, The International Journal of Press/Politics 15(3): 344–361. FTC (1968) ‘Advisory opinion digests’. https://www.ftc.gov/sites/default/files/documents/ commission_decision_volumes/volume-73/ftcd-vol73january-june1968pages1289-end.pdf. FTC (2012) ‘FTC permanently stops six operators from using fake news sites that allegedly deceived consumers about acai berry weight-loss products’, news release, 25 January. https:// www.ftc.gov/news-events/press-releases/2012/01/ftc-permanently-stops-six-operators-usingfake-news-sites. FTC (2015a) ‘FTC approves final orders related to false advertising by Sony Computer Entertainment America and its ad agency Deutsch LA for PS Vita game console’, press release, 31 March. Washington, DC: FTC. https://www.ftc.gov/news-events/press-releases/2015/03/ ftc-approves-final-orders-related-false-advertising-sony-computer. FTC (2015b) Enforcement Policy Statement on Deceptively Formatted Advertisements, 22 December. Washington, DC: FTC. https://www.ftc.gov/public-statements/2015/12/commissionenforcement-policy-statement-deceptively-formatted. FTC (2015c) Native Advertising: A Guide for Businesses, 22 December. Washington, DC: FTC. https://www.ftc.gov/tips-advice/business-center/guidance/native-advertising-guidebusinesses. FTC (2016a) ‘FTC approves final order prohibiting Machinima, Inc. from misrepresenting that paid endorsers in influencer campaigns are independent reviewers’, press release, 17 March. Washington, DC: FTC. FTC (2016b) ‘FTC approves final Lord & Taylor order prohibiting deceptive advertising techniques, press release, 23 May. Washington, DC: FTC. https://www.ftc.gov/newsevents/press-releases/2016/05/ftc-approves-final-lord-taylor-order-prohibiting-deceptive. FTC (2017) ‘The FTC’s endorsement guides: What people are asking’. https://www.ftc.gov/ tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking.

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FTC (2021) ‘Cases tagged with endorsements, influencers, and reviews’. https://www.ftc. gov/enforcement/cases-proceedings/terms/231. Giddens, A. (1984) The Constitution of Society: Outline of the Theory of Structuration. Cambridge: Polity Press. Ginosar, A. (2013) ‘Media governance: A conceptual framework or merely a buzz word?’, Communication Theory 23(4): 356–374. Goodfellow, J. (2017) ‘Instagram blogger’s sponsored post for Flat Tummy Tea banned for failing to use #ad’, The Drum, 5 April. Goodship, P. (2019) ‘Influencer marketing: What you need to know’, Competition and Markets Authority, 30 April. https://competitionandmarkets.blog.gov.uk/2019/04/30/influen cer-marketing-what-you-need-to-know/. Hancher, L. and Moran, M. (1989) ‘Organizing regulatory space’ in L. Hancher and M. Moran (eds) Capitalism, Culture and Economic Regulation. Oxford: Clarendon Press. IAB UK (2018) ‘IAB UK advocates for greater transparency with latest release of content and native guidelines’. https://www.iabuk.com/press-release/iab-uk-advocates-greater-tra nsparency-latest-release-content-and-native-guidelines. ICC (2018) ICC Advertising and Marketing Communications Code 2018 Edition. ICPEN (2017) ‘ICPEN re-launches guidelines on online reviews and endorsements’, news release, 21 July. https://icpen.org/news/83. Ikonen, P., Luoma-aho, V. and Bowen, S. A. (2017) ‘Transparency for sponsored content: Analysing codes of ethics in public relations, marketing, advertising and journalism’ International Journal of Strategic Communication, 11(2): 165–178. Impress (2018) Standards Code. https://impress.press/standards/impress-standards-code.html. Jessop, B. (2007) State Power: A Strategic-Relational Approach. Cambridge: Polity. Kurnit, R. and Taylor, H. (2019) ‘Advertising & marketing in the USA’, Lexology, 11 April. http s://www.lexology.com/library/detail.aspx?g=9fd41625-bced-4bcb-9d3c-96dabf86b673. Lukes, S. (1974/2005) Power: A Radical View, 2nd Edition. Basingstoke: Macmillan. Mahoney, J. (2000) ‘Path dependence in historical sociology,” Theory and Society 29(4): 507–548. Marsden, C. and Verhulst, S. (eds) (1999) Convergence in European Digital TV Regulation. London: Blackstone Press. Mathes, D. (2018) ‘Best legal practices for brands using influencer marketing’, Dallas Business Journal, 26 July. https://www.bizjournals.com/dallas/news/2018/07/26/best-legal-practicesfor-brands-using-influencer.html. McChesney, R. (2007) Communication Revolution. New York: The New Press. McChesney, R. (2013) Digital Disconnect. New York: The New Press. OECD (2006) Alternatives to Traditional Regulation, Regulatory Policy Division. Paris: OECD. Ofcom (2016) Guidance Notes. Section Nine: Commercial references in television programming. London: Ofcom. Ofcom (2017) The Ofcom Broadcasting Code. London: Ofcom. https://www.ofcom.org. uk/__data/assets/pdf_file/0005/100103/broadcast-code-april-2017.pdf. Pflücke, F. (2020) ‘Making influencers honest: The role of social media platforms in regulating disclosures’, in C. Goanta and S. Ranchordás (eds) The Regulation of Social Media Influencers. London: Edward Elgar. Ponsford, D. (2012) ‘ASA rejects Health Lottery splash complain’, Press Gazette, 18 April. Popiel, P. (2020) ‘Let’s talk about regulation: The influence of the revolving door and partisanship on FCC regulatory discourses’, Journal of Broadcasting & Electronic Media, 64(2): 341–364. Puppis, M. (2010) ‘Media governance: A new concept for the analysis of media policy and regulation’, Communication, Culture and Critique 3(2): 139–149.

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Rosenau, J.N. (1992) ‘Governance, order and change in world politics’ in J. Rosenau and E. O. Czempiel (eds) Governance without Government: Order and Change in World Politics. Cambridge: Cambridge University Press, pp. 1–29. Schmidt, V.A. (2008) ‘Discursive institutionalism: The explanatory power of ideas and discourse’, Annual Review of Political Science 11: 303–326. Serazio, M. (2013) Your Ad Here. The Cool Sell of Guerrilla Marketing. New York: New York University Press. Starr, P. (2004) The Creation of the Media. New York: Basic Books. Stewart, R. (2017) ‘UK ad regulator singles out Instagram for failing to label paid-for content’, The Drum, 21 September. Stichting Reclame Code (SRC) (2019) Social Media Advertising Code. Woller, M. and Hofmarcher, D. (2019) ‘Austria: Influencer marketing – Austrian Advertising Council adopts specific rules’, Schoenherr, 4 March. https://www.mondaq.com/austria/ advertising-marketing-branding/788012/influencer-marketing-austrian-advertising-counciladopts-specific-rules.

8 LOBBYING, LIBERALISATION, NORMALISATION, AND CONTESTATION

How have we arrived at the regulatory outcomes described in the previous chapter? While Chapter 7 surveyed what has changed, this chapter explores why and how these changes occurred, focusing on the UK and European Union states, but also discussing other supranational regulation and digital communications regulations in the US and elsewhere. This chapter also examines the discourses of practitioners as components of governance, and considers how branded content has been normalised, but also how, within inter- and intra-industry mediated communications, it has been contested.

Policy-making and critical governance analysis Communications policy-making is the outcome of ongoing struggles between different organised interests that interact in institutions, processes, and arrangements that are themselves inscribed by power dynamics that are outcomes of previous struggles. Communications regulation predominantly comprises specialised sets of negotiations between industry stakeholders and core policy leadership actors. Government and commercial actors make up two main sectors, but they are joined by a third, civil society, which includes charities, NGOs, trade unions, social movements, and advocacy groups (Chapter 11). On communications policy issues, for civil society stakeholders to have influence, there usually has to be a combination of powerful interest groups, such as the lobbies on behalf of health and children, and widespread public coverage of the issues, including discussion of problems and solutions, putting pressure on politicians, regulators, and industries to act. As this illustrates, governance analysis must encompass the many ways in which rules and norms are established, and how they are subject to discursive construction and contestation. This requires an expansive policy network analysis that can identify the range of stakeholders involved, the diversity of communicative activities they use to promote and advance interests, and DOI: 10.4324/9781315641065-10

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the ordering of that discursive space. While such analysis must always be circumscribed for practical purposes, it is in keeping with this conception of critical governance to question where such boundary points are set and to look for actors and communication exchanges that may otherwise be ignored. For instance, a full study of influencer marketing would need to consider multiple sites of discursive engagement, from public and performative interactions, to relatively confidential and concealed contractual discussions among microcelebrities, marketing agencies, and intermediaries. Critical political economy brings to communications policy analysis attention to the way the power dynamics in play relate to the wider political and economic configuration, the ordering of state power and its relationship with the organised advancement of capitalism. Yet the analysis of policy as the outcome of the most powerful interests can lack sufficient attention to the complexity and contradictions of policymaking. Communications policy-making, like other areas, has its own specificities and relative autonomy from state capital. Critical scholarship is strengthened by engaging with the conceptual tools and analysis of more mainstream, overwhelmingly ‘liberal’, scholarship, while attending to structural power asymmetries and their consequences in ways that mainstream scholarship disavows or downplays. One tension is between analyses that emphasise the influence and force of ideas (ideational), versus accounts that see policy as the outcome of pre-structured orderings of power (structural; radical functionalist). A more synthesising, radical approach seeks to examine discursive struggle – struggle to name, frame, and order how problems and solutions are conceived – as an integral and important part of the overall struggle among contending, variously organised interests to shape how resources are used and allocated. This draws on approaches that see the policymaking process as one involving struggle over the interpretation of policy problems. The importance of ideas in policy processes is developed by the political scientist Colin Hay (2002: 209–10), summarised by D’Arma (2018): Actors operate within a ‘densely structured context’ which places constraints not only on their strategic choices (‘given a specific context, only certain courses of strategic action are available to actors’) but also on their discursive constructions of the context, that is, upon the ideas they hold about it. Material conditions, including political factors, then shape not only actors’ strategies but also how actors make sense of the environment within which they find themselves and discursively construct it. However, the direction of influence is two-way. Ideas, Hay contends, can also have an independent effect on the context. For Hay (2002: 214), ideas have effectivity and influence the ‘context’ within which actors act; ideas ‘exert their own effect upon the development of the context over time’. This approach has important merits: it counters overly determinist, unidirectional accounts of influence, and emphasises the processes and significance of struggles for definitional power. However, for critical, para-Marxist approaches, it is necessary to try to understand connections between the ordering of power under capitalism and policy processes. To regard the latter as free-floating is naive ideationalism, while to

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offer a rigid determinism is limited and flattens contestation. So, much depends on how the macro context and structure is identified and how the various ‘levels’ of operation and effectivity of influence (macro–meso–micro) interact.

Media and marketing industry self-regulation: Overview An underlying dynamic is the effort of industry interests to maintain ‘self-regulation’ as the best means to ensure governance arrangements that are deemed appropriate, proportionate, flexible, and adaptable. In general industry interests seek to limit the scope of action by regulators or courts and so lobby to shape or prevent legislation. This drive to restrict formal regulatory intervention is evident and strong across communications, but it is not the only motivation and influence. Firms use regulation to extract benefits for themselves and to curtail or affect the activities of actual or potential competitors. Firms and industry sectors can support regulatory action because it creates barriers to market entry, or advance, for other firms and sectors. Trade associations usually seek to pursue self-regulatory governance arrangements that will support the interests of the wider sector they represent, and to safeguard interests over future periods. The use of sanctions for code breaches against its own rules, such as the PRCA’s expulsion of Bell Pottinger in 2017, illustrates that dynamic. Industry actors also support regulatory action affecting their own activities on behalf of better governance for a variety of motives, including advancing the interests of service users, supply, and value chain partner interests, or public interest values and outcomes. Industry interests are advanced through policy advocacy, lobbying, and influence within policy networks. They are also advanced by demonstrating and advancing sets of claims for the suitability and effectiveness of self-regulation. The determination of rules for conduct is codified in outputs by industry self-regulatory agencies but also developed, interrogated, and debated in industry discursive exchanges, in the daily interactions of practitioners, and in trade media, general media, published and selfpublished commentary, conferences, events, award ceremonies, and so on. The attractions of governance are that it invites attention to the multiple sites of production of rule-making, their interaction with consumers and other actors, and their ordering across production, circulation, consumption, and use. This connects the study of regulation, which is often a specialist sub-field in communications, with analysis of production and practices across media and marketing industries. The study of governance includes examining how professional attitudes change, how norms are formed and challenged, and how industry practitioners and trade bodies engage with contestation from within and outside their domains.

Policy advocacy and lobbying To assess the role of lobbying in relation to branded content, it is necessary to broaden the scope beyond conventional policy studies. First, the lobbyists are intimately connected to the communications policy arena itself. Professional lobbying is a branch of public relations and so part of the broader marketing/communications sector. Second,

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branded content is not just a topic for lobbying but a set of practices used for lobbying, by commercial and political interests, as well as by NGOs and other civil society interests (discussed below). Media governance analysis, in particular, needs to examine how communication forms part of policy advocacy in multiple ways. In its modern form lobbying refers to the activities involved in efforts to influence the decisions of legislative bodies, but also has a more general meaning of influencing opinion on an issue, where a lobby can refer to both a sectional interest and to the group of persons supporting such an interest. Studies of policy-making often focus, with justification, on the active participants in policy networks. However, to assess policy-making in relation to criteria of democratic participation and influence, representation, equality, and justice, we need to consider the full range of policy stakeholders, all those affected by the policy whether actively engaged or not, invited into or excluded from decision-making. It is important to examine the organised arenas in which policy networks interact to shape formal policies, not least since the organisation and ordering of those networks – who and what is core, peripheral, or excluded – is integral to their operation. Yet governance analysis must address the full range of ways advocacy by policy stakeholders can be conducted and influential, and how this relates to policy action and outcomes. As well as attending to the broader scope of policy stakeholders, this means attending to the communicative actions and spaces in which relevant topics are constituted and discussed, and to the relevant, diverse modes of political activity. Branded content is a subsidiary set of governance issues within the overarching framework of data, commerce, information, communications and culture. However, even that broader frame is insufficient. We need to trace the governance of market actors in world economies for all the arrangements that affect the environment and conditions in which market actors are enabled to operate. Those conditions reflect the capacities and influence of political, economic, legal, social, and cultural forces, and so the wider framework of governance concerns their dynamic interaction across macro, meso, and micro levels. The wider context in the West is the combined shifts towards information capitalism and neoliberalism, promoting liberalising re-regulation of communications from the 1980s (Freedman, 2008; McChesney, 2013; Hardy, 2014). Lobbying on behalf of branded content (usually to policy stakeholders – mostly private but with public communication and public documentation elements) involves the following main actors:        

Platforms Commercial media publishers/providers and their associations Public service media and associations Marketers and associations Marketing communications (advertising, PR) agencies and associations Media and advertising regulatory agencies Governments and inter-/supra-governmental authorities Political parties and movements

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Civil society organisations and associations: consumer welfare, health and wellbeing, children, etc.; communications reform campaign groups Trade unions

Delivering a full analysis of communications policy interactions at national and supranational level is required but beyond the scope of this book. Instead, some key findings can be identified that help to locate the lobbying investment and influence of commercial marketers, corporate media, and the tech giants who own the major platforms. The public stance is often one that advances a shared commitment to regulatory outcomes, yet advocates self-regulation as effective and sufficient, and contests the need for stronger regulation solutions as unsuitable or unnecessary. This public stance is belied by the evidence of significant investment in lobbying by the larger firms and by trade associations on behalf of wider groupings. The evidence from published statements, policy documentation and accounts, including from whistle-blowers and former employees, shows considerable resistance towards regulatory ‘interference’. For the liberalisation of product placement (Chapter 3), the larger commercial firms submitted responses to formal consultations but used their privileged access to politicians and policymakers for more intensive lobbying, achieving support for policy liberalisation. The regulatory space was dynamic, with some trade unions (including the Writers Guild of America) warning EU politicians about the dangers of product integration, consumer bodies, and EU political groupings opposed to liberalisation. Yet the commercial interests of advertisers, agencies, and media were stronger, better resourced, more embedded in core policy networks, and able to adapt market liberal framings and values their lobbies had helped to construct to their advantage. The ordering of powerful corporate interests at the apex of regulatory space does not mean governance is thereby controlled or uncontested, but it is necessary for analysis to grasp the structuring of political economic power in governance, in order to investigate the complex and uncertain influences this has in any given instance. That structuring is indicated, but certainly not fully explained, by evidence of lobbying investment and resource, and the major corporate lobbyists on digital marketing are the big tech giants. These firms lobby to mitigate regulatory threats and ensure that unavoidable regulatory action is established on the most favourable terms achievable. Zuboff (2019) explains the huge investment and lobbying effort of big tech firms who also benefited from US policy shifts towards state–corporate collaboration after 9/11. The largest corporate lobbyists targeting the European Union in 2020 were Google, Microsoft, and Facebook (LobbyFacts.eu, 2021). Within the first half of 2020, Google, Facebook, Amazon, Apple, and Microsoft declared spending a combined €19 million on lobbying ($23 million), equal to their annual spending in the whole of 2019 (Satariano and Stevis-Gridneff, 2020). This ‘lobby spending-spree’ is ‘a harbinger of key tech-related upcoming lobby battles in the EU that could shape the industry’s future’ (Corporate Europe Observatory, 2020). The tech firms have extensive links to think tanks who further amplify lobbying through their publications and events,

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giving the impression of independent advocacy, yet failing to disclose their relationship, breaching the standards of the EU Transparency Register (Corporate Europe Observatory, 2020). A leaked Google document revealed the company’s investment in lobbying to ‘undermine new legislation that could severely damage its digital advertising business’, including financing ‘academic allies’ to query and challenge proposed rules (Satariano and Stevis-Gridneff, 2020). Big tech is facing tougher regulatory action by the EU, including on digital advertising processes, as well as antitrust action by the FTC. The EU proposals in 2020 for a Digital Services Act and Digital Markets Act indicate a stronger tilt towards the protection of user rights and democratic processes, and curbing the unaccountable power of platforms. How market, state, and civil society interests will be balanced is yet to be determined. The challenges to big tech should also not distract or detract from the underlying successes of establishing and normalising a political economy based on data extraction and digital marketing, including embedded branded content.

Lobbying through branded content The use of money or influence to affect communications on behalf of those holding or aspiring to political power can be traced to the earliest forms of human civilisation. The influence of sources such as government, political, and commercial interests through ownership, payment, or coercive, legal, or economic control is coterminous with the growth of public media. By the mid-20th century most democratic states imposed rules on paid political advertising in media, especially during elections, to safeguard democratic processes. For editorial content and earned media, the relationship between media and sources has remained complex across ownership, resources and interdependencies, governance, and professional cultures (Manning, 2001; Hardy, 2014). Into this mix has come the relatively new phenomena of political branded content, and of paid but undisclosed and ‘unbranded’ content. The main sponsors of paid-for editorial have been commercial brand owners, but political branded content is being undertaken by governments and political parties, with bearing on policymaking and enforcement where this occurs. For instance, Ferrer-Conill (2016) found that Spanish publications did not disclose their native ads clearly, including political branded content, using in-feed units, whereby paid content is embedded in the main flow of news, where the user is expecting editorial content. El Periódico produced four articles for Area Metropolitana de Barcelona (AMB), a local political entity, within the framework of more than half a million euro contract in which AMB bought an unknown number of articles. The contract was disclosed in the governmental official journal, but was not on the newspaper’s website. The Irish Government’s strategic communications unit arranged, in 2014, for sponsored content to appear in local, regional, and national newspapers, including the Irish Independent and The Irish Times. The unit was disbanded following a review and majority vote in the Irish Parliament, the Dáil, (Finn, 2018). The UK government was found in breach by the ASA (2019) for advertorials, carried in Metro regional papers, Metro online, and MailOnline, on welfare benefit that were deemed to have ‘the

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potential to create some ambiguity as to whether or not they were ads or editorial’. All the complaints made against claims were upheld, a damning verdict on a government ‘information’ campaign. The phenomenon includes state actors paying for presence in publications that carried critical journalism, as the Thai government did with sponsored content carried by Reuters (Carroll, 2019). During the period in which Reuters journalists exposed how sections of the Thai navy and police were involved in the trafficking of Rohingya migrants from Myanmar into the seafood industry, a paid-for article appeared on Reuters.com rebutting seafood slavery in Thailand; ‘paid for by Thailand’s military junta, it touted a “sea change in ethical marine commerce” brought about by reforms that included “stringent measures to protect the rights of workers”’ (Carroll, 2019). Reuters stated that the unit that produced the paid content, Reuters Plus, operates independently of its journalists and that ‘All Reuters Plus content on Reuters.com is clearly labeled to differentiate it from editorial content’. The article featured ‘sponsored’ at the top, with a statement that the content was ‘provided by’ Thailand’s foreign ministry. A statement at the end of the piece ‘in a smaller, lighter font states that the article was not produced by Reuters journalists’ while it appeared on Reuters’ homepage section for sponsored content, where ‘stories sponsored by the Thai government are mingled with news stories in Google search results about the topic’ (Carroll, 2019). Bartosz Wojdynski, director of the Digital Media Attention and Cognition Lab at the University of Georgia, noted that Thomson Reuters Foundation, Reuters’ charitable arm, published articles detailing how the traffickers were continuing to force people into hazardous work, commenting that publishing the sponsored content ‘without the conflicting context provided by Reuters’s own reporting on this issue seems pretty unethical to me’ (Carroll, 2019). A former Reuters journalist commented (Carroll, 2019): When you strip away all the pretense … the reason these advertorials exist is to fool at least some readers into thinking they are legitimate editorial content, or at least imbued with the rigor of Reuters reporting. The piece ‘gave space to a government to whitewash abuses on one of the same platforms on which they were exposed’ (Carroll, 2019). The use of advertorials by corporate and other interest groups for public policy influence grew from the 1980s in the US (Wojdynski, 2016) and is part of what Cooper and Nownes (2004: 546) describe as ‘issue advocacy advertisements that are designed to influence citizen opinion’. Kollman (1998) found that half of the organised interest groups interviewed advertised their policy positions in the media regularly or occasionally. A study by Supran and Oreskes (2017) found that the US oil and gas multinational ExxonMobil provided misleading information on climate change over a 40-year period, including in advertisements and advertorials in the New York Times. In 1980, advised by external public relations consultants, Exxon developed a CO2 Greenhouse Communications Plan that included taking out advertorials, to target ‘opinion leaders who are not scientists’ (Supran and Oreskes,

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2017: 15). A 2000 advertorial said that a US government report on climate change put the ‘political cart before the horse’ and was ‘based on unreliable models’. The study found that of all the company’s communications, it was advertorials that differed most in promoting doubt on climate change: ‘83% of peer-reviewed papers and 80% of internal documents acknowledge that climate change is real and human-caused, yet only 12% of advertorials do so, with 81% instead expressing doubt’ (Supran and Oreskes, 2017: 1). The study also found that ‘ExxonMobil’s scientists and executives were, for the most part, aware and accepting of the evolving climate science from the 1970s onwards, but they painted a different picture in advertorials’ (Supran and Oreskes, 2017: 9). Examples include a 1995 advertorial with the headline ‘The sky is not falling’, which asserted, ‘The environment recovers well from both natural and man-made disasters’. Only advertorials in the New York Times were examined for the study, but Exxon used eight major US newspapers in total. Scholars have examined the phenomena of corporations taking out sponsored content in publications that have carried critical editorial, providing opportunities for confusion over information or editorial stance, or as a platform for rebuttal. In the Guardian newspaper, which ran critical articles highlighting the role of large pharmaceutical companies in opioid addiction, a paid supplement by MediaPlanet carried a positive and entirely uncritical article on the role of opioids in paid relief, ‘Opioids could help you manage your pain’ (Sharma, 2019). The sponsored publication was criticised in a BBC radio documentary on the opioid scandal (BBC Radio 4, 2019). One of the most significant interventions in corporate advocacy branded content was a sophisticated campaign run by Facebook in 2019 involving sponsored promotion in the Telegraph newspaper, the de facto house publication of the UK Conservative Party, then in government. The government had signalled its intention to address online harms and tackle the power of the platforms, publishing its Online Harms White Paper in April 2019. During this period of increasing political scrutiny, Facebook funded an advertorial rebuttal; 26 stories were published in the Telegraph in March 2019, produced by Telegraph Spark, the newspaper’s sponsored content unit. As one journalist reported, the Telegraph was ‘running dozens of stories that defend Facebook on controversial subjects like terrorism, hate speech, and cyber-bullying. […] It shows how Facebook is attempting to sidestep the often-critical media by buying positive coverage of itself’ (Price, 2019). Facebook spokesperson Vicky Gomes stated that ‘this is a part of our larger marketing efforts in the UK with the goal of educating and driving awareness of our local investments, initiatives, and partnerships … that have a positive impact on people’s lives’. Facebook had invested in sponsored content in UK newspapers already, running stories in the centre-left Guardian newspaper on subjects including how to grow your business with video, understanding customers, and corporate case studies (Guardian, 2017). The use of branded content for issue advocacy is also undertaken extensively by public sector and civil society organisations, notably NGOs and charities. However, the majority of NGO and charitable promotion that is not directly promoting public information, services, membership, or fundraising, is awareness raising. While some

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media and advertising regulation affects any political speech, regulations for UK registered charities tightly restrict overt public policy advocacy. There are no comparable limits on corporate voices. Branded content does offer smaller advocacy groups impact over scale, with bespoke content in selected, target media, but barriers of cost remain for paid advertising expenditure by ‘resource-poor’ organisations.

Industry self-governance and practice Major professional associations, such as the Interactive Advertising Bureau, advise their members on complying with regulations on labelling and disclosure of branded content, and advocate good practice principles. The IAB produced good practice guidelines on native distribution formats in 2014, addressing in-feed and content recommendation, then in 2015 addressing online content-based advertising. IAB UK (2018) issued its own updated guidelines in 2018, produced as ‘a result of the growth of social media advertising, rapid rise of influencer marketing and ease of self-publishing’. Guidelines for content-based and native advertising include: 

  

Provide consumers with visual cues, or verbal brand mentions in audio formats, so consumers immediately know that they’re engaging with marketing content, e.g. brand logos and design features (such as fonts or shading) for native ad units that clearly distinguish them from surrounding editorial content Use a clear, up-front label and/or verbal descriptor (as appropriate) to show there’s a commercial arrangement in place and identify the content as marketing. One option where space is limited (e.g. in social media) is the label #ad. Design disclosures so that they are clear and prominent in different formats and devices Ensure the content of the advertising adheres to the CAP Code and all other relevant legislation.

So, these industry bodies identify and advance best practice guidance for their members and other industry actors. Yet, the IAB and other bodies also lobby against stronger regulation. The US-based Interactive Advertising Bureau (IAB, 2015) criticised the FTC’s 2015 disclosure requirements for native advertising as ‘overly prescriptive’, arguing ‘the guidelines could impinge on commercial speech protections’ (Lynch, 2018: 18–20). IAB Europe (2017) reported the results of a survey of IAB national members to identify drivers and hurdles to growth. Drivers included programmatic and native, hurdles included ‘[p]rivacy and regulation, macroeconomic environment and adverse political conditions’. Industry perspectives represent a complex and volatile mix, however, engaging with business, operational, and ethical problems to varying degrees, although rarely attacking underlying premises for commercial expansion. Where there are risks to ‘brand safety’ and reputation – as there are across digital advertising – there can be incentives for firms and sectors to differentiate themselves, as responsible actors, from the damaging practices by others.

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Technological self-regulation There are also interesting technological forms of self-regulation emerging, creating technology-assisted rule application. For instance, Instagram now offers brands the incentive of access to data analytics if they use its sub-headers on posts to declare that they are sponsored. In 2020, following investigations by the UK Competition and Markets Authority highlighting widespread non-disclosure, Instagram announced a new prompt requiring influencers to confirm if they have received incentives to promote content, and updated algorithms to detect potential advertising content (CMA, 2020). The Australian AIMCO (2020) guidelines state: ‘[w]here advertising disclosure tools are available within the digital platform (e.g. Paid Partnership or Branded Content) and are used as part of the Contracted Engagement enabling clear, unambiguous disclosure is made then other disclosures outlined below may not be required’. Regulators, too, are using technology for monitoring and detection. In the UK, the ASA has started to use a media monitoring platform, Brandwatch, with software that uses machine learning to identify and assess potentially illegal or misleading advertising. Brandwatch is a social intelligence tool used to monitor ad content online. According to the ASA (2020), ‘Using Brandwatch, we can both observe trends across a broad range of online content, such as gender presentation in ads, and also look closely for individual breaches of the advertising rules, such as unlabelled ads from individual influencers’. However, the ASA Chief Executive, Guy Parker, acknowledged the regulator was still ‘overreliant’ on alerts from members of the public (Dresden, 2020).

Industry compliance It is important to assess industry compliance with care. Practices and cultures vary considerably and can only be fully identified by micro-level analysis. The ways in which rules are constructed, understood, valued, and acted upon will be interpreted differently within different contexts, and are continually shifting, especially where there is a rapid development of new forms and practices. The tensions of rule-making and rule adherence will be played out within individuals, within groups of workers, within firms, in identifying with others across professional practice or other networks, and within the governance frameworks of organisations and professional bodies. Critically, for later discussion, the rates of non-compliance with formal regulations is not a simple indicator of industry bad faith. Much industry self-regulatory discourse recognises bad actors but differentiates responsible players. More damning and damaging, then, is the failure of those signed up to industry self-regulation to adhere to their own rules. The research evidence, overall, indicates that a significant proportion of publishers do not identify branded content in accordance with the relevant regulatory standards. This highlights the importance of examining compliance and labelling across all relevant communications activities to inform regulation. Studies of native advertising in

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the United States found high levels of non-compliance with the FTC rules introduced in December 2015. Of the online publishers offering native ads, one study found 70 per cent were not compliant with the FTC’s guidelines (Swant, 2016). A subsequent study by MediaRadar (2017), published in January 2017, found the level of noncompliance to be less, although still significant at nearly 40 per cent. Research by the Native Advertising Institute (Eliasson, 2018) in collaboration with FIPP and INMA found that more than 10 per cent of publishers did not label their native advertising. However, while global in scope, this research examined only a limited sample of publications (231) and relied on self-disclosure in responses from news media executives. The evidence from the US studies and other analysis suggests that non-disclosure is significantly higher than one-tenth. Where there is disclosure there are problems of clarity, consistency, and user awareness and understanding, as discussed below. WARC analyst James McDonald notes that ‘[g]uidelines for advertorial content are being flouted to a degree at present. Were they enforced, consumer cynicism for the format may knock investment’ (Hammett, 2016). The reputational damage for marketers and publishers arising from undisclosed ads, as well as from poor-quality ‘clickbait’ from content recommendation engines, may yet strengthen industry self-regulation. A study of 800 Instagram accounts found just over two-thirds disclosed monetary partnerships, but only 25 per cent did so in line with FTC recommendations for clear disclosure within the first three lines of a caption (Williams, 2018). Another study found only 10 per cent of YouTube (0.5 million videos) and 7 per cent of Pinterest links (2.1 million) include a written disclosure of affiliate links, where influencers receive commission when viewers use links to purchase products (Mathur et al., 2018). We lack similar data on compliance across Europe. However, influencer marketing firm Takumi conducted UK research in 2015, finding that merely 37 per cent of marketers admitted to adhering to the Committee of Advertising Practice Code, while many said they did not even know what the Code was (Audunsson, 2016). A survey of 1,400 vloggers and bloggers conducted by CollectivEdge found that only 38 per cent of brand collaborations were disclosed to readers as an advertisement or sponsored post; 40 per cent of those who did not disclose reported they were confused about the requirement to disclose paid-for content on their blogs or social channels. Further, a third of influencers polled ‘admitted that brands were asking them not to disclose paid content, which, in light of the fact that paid-for collaborations makes up 26 per cent of influencers’ content, highlights a lack of awareness or willingness to play by the rules across a significant proportion of brands’ (Murphy, 2019). Global affiliate network www.Awin.com (Langford, 2020) examined the top 100 posts on Instagram for each form of disclosure, including ‘#ad, which had the highest number of posts at 12.8 million, #advertisement (1.8m), #sponsored (3.3m), #gifted (1.8m) and #affiliate (744,000)’; ‘76% of the analysed posts hid the disclosure from view; i.e. their post was not in line with the ASA guidance’ requiring prominent, up-front disclosure. The disclosure was hidden in the middle of posts in 59 per cent of cases, and at the end in 24 per cent, with only 5 per cent disclosing at the start of the post, as required, with 12 per cent hidden in comments sections.

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Labelling, identification, and disclosure practices Content providers use a diverse set of labels. Evidence of the extent to which consumers are confused about labelling is discussed below, but there is a need to collect evidence of labelling practices themselves to test hypotheses that the large number of different labels used (h1), use of unfamiliar labels (h2), lack of clarity in labelling (h3), generate confusion for users, assessed across adults, children, and relevant user group demarcations. Table 8.1 illustrates the range of labels used across seven UK news publishers, 2016-2020. Table 8.1 is illustrative but not exhaustive, even for these publications. For researchers, publishers’ branded content, like other advertising material, is ignored, or inconsistently captured in news databases and publishers’ digital archives, and is especially ephemeral online, with problems including inconsistent tagging, the removal or alteration of labelling, and, in some instances, the removal of sponsor identification after paid promotions, so that the presence of brand sponsored content is entirely erased. A survey of publisher labels in the United States (Sebastian, 2015) showed a similar variety of terms such as hosted by, presented by, promoted by, as well as sponsored, sponsored content, and brand publisher. A common feature was the aversion to labelling the native advertising material as advertising. Other labels include BrandVoice (Forbes); Paid Post (the New York Times); and sponsor generated content (Wall Street Journal). Publishers’ use of labels is idiosyncratic, such as the Guardian’s (2017) divisions between ‘Advertiser content’ ‘Paid content’ and ‘Supported by’. The latter indicates content that has been funded by a marketer but is declared to be editorially independent by the Guardian. Content produced by Guardian Labs is labelled ‘Paid content’ or ‘Paid for by’, while content produced by advertisers is labelled ‘Advertiser content’ or content ‘From our advertisers’. The Guardian has defended its labelling. Anna Watkins, managing director of the Guardian’s sponsored content division, Guardian Labs, told Business Insider in 2016, ‘The Guardian has very clear guidelines on how it labels branded content. We only use two labels – “supported by” and “paid for by” – which distinctly demonstrate what content is editorially independent and what has advertiser sign-off’; ‘If the lines and labeling for sponsored content are not clear then you risk undermining the trust of the reader. This is why we are so black and white about what is editorially independent and what has advertiser influence’ (Heilpern, 2016). The descriptions used for two categories (Guardian, 2017) differ as follows (words underlined): ‘Paid content/paid for by’ is used to describe advertisement features that are paid for and controlled by the advertiser rather than the publisher and are subject to regulation by the Advertising Standards Authority in the UK, the Federal Trade Commission in the US and the Advertising Standards Bureau in Australia. This content is produced by commercial departments and does not involve GNM staff journalists.

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‘Advertiser content/content from our advertisers’ is used to describe advertisement features that are paid for and produced by the advertiser rather than the publisher. They are subject to regulation by the Advertising Standards Authority in the UK, the Federal Trade Commission in the US and the Advertising Standards Bureau in Australia. This content is created by advertisers and hosted by the Guardian and does not involve GNM staff journalists. (emphasis added)

TABLE 8.1 UK newspaper labelling

Publisher website/app

Label

Examples

Daily Mail

Advertorial

Daily Mail

Sponsored by

https://www.dailymail.co.uk/health/a rticle-182775/Advertorial-shape-summer.html https://www.dailymail.co.uk/home/ article-1388146/Terms.html https://www.dailymail.co.uk/femail/a rticle-3226677/Fabulous-floral-trends-hot-pink-ger beras-comeback-chrysanthemum-best-blooms-a utumn-poinsettias-sparkly-pine-cones-don-t-loo k-in.html https://www.thelondoneconomic.com/news/da ily-mail-cashes-in-on-more-government-sponsored-p ropaganda-222787/

Daily Mail

Sponsored content

Daily Express

Advertorial

Daily Express

In partnership with

Daily Express Guardian

Sponsored content

Guardian

Advertisement features An independent supplement; [other terms include] independent advertising supplement, commercial supplement, distributed advertorial supplement From our advertisers

Guardian

Guardian

Advertiser content

https://www.express.co.uk/featured/life-style/life/ 823325/how-long-before-meeting-online-date-fa ce-to-face https://www.express.co.uk/featured/life-style/food/ 972586/That-s-entertainment-How-to-keep-thekids-happy-on-a-budget-this-summer See Express ‘advertorial’ example above: ‘This article is sponsored content for mysinglefriend.com’ https://www.theguardian.com/info/2016/jan/25/ content-funding https://www.theguardian.com/tone/advertisem ent-features An independent supplement distributed in the Guardian on behalf of MediaPlanet who take sole responsibility for its content. https://issuu.com/m ediaplanetuk/docs/pages_digestive_health_dec_2018

https://www.theguardian.com/info/2016/jan/25/ content-funding (Continued)

182 Policies and problems TABLE 8.1 (Cont.)

Publisher website/app

Label

Examples

Guardian

Hosted by

Guardian

Paid content

Guardian

Paid for by

Guardian Guardian

Sponsored features Supported by

Mirror

Advertorial

Mirror Mirror

In association with Campaign with

Mirror Sun

Sponsored; sponsored content In association with

Sun

Sponsored

Telegraph

Advertisement feature

Telegraph

Telegraph Telegraph The Times

The articles on these pages are produced by X, which takes sole responsibility for the contents In association with Paid for by In association with

https://www.theguardian.com/gnm-press-office/ 2016/dec/15/the-guardian-launches- hosted-by-theguardian-a-new-platform-for-advertiser-created-bra nded-content-with-renault-and-top-brands https://advertising.theguardian.com/labs/projects/ tesco-mobile https://www.theguardian.com/tone/advertisementfeatures https://www.theguardian.com/tone/sponsoredfeatures https://www.theguardian.com/global-development https://www.theguardian.com/global-developm ent/2010/sep/14/about-this-site https://www.mirror.co.uk/play/brit on-receives-sky-high-sum-7477695 Sponsorship bar used cross-platform ‘Mirror Online is excited to launch its brand new Grow Your Champions campaign with Team GB partner Aldi. … we will be running features and articles. As part of the campaign, Team GB partners Aldi will also be regularly showcasing their fresh produce and award-winning products to help you fuel your family with healthy meals for less.’ https:// www.mirror.co.uk/lifestyle/health/childs-adorable-ex cuse-not-eating-8292617 https://www.mirror.co.uk/sponsored/youneed-know-world-gratitude-11080093 http://bridge-studio.co.uk/case-study/hunger-gam es-mockingjay-part-2/ https://www.thesun.co.uk/news/11676966/governm ent-support-to-keep-your-business-on-the-road/ https://www.telegraph.co.uk/technology/informa tion- age/ https://www.telegraph.co.uk/sponsored/business/ business-reporter/12210189/changing-the-digital-la ndscape.html

The Times

Promoted content

https://www.telegraph.co.uk/good-news/ https://www.telegraph.co.uk/travel/explore-dubai/ https://newscommercial.co.uk/case-studies/vir gin-money Catt, L. (2019) ‘Where the wild things are’, The Times Magazine, 13 July, pp. 60–1. Advertorial for Kia.

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There is no clarification for readers about the distinction between ‘controlled’ and ‘produced’. There is no reference in this document to Guardian Labs and to the production of content for brands by employees of the publisher. The description ‘commercial departments’ is vague and the assurance concerning ‘GNM staff journalists’, however accurate, may be regarded as misleading since it ignores the role of Guardian Labs and the degree to which its employees may be regarded as being in a category, separate to other ‘staff’/journalist employees, which is meaningful and transparent to readers. This example highlights the need for research into all forms of public communications made by publishers concerning the identification of advertising, not just those attached to particular articles or other items of content. For readers who do reach this Guardian page, the statement requires a relatively specialised grasp of news publishing and advertising practices to understand the various distinctions being outlined. However, few will reach the page; publishers’ guidance for readers is rarely read, similar to digital apps’ terms and conditions. It is not surprising, therefore, that audiences are often confused and annoyed, especially when they discover only after viewing content that it was sponsored. The Reuters Institute for the Study of Journalism (2015) found that a third of UK adults have felt disappointed or deceived in this way, even more (43 per cent) in the US, while a similar poll of US internet users found 48 per cent disappointed (Kirkpatrick, 2016).

Industry discourses on branded content: Normalisation and antimonies Normalisation in journalistic discourses We now have multiples studies of the ways in which journalists, managers, content studio workers, and other actors have responded to increasing pressures to incorporate branded content in publishing. For instance, Carlson (2015) identifies a process of norm entrepreneurship by which the constraints of older ‘firewall’ norms are replaced by a ‘curatorial norm’ that embraces the collation of editorial and paid content for readers based around ‘an imperative of providing content that audiences would find attractive’. Drew and Thomas (2018: 197) examine how ‘once-sedimented institutional and organizational logics are being negotiated and, potentially, reshaped’. In 2014 the New York Times’ Innovation Report advocated a shift in attitudes and practices at the news organisation, in which the ‘very first step should be a deliberate push to abandon our current metaphors of choice – “The Wall” and “Church and State” – which project an enduring need for division’ (cited in Drew and Thomas, 2018: 196–7). Almar Latour (2015), executive editor of the Wall Street Journal, proposed replacing the metaphor of walls with canals, ‘purpose-built and with a clear narrow focus’ whereby ‘news organizations that align with business colleagues on relevant issues will be better positioned to respond to competitive threats’. Artemas et al. (2018) identify a shift away from ‘building’ metaphors to ‘ecological’ metaphors that endorse closer business and editorial collaboration and which serve to frame more integrated practices ‘in “natural, and hence amoral, terms”’, rendering them beyond ‘the realm of normative consideration’ (Artemas et al., 2018: 1015). Whereas for Artemas and colleagues, these are framing strategies, Cornia et al. (2018)

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suggest that a new norm of integration has emerged, based on concepts of ‘collaboration, adaptability and business thinking’, that ‘supplement the traditional value of editorial autonomy and norms of accuracy, fact-based discourse and a commitment to the practice of reporting, but seek to ensure it through integration rather than separation’. They examine the extent to which senior editors and managers legitimise or contest practices that diverge from what they term ‘the traditional norm of separation’. Processes of normalisation are identified by Ferrer-Conill (2016: 912) whereby ‘the long-standing divide between editorial and commercial content has started to be questioned by powerful actors within the industry’. In their study of lifestyle journalism in Australia, Hanusch et al. (2019) examine how organisational and individual factors, including employment status, age, and media sector are among key determinants for how lifestyle journalists perceive commercial influences from PR and advertising interests.

Normalisation in marketing media industry and policy discourses The discourses of professionals are highly diverse, reflecting the complex range of perspectives of individuals and groups situated across conflicting pressures and values. In crude terms, there are divisions between discourses tailored towards ‘external’ policy stakeholders and more ‘internal’ discussions. The latter may be more unguarded but remain attendant to external scrutiny, especially in durable published or recorded forms. Trade bodies and firms engage in discourse as part of their lobbying and advocacy in policy networks, although, again, publicly available statements do not encompass the range of discursive interaction with politicians, regulators, and others. Across the statements made in policy documentation, such as consultations and responses, and in other so-called grey literature, as well as statements in public media, notably trade publications, personal and corporate self-publishing but also reported commentary and writing in general media, the main arguments for branded content can be identified. These can be identified as stories, as strategic narratives. Deborah Stone (1997: 138) examines the role of storytelling in policy-making, whereby policy actors, craft ‘stories with a beginning, a middle and an end, involving some change or transformation’, setting ‘the forces of evil against the forces of good’. D’Arma (2018: 205) describes this approach as one that: sees policy actors as operating within the boundaries of the prevalent political discourse, which can either facilitate or constrain their strategies. In seeking to realize their goals, actors draw upon influential discourses, sometimes creatively refashioning them to promote sympathetic policy outcomes, and craft stories in order to be able to portray themselves as the fixer of a problem. In turn, the ideas that actors draw upon to realize their goals can have material effects on the context through the strategic action they inform. This links to the valuable concept of discursively constructed ‘regulatory space’ (Hancher and Moran, 1989; Chapter 7). Examining processes of normalisation can draw on analysis inspired by Gramsci on the production of dominant ideas (hegemony),

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‘common sense’, and the dynamics of contestation (Davies, 2011). This can also contribute to assessing a core issue: the shifting distribution of power and agency between marketers, media, intermediaries, and communication users. One normalisation strategy is to argue that the relationship between marketers and media is longstanding, even a common origin, and so branded content represents continuity. Normalising media and advertising integration are arguments that media dependence on advertising is long-standing and that the current phase does not indicate a break so much as underlying continuity. ‘Media has since its beginning sought ways of attracting external funding for content, as well as means for filling its schedules’, assert Dzamic and Kirby (2018: 113). A discourse of valuable and valued ‘storytelling’ is another of the most common strategic narratives. ‘Brands are inserting themselves with topics of importance and high ideals – it’s about delivering a story rather than selling something’, says the then IAB UK Head of Policy Clare O’Brien (Crouch, 2015). An appeal is made to the value of the content created by brand support and involvement. This may be focused on what appeals to users and include engaging, entertaining content. It may focus on providing or subsidising (directly or indirectly) information or news. It may make claims about brands’ capacity to support content that has high value, or importance in terms of topics, or which has value in its creative originality or qualities of its form, content, creation, or context. An emphasis is placed on the responsiveness towards, and benefits for, users. ‘The secret to good native advertising has got to be putting the audience first’, declares Clare O’Brien (Hansen, 2017). In some discursive formulation, the benefits are loaded on users. but it is more common, especially in intra-industry or mixed audience discussion, to identify benefits for marketers and media. A common discourse among commercial publishers is that branded content enables the creation of valuable content. This may be a direct relationship in which the content is directly attributable to a brand ‘partnership’. Usually such direct contribution is not characterised in purely economic terms, which would render the brand substitutable and the relationship instrumental, but in terms of a creative partnership involving value exchange of information and ideas and some shared values and purposes. When the discussion shifts from specific brand partnerships to the benefits of branded content overall, then more explicitly economic justifications are advanced, but usually with emphasis on funding enabling the creation of value other than purely economic. The Managing Director of Guardian Labs, Anna Watkins, argues: ‘Branded content offers publishers the opportunity to generate additional revenues for investment in journalism, and to develop innovative projects and platforms that would not be possible on editorial budgets alone’. Addressing how branded entertainment can save advertising, and media, a marketer argues: Production companies benefit because they’ll actually get to make their movies; advertisers win because people will see their products being used – with built-in celebrity endorsements. As for consumers? Having made our bed by skipping ads and installing ad-blocking software, we may now have to lie in it by watching

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brand-supported content. But with the storytelling expertise of Hollywood on task, that isn’t necessarily a bad thing. (Borum, 2016) In what may be regarded as the ideal formulation is a discourse of mutual benefits for marketers (served by marketing agencies), media, and consumers. For Canter (2017), the principles guiding good practice in branded content are to ‘give value across those three different pillars – the consumer, the brand and the platform’. This is a specialised variant of a more general marketing ideology discourse (Brierley, 2002: 25–7) in which the interests of buyer and seller should be matched to their mutual benefit; here the interests of content providers and users or produsers should be matched. Yet, Canter’s (2017) ‘value equation’ does articulate concern to ensure that branded content is effective for the brand but also ‘shows the medium in the best light and is best to the consumer as well’. This ideal formulation is an articulation of best practice that includes some acknowledgement of problems in realising such practice. Canter supports signposting that content is paid for. Failing to do so is ineffective: ‘you are going to be found out’, and instead ‘you might as well do it and be upfront about it, and make no excuses for it, because that is the way the world is going’ (Canter, 2017).

Addressing problems The problems of branded content cluster around three key issues: consumer awareness; the consequences for media content (integrity of media channels); and concern about the extension of marketers’ power across communications (Chapter 9). The first two are engaged in industry discourses (consumer awareness; integrity of media channels); however, the third, marketers’ power and share of voice, is very rarely articulated. Likewise, marketing industry actors seldom advocate curtailing branded content overall. The range of responses can be grouped by type and topic focus as follows:   

Operational: what makes for effective communications and what impedes effectiveness? Ethical: what non-instrumental benefits and needs should be served beyond the instrumental interests of actors involved in the supply of communication services? Reputational: how can stakeholder and wider public confidence be secured to advance common/sectional/organisation/individual interests?

These concerns can be and often are combined in complex ways. They may be analytically separated and it is important to do so, yet they are usually not treated entirely discretely by practitioners but recognised as necessarily interconnected. The main focus for industry criticism and self-criticism is operational effectiveness. A core operational failure is the failure to bring value for recipients. Critiques focused on delivery of messages highlight failure to be appropriate in content and

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placement context. Key terms and values include authenticity, credibility, and subtlety. Another set of criticisms concern the putative ‘pull’ dimensions of branded content and so the extent to which content is set to be ‘invited’ and welcomed by receivers. Effectiveness is serviceable as it includes instrumental interests, but can incorporate a range of non-instrumental benefits for users, such as valued informational content or entertaining experiences. Instrumental effectiveness objectives can also be articulated and presented within a wider set of humanist ethical values, such as truthfulness. Surely one missing element in what we used to call ‘advertorials’ is the absence of a genuine, humanized brand voice. An uninvited pitch, no matter how cleverly constructed will fail in this genre without a storyteller and a listener. To create an environment where marketing doesn’t feel like a pitch but rather an experience, it needs to avoid selling and succeed at teaching. (Conticchio, 2017) For Donaton (2007), ‘[a]s advertisers move more directly into content production, the danger increases that the end product will be dreadful and will turn viewers away with a hard sell at the expense of entertainment value’. However, while acknowledging ‘there has been, and will be, some of that … surprisingly much of the content created or backed by sponsors is even more subtle than anything we’ve seen before. In some cases, the brand is nowhere to be seen.’ The focus has been on enhancing brand positioning ‘without making any kind of sales pitch at all’. Yet, Donaton also makes the case for overt promotions, for example applauding Burger King’s co-production deal with Microsoft’s Xbox to create a series of branded video games, selling 2.5 million copies in its stores in the first five weeks of launch.

Market regulation and consumer power The concerns about effectiveness, ethics, and reputation are combined in the notion of ensuring value for all parties to the communicative-market transaction. This serves as an overarching objective but also as a guide for testing and measurement. It is also reflected in a discourse where ‘effectiveness’ is assessed not in narrower terms such as shorter-term ROI, but in balancing the interests of the participants (marketers, media, users) in a sustainable, mutually beneficial manner. Failure to do so can also serve as a disciplinary measure leading to (self-) correction. This is also expressed in discourses of the market as regulator. Donaton’s book Madison & Vine sets out the argument for market self-correction in his discussion of the shift of power from marketers to users. With the convergence of advertising and media, he writes that ‘there is a real danger that content will be developed first and foremost with an advertiser’s needs in mind, and will only then seek an audience’ (Donaton, 2004: 148). More media content may be produced that serve advertiser interests first. Donaton articulates the risk that advertisers won’t honour the power shift to consumers, but if they do that they will be punished, he

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says: ‘Forgetting that the consumer comes first is a surefire model for disaster, one that leads to weak products that are unable to attract an audience, or earn its trust if they do attract it’ (Donaton, 2004: 148). So, Donaton’s proposition is that the market will regulate. Consumers will send signals that will require market providers to serve them better. Well, I disagree, as developed in this chapter and the remainder of the book. The market regulation, Donaton describes, is a very important element, but not sufficient. As we have encountered in the writings of Donaton and others, a core industry discourse has concerned the shift of power to consumers. This functions in a variety of mutually supportive ways. It shifts attention and explanations from the accrual of power by those involved in the provision of advertiser-supported content to the receivers of such content. Further, it advances consumer power as a regulatory mechanism that is capable, in some versions sufficient, to act against the potential risks of ‘producer’ control. A milder version argues that consumers have values and expectations of what is appropriate. Marketers and media must both work together with a shared understanding and respect for the parameters of acceptability for users. These user parameters extend across, and combine and fuse, operational, ethical, and reputational matters. For operational matters, the discourse usually focuses on issues such as invasiveness, subtlety, ‘fit’, and appropriateness. This blends to more ‘ethical’ concerns, such as permission concerning the form and context of the communication, permission concerning the content, and the source of the communication. Ethical issues blend into reputational issues such as dataveillance and privacy, the acceptability of sponsor/sponsorship connected to the activities and reputation of the promoter, of the communications provider, of the platform. ‘Advertiser[s] should respect the consumer expectation on an individual publisher site and publishers should consider rejecting ad types that do not meet their consumer expectation’, argues the IAB (Borst, 2015).

Transparency and trust ‘The most urgent thing for native advertising is trust’, declares the Native Advertising Institute (Hansen, 2017). Effective labelling of branded content/native advertising is necessary to benefit consumer trust and hence marketing effectiveness for advertisers and publishers alike. O’Brien (cited in Hansen, 2017) says: That’s why we need to, as an industry, ensure that everything is properly labelled. There are research programs from around the world saying that people actually respond better to a native ad that’s labelled, than a native ad that’s not. That is because there is a trust contract between a publisher and its audience and if that gets broken because somebody suddenly realises they’re looking at a piece of content that is paid for. It’s not only bad news for the brand, it’s bad news for the publisher as well. O’Brien’s successor at IAB, Christie Dennehy-Neil, Senior Public Policy Manager, states in a press statement:

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It’s essential when brands are using content and native advertising to reach their audiences that they understand the rules about disclosure, and how to comply with them in practice. Transparency is vital, not just because it’s required by the advertising rules, but because it is key to audience trust, which is so important for brands and anyone they partner with to create or publish advertising content. (IAB UK, 2018) The context for such important appeals is one in which trust in advertising is low and falling. According to the IPSOS Veracity Index 2018, based on a survey of 1,001 British adults, advertising executives rank lowest of all professions (IPSOS, 2018: 2). Reach plc’s 2018 research showed that only 69 per cent of people trust advertising. The Advertising Association (UK) recorded favourability towards advertising at only 25 per cent, the lowest ever, in its annual survey in 2018 (Alps, 2019). The issue of ‘truth in advertising’ has accompanied marketing communications throughout its history (Williams, 1980), yet intensified from the late 20th century as part of a deepening and multifaceted ‘crisis’ debate in Western and other advanced economies. A session on trust at the 2014 Contently Summit heard Eric Goeres, Director of Innovation at Time Inc., advocating honest relationships with the audience: ‘Don’t trick them; don’t piss them off’ (Teicher, 2014). A more recent opinion piece by marketing consultant Gord Hotchkiss (2019) criticises the lack of transparency in native advertising and influencer marketing in particular: when advertising attempts to present itself as something other than advertising, it slips from a black-and-white transaction to something lurking in the darkness, colored in shades of grey. The whole point of influencer marketing is to make it appear that these people are genuine fans of these products, so much so that they can’t help evangelizing them through their social media feeds. This – of course – is bullshit. Money is paid for each one of these ‘genuine’ tweets or posts. Big money. In some cases, hundreds of thousands of dollars. But that all happens out of sight and out of mind. It’s hidden, and that makes it an easy target for abuse. Hotchkiss argues the problem is not just ‘transactional transparency’, but a moral one affecting influencers: ‘[t]he minute you go on the payroll, you begin auctioning off your soul to the highest bidder. [Influencers] Amena Khan and Munroe Bergdorf both discovered this … cut from L’Oreal’s influencer roster by actually tweeting what they believed in’ (Hotchkiss, 2019). Abby Carvossa, Managing Director of Advertising at Bauer Media, asserts the importance of being clear to the consumer whether publisher content is editorial or sponsored by brands: ‘[i]t’s important that anything on our sites is genuine, edited, authentic, curated and clearly labelled. […] giving [consumer] that confidence and trust. We have got to have a big voice in this as content creators’ (cited by Chahal, 2017). Tess Alps (2019), founding Chief Executive of TV marketing body Thinkbox, addressed the lack of transparency as part of a broader review of

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problems and negative perceptions of advertising: ‘The “suspicious techniques” heading covers many dodgy and deceptive approaches from “influencers” to “native” advertising but they all share a disdain for the public and a belief that people have to be tricked into consuming ads. How depressing.’ She argues that the ‘most successful brands know that investing in creativity is the best way to encourage people, not just to tolerate their ads, but to actively enjoy them, to seek them out and to share them’; award-winning creative ads ‘deliver many times more effectiveness, pound for pound, than an average ad’ (Alps, 2019).

Media quality and integrity The discourse on labelling outlined above argues that to secure its legitimate place alongside editorial content, native advertising must be suitably labelled and identified as non-editorial. This discourse includes consumer welfare values, industry defence, and normalisation arguments, but also recognition and valuation of media qualities. Advertising should be distinguished from editorial not only to alert consumers but to protect the values of that editorial content. In this space where media integrity is addressed, there is an industry debate about whether branded content damages editorial quality, trust in media, and media brands. The argument shifts from the operational issues of better or worse executions of branded content in specific instances to the broader, cumulative implications for publications, media sectors, or system-wide. The avowed intent of native advertising is to blend into the editorial environment in which it occurs. Simon Fraser (n.d.), Creative Director at OgilvyOne Business, castigates ‘ads donning editorial clothing in an attempt to make you believe that what you’re reading is objective’. Here a creative executive criticises transactional journalism in a local free glossy magazine in which there is ‘editorial’ invariably praising businesses who advertise in the magazine. So, my question is this: what’s the point of the advertorial format when audiences no longer trust the impartiality of the editorial within which it hides? Could it be that it gives agencies and clients an opportunity to include an amount of information that simply won’t fit into a traditional ad? He concludes, ‘I’m not sure what the answer is, but my instinct tells me that secreting fake views within fake news isn’t a sound strategy’. Such critique may indicate an assertion of quality discrimination to display expertise and value, signalling capability to guide marketers from unwise and potentially damaging strategies. It also expresses a critique of the media standards shown. Yet it articulates normative values for independent, trusted editorial. However, advertiser influence is also defended as one amongst many kinds of influence on content and one that can be applauded for its transparency (when clearly labelled or otherwise identified) in comparison with other source influences. Advertising influence as just one more kind of editorial bias. For Meghan K. Graham, Vice President of Women’s Content at Alloy Media,

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I think it’s important to keep in mind that everyone has biases. A newspaper has a bias. An op-ed page has biases … We all have biases […] And I think that the bias brands bring to content is a new bias, but it’s in the open, and if we’re clear about what the best practices are for how we communicate with the biases, the better off we’ll be. Marketing industry actors seldom advocate curtailing branded content overall. Instead there are antimonies, expressed and resolved (Table 8.2). These antimonies reflect liquidity across practices, relations, and identities. They reflect volatility and unsettledness in the way tensions over branded content are partly acknowledged and partly subsumed in efforts to resolve them, notably in claims for mutual benefits across the triadic relationship between brands, media, and consumers. Industry rhetoric of the ‘savvy consumer’ serves an ideological purpose of disguising the mechanisms by which persuasive power is exercised on behalf of brands in conditions that seek to disable resistance to advertising and, in some cases, the capabilities of users to detect advertising. Kaaren Whitney-Vernon, SVP Branded Entertainment for Shaftsbury, argues that millennials are ‘extremely savvy. They are well aware of when they are being “sold to” and placing a brand prominently, or even not-so-obviously, within the content doesn’t fool anyone’ (Whitney-Vernon, 2018: 232–3). Arguments concerning regulating branded content are frequently framed around the issue of whether audiences are already sufficiently savvy or not. In part, that is unavoidable because if consumers are sufficiently savvy, then the case for ‘stronger’ regulation is thereby diminished. But this framing is problematic. The issue of regulation is not determined as if it were a matter of inoculation, herd immunity through (self-)education. The issues of understanding and respecting

TABLE 8.2 The antimonies of branded content

‘New’: innovations

‘Old’: traditions

‘Resolution’

Hidden

Transparent

Disruption

Continuity (disclosure principles; consumer awareness) Consumer recognition

‘Disclosure’ Labelling ‘Seamless fit’ – integrated AND overt Brand/media/consumer advance together

Innovation and emergent formats Creativity ‘Consumer power’ ‘Marketer power’

Restriction (regulation; prominent labelling) ‘Push’ marketing Regulation and industry self-regulation

‘Savvy consumer’ Trust creatives/market governance ‘Pull’ marketing; permission; ‘Value’ for all: brands/media/user Adaptive industry self-governance ‘media literacy’

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users matter hugely but are not the salient issue, as the savvy consumer framing proposes in order to then frame pro-regulation perspectives as misguided, atavistic, paternalistic, and elitist. The salient issue is the imbalance of information between the communicator and receiver, and how best to address that to serve the interests of actual consumers (taking full account of their capabilities) and potential consumers (considering the appropriateness and proportionality issues arising).

Practitioner narratives, identities, and self-reflection The discussion above highlights that we must analyse not a single strategic explanatory account but a mix of narratives. How those narratives are ordered reflects the outcome of interactions and articulations by ‘institutional’ actors (professional associations, representatives of major companies, and market actors) in particular, but also individual actors, ‘opinion leaders’ with credibility and reach. For individual workers, such discourses will be refracted through more proximate articulations. These may include the discourses of their employer (both external facing and internal), the discourse of the formal or loosely identified network of other workers with whom they identify (within or outside employment relations), the discourses of intra-firm units (departments, sections, teams, etc.), the discourses of those with whom they interact or which encompass their activities, and the wider discourses that they encounter and which may be influential, from their own social and media interactions, media reporting, and other sources. It is only in recent years that researchers have begun to examine the professional identities and discourses of branded content practitioners, but this has been the focus for a rapidly expanding body of work. This work builds in various ways on a larger body of research examining media industry workers and broader sociological, psychological, and cultural anthropological studies. There is increasing transdisciplinary integration, yet there is also a legacy of sectoral compartmentalisation to overcome, with research located and sometimes limited within journalism, media entertainment, advertising, or public relations production. Those lived demarcations remain important, but branded content research, here as in so many other areas, must be converged and integrative.

Inter- and intra-industry critiques It is always important to avoid homogenising industries/sectors that are not only internally complex but increasingly mobile and converged (Chapter 6). Yet, professional identifies also cohere in the arrangements of institutions, practices, and networks that make up fields. While always complex, there is a discernible dynamic of intra- and inter-critique that is enacted, reproduced, and modified. One of the most important in governance contexts is the effort to distinguish and differentiate responsible and rogue actors. The latter may obtain advantages from non-compliance that competing firms call on regulators/self-regulators to prevent. More commonly, rogue actors are challenged because of their actual or potential

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effect on end-user trust and perceptions, for threatening confidence in the effectiveness of existing governance, and for increasing the threat of unwelcome regulatory action. Alexei Lee, head of communications for Fat Media, told AdWeek (Murphy, 2019): We welcome the decision by the CMA to crackdown on misleading advertising, but in all honesty it’s the tip of the iceberg. Some businesses are employing a range of methods to drive sales from native ads, which don’t look like advertising, just normal content, to sponsoring influencers, who, as our own surveys have revealed, don’t then disclose who they are collaborating with […]. Our experience is that influencer content and native advertising is valued and engaged with by consumers if it is delivered using best practice, and consumers are fully aware of the link with a brand. It’s when consumers feel duped that problems can arise for all concerned.

Journalistic critiques of branded content On 17 February 2015, the Daily Telegraph’s chief political correspondent Peter Oborne published a powerful resignation statement, indicting the Conservative Party-supporting paper’s reluctance to cover the story of tax evasion by HSBC bank for fear of losing advertising revenue. Oborne (2015) alleged that HSBC stopped advertising in the paper in 2012 after its reporting on tax evasion in Jersey. Managers were motivated to self-censor their reporting to see ad revenues restored, he claimed, amounting to ‘a form of fraud on its readers’. ‘It has long been axiomatic in quality British journalism that the advertising department and editorial should be kept rigorously apart. There is a great deal of evidence that, at the Telegraph, this distinction has collapsed’ (Oborne, 2015). When Oborne’s original investigation into HSBC was spiked, he investigated the treatment of other Telegraph reporters, finding stories published and then swiftly removed, and details of a major investigation into HSBC shut down by lawyers acting for the paper’s then owners, the reclusive Barclay brothers. When confronted, the Telegraph Chief Executive, Murdoch MacLennan, according to Oborne, ‘agreed that advertising was allowed to affect editorial, but was unapologetic, saying that “it was not as bad as all that” and adding that there was a long history of this sort of thing at the Telegraph’. Oborne criticised the rise of ‘shadowy executives’ who exercised power over editorial to ‘determine what truths can and what truths can’t be conveyed across the mainstream media’ and asked ‘[i]f advertising priorities are allowed to determine editorial judgments, how can readers continue to feel this trust?’ (Oborne, 2015). In response, the Telegraph rejected ‘an astonishing and unfounded attack, full of inaccuracy and innuendo’ (Turvill and Ponsford, 2015). The paper defended its coverage in an editorial, but also pledged to introduce new guidelines to clarify ‘how our editorial and commercial staff will co-operate in an increasingly competitive media industry, particularly in digital

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publishing, an area whose journalistic and commercial importance can only grow’ (Ponsford, 2015a). In a written response to Oborne, the paper stated, ‘We aim to provide all our commercial partners with a range of advertising solutions, but the distinction between advertising and our award-winning editorial operation has always been fundamental to our business’ (Ponsford, 2015a). The editor of UK trade journal Press Gazette criticised the lack of admission of error by the Telegraph, and reported that staff with ‘first-hand knowledge of the inner workings of the Telegraph … backed up Oborne’s claims that commercial concerns have had too much influence over editorial [… extending] beyond HSBC to other major advertisers’ (Ponsford, 2015b), while a Financial Times journalist was told by several Telegraph employees that the ‘allegations of editorial interference were plausible’ (Manse, 2015). A subsequent article in Press Gazette (Turvill and Ponsford, 2015) reported claims from senior Telegraph sources that the commercial department was ‘stronger’ than editorial and that the set-up has been the Telegraph’s ‘dirty little secret for some time’. Reporting a close relationship and interdependency between the paper’s owners, CEO and major firms, an insider said that not all reporters were aware of the commercial sensitivities and that the influence is ‘subtler than that’. Another claimed that the commercial–editorial division had ‘“completely broken down” and that it was now normal for commercial staff to attend news conference and then talk to reporters directly about stories, emphasising which companies are major advertisers’ (Turvill and Ponsford, 2015). Press Gazette called for an independent review and clearer rules to help journalists defend themselves against commercial pressure. MacLennan had previously testified to the Leveson Enquiry into the culture, practices, and ethics of the press, saying: the division between the newspaper’s commercial and editorial teams. It is a ‘church and state’ relationship, at the heart of which lies editorial independence. Whilst the editorial team are all aware of, and engaged with, the strategic development of the business, for example the development and performance of the Telegraph’s multimedia platforms, the editor decides what is published … in compliance with the letter and spirit of the Editors’ Code of Practice. Research by the Media Standards Trust (Ramsay, 2015) confirmed Oborne’s claim regarding the coverage of the HSBC scandal in February 2015. It found that the Telegraph published fewer than half the amount of stories of comparable newspapers, The Times (and Sunday Times), the FT and the Independent, over the same period, and fewer than a quarter of those published by the Guardian (who broke the story) and the Daily Mail. Of the Telegraph’s coverage that did mention the scandal, ‘none focused significantly on alleged wrongdoing at HSBC’. This study was reported in the Financial Times, which stated that ‘Leading national newspapers – including the Telegraph, the Guardian and MailOnline – all offer sponsored content, which critics say blur the traditional division between newspapers’ editorial and commercial operations’ (Manse, 2015). Roy Greenslade, former editor of the Mirror, commented that ‘everyone in the newspaper industry knows that advertising is harder and harder to come by. The implication of Oborne’s revelations is that part of its strategy involves pandering to

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big advertisers to the extent of curbing critical editorial content’ (Manse, 2015). Guardian columnist and former Times editor Simon Jenkins (2015) acknowledged the frame of advertiser as bully, reporting that HSBC ‘paused’ its advertising in the Guardian, while the paper ‘declined to yield’. Yet Jenkins also offers various defensive and collectively dismissive responses. First, advertising dependency is the trade-off for Britain’s ‘robust and free-spirited press’. Second, there is a weary resignation towards a status of advertiser dependency: An American newspaper is said to have carried the ironic motto ‘As independent as resources permit’. Any student of the press knows what this means. A business page protocol ordains gentle treatment of proprietorial interests. Fashion pages would not exist without kickbacks, or travel pages without ‘contra’ deals on hospitality and mentions. Yet, third, Jenkins expresses concern that ‘standards are slipping’. Decrying the subjection of page layout and editorial to fit around ads, he goes on: ‘I cringe when I see “sponsored content” supplements full of “advertorial”. I gather some titles now actively seek corporate sponsorship for columnists’. However, fourth, Jenkins isolates Oborne’s example as an extreme case: ‘I have never come across anything as serious as Oborne’s accusations against the Telegraph and its “creative advertising solutions”’. He diminishes Oborne’s attack as a necessary, but unreliable and overstated attack by a ‘maverick … [whose] veins run with the blood of scepticism … [and who has] extended his charge sheet to venal advertisers’. Jenkins returns to his main theme: ‘There is no question that the private sector is an insecure way of financing a free press that does not make money. But all other ways are worse.’ The principal anxiety acknowledged in the piece is the threat of regulation, with Oborne’s atypical internal critique lauded as the best mechanism for self-governance: ‘The only champion of a free press is not some regulator or commission or charter board. It is the free press itself. Plurality, rivalry, disclosure, exposure and sometimes fury are the best guardians.’ Referencing the enquiry into press standards by Lord Leveson, he concludes: ‘One Oborne is worth 10 Levesons’. Yet, that assertion of self-regulation fails to counter the extensive evidence of press malpractice and code breaches uncovered by Leveson and documented by the Media Standards Trust, Hacked Off, CPBF, Media Reform Coalition, and many others, nor, crucially the collective silence and mutual protection accompanying media abuses. Oborne writes, ‘All the newspaper groups, bar the magnificent exception of the Guardian, maintained a culture of omerta around [News Corporation’s UK newspapers’] phonehacking, even if (like the Telegraph) they had not themselves been involved’. A comment posted in response to an openDemocracy article on sponsored content (no longer available) discussed conditions in lifestyle and women’s magazines whereby major brands are covered ‘in what affects to be an independent process of editorial judgement [… but is] all just bought and paid for by big corporations’: But it is a tricky subject because almost all publishing depends upon … these kind of ‘deals’ – and no-one likes their own deals being exposed so an unholy

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alliance in preventing daylight being shone is the order of the day. To cling onto their precarious and lowly paid jobs, often indeed unpaid, the young journalists who know and understand little of this type of thing collude with the bright and shiny sly con, aided by PR trips. Media governance involves the role of trade media and general media in discussing the parameters of good practice. Bromley (2000) discusses the influence of Columbia Journalism Review and other forums through which professional norms are debated in US journalism, noting that the UK is comparatively less developed, although British Journalism Review and Press Gazette are amongst the vehicles for such discursive spaces. The satirical magazine Private Eye has played an important role casting a critical and insider-informed gaze over personal and corporate abuses, including Eye-Sky column that documented servile cross-promotion of Sky in Murdoch papers, discussed earlier (Hardy, 2010). Oborne told Press Gazette: ‘I’m not sure I would have resigned but for reading these stories in Private Eye … They drew attention to things I was unaware of … [and were] the main source of information for Telegraph journalists about what was going on in the paper.’ (Turvill, 2015) Press Gazette (Ponsford, 2015b) re-affirmed editorial integrity and advocated strengthening self-regulation: The travails of the Telegraph this week show that there is no quicker way for a newspaper brand to self-destruct than by losing its reputation for putting the interests of readers (rather than advertisers) first. That’s why it would be in the whole industry’s interests for the Editors’ Code to be changed to provide journalists with protection from commercial pressure But this is a call so far unanswered. The Telegraph (2019) produced updated guidelines which state: It is entirely appropriate, and indeed essential, that editorial staff understand and contribute to the commercial success of the Telegraph. However, editorial independence must always be maintained. Commercial staff should not influence editorial’s story judgments in connection with any advertiser’s or potential advertiser’s interest. The final decision on all editorial content is the Editor’s. The statement balances obligations to readers, viewers, and the wider public, but also advertisers, partners, and suppliers. Yet it also includes an oblique reference sanctioning branded content: ‘In a fast-changing media world, we must innovate to achieve that [commercial] success, while at all times ensuring we preserve editorial independence’. The guidelines state, ‘Any commercially paid content beyond traditional advertisements must be clearly and appropriately marked as per protocols’. So, the publisher makes a

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clear commitment to labelling, and to distinguishing editorial from paid content, but the message to its own journalists is less clear. Commercial involvement, even ‘Commercially funded positions in editorial are permitted’. It is perfectly proper for journalists to write content that is paid for commercially, provided that it is clearly marked as such. In undertaking such tasks, journalists should do nothing to compromise their ability to write for our audience objectively, fairly and honestly. Does this mean that journalists should ensure their ability to write non-paid articles is not undermined, or is it a claim that paid stories themselves should be written in accordance with journalistic norms of objectivity? If the latter, that is a highly contentious claim, and unsupported. The very problem of a corporate policy towards an advertiser affecting editorial, as the HSBC case presented, is rewritten as a task of balancing competing pressures by individual journalists. The tensions between independent and bought content are ‘resolved’ by re-affirming editorial standards as a commitment and obligation on journalists, while the extension of commercial influence in the publication is acknowledged and justified. For UK broadsheet journalist Ian Jack (2015), the distanciation between journalists and advertising sales teams reflected class attitudes: ‘They were in trade whereas we were the aesthetes’. there was perhaps also something ignorant and hypocritical in the traditional journalistic view of advertising, which came out of our moral hauteur. As journalists, it seemed, we were curious about everything in the world around us, apart from the people on the floor below who brought in the money. Jack describes the prevailing attitude, before the decline of the last 20 years, as one where ‘advertisers still knew their place – which, in the editor’s opinion, ideally took up no more than half of a left-hand page’. Jack worked on the Sunday Times, then a prosperous, elite ‘broadsheet’, and recounts how: The travel section of the Sunday Times, in its pre-Murdoch years, once sent me on a voyage round the Caribbean as the guest of a cruise line, and the piece I wrote as a result had the unkindness of a young, single man for whom this sort of holiday was not intended. The cruise line then cancelled the series of ads it had booked – all of them five columns wide and standing tall on the page. It never occurred to me to say sorry to the staff in display ads who must have put the deal together; in fact, to say sorry to anyone. The cost of my piece in lost revenue was considerable, but the separation between getting and spending on the paper stood absolute. Nobody suggested I wrote the piece differently. While Jack offers an ambivalent defence and repudiation of church–state divisions, there is evidence of much stronger criticism of brand-sponsored editorial, amongst

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other journalists, including by a younger generation who have always worked within an environment of digital challenges and challengers. Guardian journalist and editor Jane Martinson (2015) writes, ‘allowing advertisers to use future revenues as a bait to dictate editorial is not the way to survive but to die faster’. US journalist Andrew Sullivan, who left the Daily Beast to launch ad-free The Dish, castigated native advertising in an interview with Digiday (Braiker, 2014): ‘Advertising snuck into the editorial pages in a way that advertising has always wanted to do. It used to be an axiom that the job of journalists was to be resistant to that and sustain the clear distinction between advertising and journalism. One side has effectively surrendered.’ Another, Gene Foreman (2015: 175), warns: [N]ative advertising – like its predecessors, advertorials in print and infomercials on television – undermines the credibility of the website’s real editorial content. Native advertising blurs the distinction between a journalist’s effort to inform the public and an advertising copywriter’s effort to promote a brand. In the long term, ads camouflaged as news could lead to consumers to stop reading a website at all. For Australian journalist, Kellie Riordan, author of a report on accuracy, independence, and impartiality in news journalism (Colhoun, 2015): At its core, journalism is about truth-telling, while advertising and branding are about persuasion. Journalists compromise their independence when they start writing branded copy; you’re not hired to serve the best interests of the readers, to keep anyone accountable, to check facts or to seek the truth – you’re peddling someone’s line. There have been powerful criticisms of branded content by journalist, explored further in Chapter 9, yet Oborne’s description of omerta has support. Colhoun (2015) notes that the ‘last time the New York Times ran a pointed, critical piece about storytelling ads was in September, 2013, right before they started doing them’. Also present, but rare, is intra-publication critique. Writing in the paper, Simon Jenkins (2015) criticises the Guardian: Today its ‘branded content partner zone’ is occupied by Unilever, ‘whose sources of revenue allow us to explore, in more depth than editorial budgets would otherwise allow, topics that we hope are of interest’. Hence this week’s frothy promotion, under the Guardian masthead, of a ‘green sex sustainable’ condom – though it’s also fair to point out that the Guardian columnist George Monbiot launched a withering attack on the partnership in these pages. The activities and scope of contesting branded content are examined in more detail in Chapter 11, but it is fitting to conclude this section by discussing public media as a vehicle and platform for contestation. Amongst the most well-known example is

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the fine-tuned, richly illustrated, 11-minute counter-blast issued by John Oliver, the host of Last Week Tonight, a late-night talk show on HBO. The English comedian moved to New York to work on the Daily Show with Jon Stewart and has been the host of Last Week Tonight since its launch in April 2014. The segment on ‘native advertising’ was broadcast on 3 August 2014, assembled by a team of ten writers, including Oliver, five film editors, and a total crew of over 100 (IMDB, 2014) and mixed archive footage with satirical graphics and an elaborate spoof ad. Combining visual jokes, clips from industry proponents, and a rapid-fire, richly scripted satirical attack, Oliver challenges not just the practices but above all the efforts to normalise native advertising. In a visual joke in which surgeons fail to value and recognise the heart (‘what’s that?’) tossed out of a patient, he charges that corporate media fail to understand and value what they are destroying. He calls out as ‘bovine waste’ the rhetorical drapery by which the erosion of editorial independence by brands is represented as benign and beneficial ‘storytelling’. Oliver later told an audience at the publishers Hearst that the piece was inspired by a media interview with Time Inc’s CEO Joe Ripp. As reported in Advertising Age (Sebastian, 2014), Oliver ‘was struck by how easily and quickly Mr Ripp dismissed the tradition of separating his company’s editorial function from the business side’. At a Q&A session with Joanna Coles, editor of Hearst magazine Cosmopolitan, Oliver ‘acknowledged that native advertising probably works to draw ad dollars in the short term, but called the practice ultimately a “trust parasite”’ (Sebastian, 2014). As wryly noted by Oliver at the start of his piece, his critical commentary is presented on the ad-free HBO, providing a licence to challenge advertisers less available on ad-funded commercial media. Yet while Oliver criticises product placement, HBO is spared, with its business model instead presented, humorously, as inexplicable. The piece was favourably covered in Advertising Age, with one reporter writing that the ‘whole extended rant is scathing, thought-provoking and very funny – particularly at the end when Oliver, suggesting that turnabout is fair play, injects some hard-news content into a (fake) Diet Coke commercial’ (Dumenco, 2014). The subtitle of that piece describes how Oliver ‘Deflates a bit of the buzz surrounding sponsored content’.

Conclusion The governance of branded content is multidimensional and multilevel, but is ordered by the relationships between leading capitalist enterprises and state power. Capitalist states are oriented to support arrangements that favour wealth creation and market expansion for owners of capital and serve nationally inscribed interests within an overarching globally integrated capitalist system. States are not neutral terrain for competing interests, but have structurally inscribed strategic priorities, selectivities, towards favouring some interests, forces, and initiatives over others (Jessop, 2007). Countervailing forces exist at all levels and shape outcomes but are weaker, and can usually influence policy action only within the boundaries of state, or supranational, selectivities, unless the balance of forces shifts to challenge these

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and provide access to state power for excluded interests. The interaction between the interests and capabilities of political authorities and capitalist enterprises opens up space whereby underlying capitalist dynamics of data extraction and commodification are subject to regulatory action. Social action can influence this regulatory space but also change the outcomes across all domains of governance. The critical governance approach outlined seeks to consider the ordering and interconnections between various levels, without determinism. The ingredients for such a critical governance analysis have been outlined but require further systematic analysis to fully deliver. For instance, computational text analysis of policy and media discourses would help to identify patterns in each, and their interrelationship. The author is engaged in efforts to develop and apply tools for comparative analysis to advance this work. In the meantime, the documentation, interview and data analysis outlined in Chapter 7 and 8 can be summarised as follows for the US and UK.

Regulation  



Extension of consumer protection – labelling and identification of advertiser paid/ sponsored communication (native advertising formats; social media influencers) Rules limited, e.g. FTC (US) assessment of deception based on test of whether identification would affect the way consumers may act in respect of marketing claim. ASA (UK) test of payment and control – where brand pays but publisher feels able to claim editorial control, no disclosure is required Enforcement action limited (increased since 2015, but patchy; 51 FTC cases on endorsements, influencers, and reviews since 2016)

Media/marketing industries (self-regulation)    

Promotion of disclosure Lobby for flexibility (FTC and ASA responsive, resisting demands for consistent labelling) Flak from companies (often privileged, non-public, policy network communications) Poor compliance

Overall – lack of effectiveness  

Poor levels of recognition; ‘some disclosure phrasings recommended by the FTC [Advertising; Sponsored; #ad] seem to be only minimally effective’ (Campbell and Grimm, 2019: 111) Evidence of consumer demand for more effective regulation (Chapter 11)

Despite ongoing regulatory convergence, a diverse range of agencies regulate, and selfregulate, branded content, reflecting historical, institutional differences across publishing, broadcasting and audiovisual, public relations, and advertising. Governance

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arrangements reflect the ‘structuration of past conflicts and present organisational power’, a phrase used by Marsh and Smith (2000: 6) to describe policy networks. There is a legacy of separate regulation, and demarcation of content that has been illequipped for rapid convergence across marketing communications and publishing, with regulatory arrangements lagging behind industry practices. Such de-converged regulation has been largely beneficial to commercial media and marketing firms, although legal-regulatory uncertainty also adds to costs. This phase may be drawing to a close, however. Heightened attention to issues of fake news and misinformation, undisclosed political advertising, influencer marketing and online harms, digital literacy, and communication rights is resulting in pressure for more regulatory intervention. How far this will apply across online advertising and branded content will depend on corporate lobbying power, the mobilisation of civil society interests, discursive ordering across mediated communications, and on self-regulatory responses across the industries involved.

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9 COMMUNICATION GAINS AND LOSSES Economic, cultural, and societal

This chapter discusses major perspectives and debates on media–marketing integration and puts forward arguments against commercial integration, responding to various objections. The relevant debates here engage with issues and concerns, ranging from: media finance; managerial, editorial, and creative control; brand realism and aesthetics; consumer awareness; marketer power; and the desirability and feasibility of different forms of governance.

Critical framework: Three problem areas Reviewing the literature, there are three main problem areas, three main clusters of concerns. The first is consumer welfare, ensuring that consumers are sufficiently aware of marketing communications. The US Federal Trade Commission (FTC, 2015: 1) describes native advertising as ‘advertising and promotional messages integrated into and presented as non-commercial content’. A key principle of advertising regulation is transparency: ‘[m]arketing communications must be obviously identifiable as such’ (CAP, 2014; rule 2.1). At issue is the degree to which branded content is labelled and identified so that consumers can assess the interests behind the communication. The problem of consumer awareness is vital, and examined below, but the focus on this tends to displace two other concerns. The second problem is the effect of native advertising on the quality and integrity of channels of communication. I take that phrase from public relations codes. For instance, the International Public Relations Association (1961/2009) says its members should ‘not engage in practice which tends to corrupt the integrity of any channel of communication’. The creation of content on behalf of marketers that looks very similar to editorial content has the potential to undermine the editorial integrity of the publication, critics argue. Such branded content undermines, or threatens to undermine, the integrity of channels of communication. It highlights concerns to DOI: 10.4324/9781315641065-11

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safeguard qualities of the communication channel, not just protect consumers from deception (Goodman, 2006; Levi, 2015). One version argues that native advertising is parasitic, destroying what it feeds on; advertisers wants to harness reader trust but in doing so undermine it. As the legal scholar Tamara Piety (2016: 101) adds, ‘native advertising threatens to spread advertising’s low credibility to all content, thereby destroying the reason advertisers wanted to mimic editorial content in the first place’. Another risk is that, as an article in Advertising Age puts it, ‘[w]hen you are a publisher that peddles native advertising, you’re more vulnerable to advertising pressure’ (Goefron, 2015). So, this second concern is about editorial independence and artistic integrity for creative producers and consumers, and the impact on credibility and trust in publishing. I will use a traditional artefact as illustration, an issue of the Saturday Guardian magazine published on 24 September 2016 which contains five double-page spreads marked ‘Paid content’, for Jaguar, Nestlé, San Miguel, the non-profit Greenpeace, and Airbnb. The Jaguar advertorial illustrates one set of problems, with content used, intentionally or not, to evade advertising regulations. The promise that ‘Drive time is no longer downtime’, with a technologically enhanced car as office extension, was found in breach of advertising self-regulatory rules regarding motoring, social responsibility, harm, and offence (ASA, 2017). For Airbnb, the premise is a ‘diary’ report on a city break to Paris written by Gemma Briggs who visited with partner Alex and child. The couple stay in the apartment of a film director who leaves them champagne. Two-year-old Nell is ‘goggle-eyed’ at the owner’s colourful artefacts, and doesn’t break any. In her own ‘diary’, she describes the Pompidou centre as ‘cool’ and ‘awesome’ and mentions her ‘comfy’ apartment bed; impressive since the average vocabulary of a two-year-old is 240 words. Gemma’s account consists of 23 sentences, of which ten refer directly to the Airbnb apartment. The level of control and construction of the communication marks this as a form of ‘branded wisdom’, to use Naomi Klein’s (1999) evocative phrase. Native advertising violates principles of editorial independence, or artistic integrity, because it creates the risk that ‘non-advertising’ content will be shaped in accordance with advertisers’ wishes. Radical political economic critiques go further in their concern about the system-wide consequences for communication provision of privileging marketers’ voices. So, the third major problem concerns marketers’ ‘share of voice’ within communication spaces. We can draw here on the work of critical media sociologist Nick Couldry (2010) examining what Judith Butler (2005) calls the materialisation processes through which some voices come to be heard and others not. Couldry sets against neoliberalism a valuation of voice as the ability of people to give an account of themselves. But he does not address advertising, which both confirms and complicates the analysis. In my Guardian Airbnb example, not only is a corporate voice privileged though marketer-controlled communication, but there is corporate ventriloquism in the storytelling, which renders the voices of the tourists and their child both embodied and inauthentic. The extension of brand voice into non-commercial spaces increases inequality in communication power.

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Problem 1: Consumer welfare The language chosen to describe efforts to safeguard the interests of consumers is burdened by sets of issues about how and by whom decisions should be taken about what is in your interests, my interests, the interests of ‘consumers’, or in a more broadly conceived way, societal or ‘public interest’. Complicating debates are strains of libertarianism that bind otherwise seemingly opposed perspectives across the right and left of the political spectrum. Those favouring ‘intervention’ on behalf of consumers also range from authoritarian or socially conservative perspectives through to those espousing radical democratisation and ‘empowerment’. This matrix of perspectives will be discussed further but requires some explanation and justification of terminology first. I choose consumer welfare as it leaves open how that should be achieved, whereas ‘consumer protection’ takes us straight to issues of decision-making by some for others and well-trodden ground for critics of authoritarian or paternalistic control. Consumer welfare does not evade problems of legitimation but does offer a more open and less directed framework. However, ‘welfare’ has its own connotations, from neoliberal and public choice theory accounts of ‘welfare maximising’ benefits conceived in individualistic terms, to statist ‘welfare’ provision, to more social democratic, social market, and socialist conceptions of collective support. A more progressive formulation is empowerment, yet welfare captures the social dimension and democratic rule-shaping that are jettisoned or downgraded in neoliberal versions of market ‘empowerment’.

Consumer identification There is now considerable empirical research into user awareness of native advertising, testing various aspects of cognition and persuasion. Research shows consumers fail to notice disclosures (Wojdynski and Evans, 2016) or fail to understand what they mean (Gilley, 2013). The FTC’s recommended disclosure phrasings seem to be only minimally effective. One study by US researchers found that less than 8 per cent were able to identify native advertising as a paid marketing message (Wojdynski and Evans, 2016). Another selective study of internet users found that ‘just over one-quarter of respondents (27%) thought that the advertorial was written by a reporter or an editor’ concluding that ‘labeling – even using a “sponsored content” disclosure – is insufficient to disabuse a significant minority of consumers about the provenance of the advertising material’ (Hoofnagle and Meleshinsky, 2015: 13). A study by researchers at Grady College, Georgia (Wojdynski and Evans, 2016) tested native advertisements on 242 subjects and found that less than 8 per cent were able to identify native advertising as a paid marketing message. The researchers found that readers were seven times more likely to identify articles as paid-for content when they were labelled as ‘advertising’ or ‘sponsored content’ than when labelled ‘brand voice’ or ‘presented by’. As well as examining disclosure language, they also examined disclosure placement. Using eye-tracking software they found that only 40 per cent of readers looked at a disclosure label at the top of the page, 90 per cent did so when it

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was in the middle of the page, and 60 per cent when it was at the bottom. Amazeen and Wojdynski (2018) tested various disclosure design characteristics for sponsored news on 800 US adults. They found that fewer than one in ten participants were able to recognise native advertising. A general finding is that only a small percentage of research participants identify sponsored content, 7 per cent in one study (Wojdynski and Evans, 2016), 9 per cent in another (Amazeen and Wojdynski 2018). Wineburg et al. (2016) found 80 per cent of student research participants believed a native advertisement, labelled ‘sponsored content’, was a real news story. Industry research has generated similar findings. A July 2014 survey by the Interactive Advertising Bureau and PR firm Edelman found that only 41 per cent of consumers considered that native ads on a general news sites were clearly identified as paid for by a brand. A Contently (2016) study, based on focus groups and a survey of 1,212 US adults, found that 54 per cent had felt deceived by native ads, 77 per cent did not interpret native ads as advertising, and most favoured ‘sponsored’ as the best labelling. Discussing that research, Melanie Deziel (2016) writes ‘The biggest takeaway: For just about every publication, readers were confused trying to separate the two types of content’. Such industry research has been more readily reported in trade media than academic studies. Yet the latter have been reported, including Hoofnagle and Meleshinsky (2015). Business Insider (Heilpern, 2016) reported on the research by Wojdynski and Evans (2016), which found that 60 per cent of readers did not notice the sponsor disclosure label placed at the top of sponsored articles: ‘readers are seven times more likely to recognize the labels that use some form of the words “advertising” or “sponsored,” than those which use more vague phrases like “brand voice” or “presented by”’. The researchers found disclosure in the centre of an article was more effective in this experimental study (90 per cent recognition) than at the top (40 per cent) or bottom (60 per cent). Wojdynski states: I think the advertisers are well aware that they benefit from some ambiguity in the consumer’s mind about whether or not it’s paid advertising. Otherwise they’d put, in really big letters, right across the top: ‘This is a paid advertisement from the company name.’ They don’t want to do that because they know that consumers habituate themselves to ignore advertising online. (Heilpern, 2016) Overall, only 20 per cent of research subjects were aware that they were reading advertising, rather than editorial content (Wojdynski and Evans, 2016).

Consumer psychology research: Persuasion knowledge Labelling is often the sole means by which users can distinguish paid content from editorial, so it is a key determinant of awareness of advertising content (Wojdynski, 2016; Boerman et al., 2012). This is the principal focus of user research, dominated by experimental research methods, that examine attention, comprehension, and recall, and assess or infer influence and persuasion. Boerman et al. (2016) review 21

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studies examining the effects of sponsored content on consumers’ responses, including product placement and video news releases, although only two studies are of print advertorials, one finding a marginal negative effect of disclosure in reader engagement with print advertorial (Cameron and Curtin, 1995), the other finding no significant differences in self-reported attention and recall by readers concerning labelled or unlabelled advertorials (Kim et al., 2001). Boerman et al. (2016) conclude that the literature is inconclusive about several effects of disclosures of sponsored content, including whether disclosures encourage readers to ignore sponsored content or activate critical processing. An influential theory for such processing is persuasion knowledge, informing studies that examine the extent to which native advertising effectiveness is dependent on consumers’ lack of awareness that native advertising is paid persuasion (Wojdynski, 2016). The Persuasion Knowledge Model (PKM) of Friestad and Wright (1994) is based on the proposition that ‘[u]pon facing a persuasive attempt, consumers access their persuasion expertise – relevant knowledge of selling and persuasion tactics –and apply coping strategies based on this accessed knowledge’ (Amazeen and Wojdynski, 2018: 224). The PKM predicts that consumers’ recognition of a persuasive intent will often lead to greater scepticism and scrutiny, and ultimately more negative evaluations of the message (Boerman et al., 2017). The PKM also predicts that the ability to decode persuasion (persuasion expertise) increases with age. However, researchers examining forms of embedded branded content test whether such novel marketing communications formats means consumers may have less relevant experience to draw upon. In their research testing recognition of native advertising, using a single example modified in various ways for presence and positioning of disclosure, Amazeen and Wojdynski (2018: 238) find: Despite fewer than one in 10 participants recognizing the content as advertising, those who did were younger and better educated. Furthermore, as predicted, those who used news for surveillance purposes (e.g., looking for information about communities, events, or politics) were also more likely to recognize native advertising. Research by Taylor (2017), Amazeen and Muddiman (2018), and others suggests that the ‘persuasion knowledge’ that helps audiences approach advertisements with greater scepticism is blocked by some native advertising so that readers’ defences are lowered. By contrast, disclosure has been found to activate persuasion knowledge and increase awareness that sponsored content is advertising (Eisend et al., 2020). Awareness of adverting status provides some ‘inoculation’ against persuasive effectiveness. Recognition of native advertising ‘motivates counterarguing as a coping mechanism in the persuasion process’ (Amazeen and Wojdynski, 2018: 239). Wojdynski and Evans (2016) used eye-tracking methods to assess which disclosure position users were more likely to notice, finding that positioning within articles was more effective than disclosure at the top of articles, the most common placement position used by publishers. Research subjects had higher recognition

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for labelling using more explicit and familiar terms such as ‘advertisement’ and even ‘sponsored content’ over more ambiguous phrases such as ‘presented by’. Howe and Teufel (2014) found that consumers who read a sponsored content article online were less likely to report having noticed advertising on the page than those who viewed a page with a banner ad. Pasandaran and Mutmainnah (2020) found participants activated their news schema instead of advertising schema when exposed to native advertising: overall, 23 per cent of participants could recognise NA, 50 per cent were able to recognise commercial NA, and around 10 per cent identified political and social NA. Wu et al. (2016) found that priming study participants about the nature of sponsored content and how to identify it made a difference, but that, unprompted, readers were alerted only when branded content was poorly matched to the news outlet. Even with disclosure, 56 per cent of participants failed to recognise the NA content as advertising (An et al., 2019). Boerman et al. (2012; 2014) found disclosure increased critical consumer attitudes towards sponsored content, and the brands utilising it, but increased brand recall. Krouwer et al. (2017) found that disclosure recognition did not lead to negative ad evaluations, but increased brand presence did. Amazeen (2019) found participants were more likely to perceive the commercial nature of native advertising when it had a hard news orientation, independent of their informational news use motivation levels. A meta-data analysis of 61 such papers on the effects of disclosure (Eisend et al. 2020: 344) found that ‘disclosing sponsored content reduced brand attitudes, credibility, and source evaluation but increased brand recognition, persuasion knowledge, resistance, and attention’. This study usefully highlights the range of factors and the moderating variables affecting user responses, including age, gender, whether research participants were students, and cultural background, noting that ‘Comparing effects between samples in Europe and the United States is important because of differing regulations regarding disclosing sponsored content (Boerman et al., 2018), and thus, potentially, people’s familiarity with and responses to disclosures’ (Eisend et al., 2020: 349). Yet contrary findings, and contextual differentiation, means some key questions remain unresolved. Does user recognition of advertising deter or encourage engagement with content, and elicit favourable or unfavourable attitudes towards content, sponsor and publisher? Edelman and Gilchrist (2012) found that participants were substantially less likely to click sponsored search engine results that were labelled as a ‘paid advertisement’ compared to ‘sponsored link’ or ‘ad’. Some native advertisements are regarded as having higher information value than traditional ads, yet Lazauskas (2014) found only 24 per cent of readers scrolled down native ad content compared with 71 per cent for normal editorial. Two-thirds of readers have felt deceived upon realising that an article or video was sponsored by a brand, while over half (54 per cent) said they did not trust sponsored content (Lazauskas, 2014). Kim et al. (2019a) found that participants exposed to native advertising formats (versus display advertising) had more favourable attitudes towards the ad, the brand, and purchase intention, while Kim et al. (2019b) found negative effects when NA was placed alongside banner advertising. Researchers have examined the impact of knowledge of sponsorship on attitudes towards the communication, the brand, and the publisher hosting the branded

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content. Iversen and Knudsen (2019) found a small loss of trust from users of political news on sites that included sponsored content from partisan sources. Amazeen and Muddiman (2018) also found that presence of sponsored content on news sites reduced the credibility of publishers for users. Across experimental research, Howe and Teufel (2014) find that user recognition of native advertising had no effect on their estimation of a news website’s credibility. However, Amazeen and Wojdynski (2018) find that readers who recognise an online article as native advertising have less favourable opinions of the host news publisher, while Amazeen and Muddiman (2018) argue that both legacy and online news publishers damage their brand reputation through native advertising. Transparency is beneficial for publishers – ‘when ad recognition was activated, disclosures with greater perceived levels of sponsorship transparency reduced the amount of general counterarguing as well as the unfavorable attitudes toward both the message content and, especially, the publisher’ (Amazeen and Wojdynski, 2018: 239). The pattern of consumer responses to native advertising identified by research presents a paradox to marketers and publishers: By choosing to be more ethical or forthcoming in disclosing a message’s persuasive nature, they increase the likelihood it will be recognized as an ad, which would undercut its effectiveness. However, if they choose to be less transparent, advertisers and publishers run a greater risk that those consumers who do recognize the ad will perceive it as being deliberately deceptive, which would lead to stronger negative reactions. (Amazeen and Wojdynski, 2018: 230) Overall, the user research points to tensions between interests, findings which are at odds with some industry discourses of alignment between marketer, media, and consumer interests. For marketers and media, ‘disclosure increases the likelihood of criticism of the brand, message, and source’ (Eisend et al. 2020: 364). Yet if there are incentives to disguise NA, the findings provide a contrary pressure on regulators to strengthen the disclosure of NA in ways that go beyond the more flexible and discretionary approaches some regulators have so far adopted.

Children and branded content identification The research evidence that there are significant problems of identification among adults has even greater significance when applied to consideration of the communication rights and needs of children. There is extensive research and ongoing debate concerning the ages at which, and circumstances in which, children can recognise commercial messages. In addition, rapidly evolving forms and formats for communications involving brands require ongoing research and careful consideration of the applicability of existing research findings based on relatively more clearly demarcated advertising messages. The European Commission’s (2016: 2) Study on the Impact of Marketing through Social Media, Online Games and Mobile

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Applications on Children’s Behaviour found that ‘online marketing to children and young people is widespread, and that the various marketing techniques used are not always transparent to the child consumer’. As a discussion paper for UNICEF on children and digital marketing states (Nyst, 2018): Some marketing techniques fall into regulatory and policy gaps concerning ethical advertising practices online. These techniques are designed to camouflage advertising in editorial content, videos, games, and social networking, and use relationships and social cues to catalyse purchases. Although such tactics may create a more relevant and seamless advertising experience for the consumer, they may also conceal the commercial intent of online content, particularly from children. Marketing to children is subject to detailed regulations in most countries, as special considerations apply. The capabilities to identify advertisements and recognise and assess promotional messages require developmental learning. Advertising literacy is generally regarded as emerging around age eight, although some researchers regard ten as more appropriate, with Rozendaal et al. (2011) finding that at this age, children’s understanding of the motivations behind various advertising tactics is becoming comparable to that of adults. Advertising directly targeting children under 12 years of age is permitted in the United States but restricted in most other countries (Snyder, 2011). The UK regulator Ofcom (2005) expressed a clear view in a position paper on EU product placement rules: In relation to news and current affairs, Ofcom believes that any use of product placement as a funding technique risks damaging audience perception of editorial integrity and due impartiality. In relation to children’s programmes, Ofcom accepts that there are unlikely to be ways in which transparency can be ensured. It recognises the reduced ability of children to distinguish between commercial and editorial content and acknowledges parents’ expectations that children should not be exposed to excessive commercialisation. In research conducted for the European Commission (2016: 3–4) study, children were found to have greater confidence in their abilities than capability in distinguishing advertising in online games: In the focus groups many children (11–12 years old) said that they found it easy to distinguish advertisements from other content, that they did not think that they were being influenced by the advertisements and that they generally perceived advertisements as the most annoying aspect of the Internet. However, when shown examples of advergames most of the children were not able to identify the advertisement features and did not appear to recognise the persuasive intent of the games. This indicates that children are likely to be more influenced by advertisements than they realise.

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The presence of advergames, embedded and contextual advertising in games available from Facebook, Apple, and Google, often took the form of a picture of the product, a logo, or product symbol as a link to more product information, as product placement or as an advertisement shown before, in the middle or after the gameplay. This illustrates the importance of addressing all forms of communications involving brands, not just those more narrowly designated as online advertisements. The analysis found that ‘the games generally lacked protective measures, such as ad breaks/ad alerts or guidelines that could help users to distinguish the advertisement in the game’ (European Commission, 2016: 3). Disclosure and identification are key issues for industry/regulators, but focus on these can detract from the issues of greatest public concern (which in turn influence politicians/policy-makers). These are concerns about ‘influence’ and about the promotion of products and services that are unsuitable. For instance, at issue in influencer marketing is not just how IM is done ‘responsibly’, and with suitable disclosure, but about the capacity for ‘irresponsibility’. The focus on creating conditions for ‘good’ influencer marketing is in tension with broader concerns about influence that are not remedied or assuaged by, for instance, clear labelling or removal of claims that breach advertising codes. These are most prominent in relation to ‘influence’ on children, but also in relation to goods and services on the borderlines between unsafe/unsuitable, especially in relation to health, nutrition, beauty, and in the impact and implications for mental health and well-being, (self-)identity, and lifestyle choices. One in five influencers cover lifestyle as their main topic, including fashion, beauty, travel, parenting, and food and drink (Guthrie and Waddington, 2019). These are always issues about the power and influence of communications and of popular culture. These ‘content’ issues (and ‘expert’ endorsement) are evident in the ASA (2019a) ruling on posts about ‘weight loss gummies’ featured on the Instagram pages of Team v24 and Georgia Harrison. The posts were clearly disclosed as a ‘paid partnership’, but the ASA objected to the absence of required nutritional information and found the diet product was promoted in an irresponsible manner. In another ruling, the ASA (2019b) found that claims in the adverts (Instagram sponsored posts) for Boombod did not accurately reflect the relevant health claims and so breached the CAP Code.

Problem 2: Media integrity Protecting consumer welfare is a clear principle for advertising self-regulation and a statutory requirement for some regulatory agencies. The protection of qualities of media provision is comparatively weak. We have seen that the statutory regulation of broadcasting and related audiovisual can include protection for editorial independence and integrity, but the governance of publishing, in printed media and online, is generally weak. The protection of media communications on the border between advertising and media is not only comparatively ‘weak’ in formal governance; it is challenged by the increasing normalisation of media–advertising integration, as discussed in Chapter 8.

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For critics, the fusion and confusion of journalistic content with advertising compromises media quality (Schauster et al., 2016; Bachmann et al., 2019). How, though, are the media qualities to be protected articulated, and assessed? With a listing that focuses more on informational content, Bachmann et al. (2019: 97) summarise criteria for media quality as ‘relevance, diversity, contextuality, and professionalism’. Native advertising, they argue, exists in tension with normative criteria for journalistic media: ‘considering that the content serves the advertiser’s rather than the public’s interest (relevance), does not convey diverse perspectives and opinions (diversity), does not place facts and opinions in a wider context (contextuality), and is not a result of independent reporting (professionalism)’ (Bachmann et al., 2019: 97). Here, first, the problems of media integrity can be approached by way of an example. In 2018, The Evening Standard was accused of proposing a deal with six major advertisers in the paper to secure ‘money can’t buy’ positive news and ‘favourable’ comment pieces following an investigation by online publisher openDemocracy (Cusick, 2018a). The Evening Standard is the sole evening paper published in London and is owned by Alexander Lebedev, Moscow-based oligarch, and run by his son Evgeny. Between 2017 and 2020 the paper was edited by George Osborne, Chancellor of the Exchequer in a Conservative-led coalition government during 2010–15. The investigation by openDemocracy revealed details of a £3 million deal between ESI Media, the commercial division of the Standard and Independent online, and six major companies. Each company would pay £500,000 to secure ‘money-can’t-buy’ positive news and ‘favourable’ comment pieces, among other promises. According to openDemocracy, the global tech giant Google was one of the two companies who signed up to a project called London 2020; another was the international taxi-app firm Uber. The conduct of the firm and contracted drivers was a major public policy issue, with the contract to offer services in London revoked for reasons including the lack of vetting of drivers and the risk to passengers, including incidents of sexual assaults by Uber drivers on female passengers. All these were matters of public interest, where the monopoly evening paper of the capital would be expected to exercise the highest editorial standards, including editorial independence from powerful sources. So, the charge of trading favourable coverage for payment was a very serious one. MP and shadow culture secretary Tom Watson said that the ‘cash for column inches” deal represented “a corporate fake news factory on a grand scale” (cited in Mayhew, 2018). The Standard responded by asserting that the openDemocracy article was ‘wrong’ and ‘inaccurate’ (Mayhew, 2018): editorial integrity and independence is always at the heart of everything we do and is beyond question. That’s why we have such a big and loyal readership. […] No commercial agreement would ever include ‘favourable’ news coverage. Like all British newspapers, the Evening Standard has valued commercial partners and works with them on specific campaigns for the benefit of our readers. […] editorial independence is and remains guaranteed in the contracts we sign.

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Jon O’Donnell, group commercial director at ESI Media, stated ‘[London 2020] will, as with all commercial content, be clearly identifiable as such’. In response, openDemocracy published an investigation into a concluded deal between the paper and Syngenta, the Swiss-based multinational agrochemicals and seed company. In 2017, the in-house ‘ESI Live’ events team secured a partnership worth upwards of £100,000 with Syngenta: A series of effectively one-sided public ‘debates’ on the ‘Future of Food’ was chaired by the then editor. Staff news reporters covered the debates for the paper, which heavily pushed Syngenta’s food technology credentials as a producer of genetically modified (GM) crop seeds. And crucially, positive news coverage of Syngenta and its pro-GM agenda was published in the news pages of the Evening Standard, with no indication to readers that this was part of a paid-for deal. […] Although the one-sided debate coverage was branded with the Syngenta logo, other articles published in the news section carried no branding. (Cusick, 2018b) One published article titled ‘Hungry for solutions: Scientists trying to satisfy London’s soaring demand for food’ ‘praised Syngenta, its laboratories, its net income, and the benefits of GM … It reads like a PR hand-out – with readers never explicitly told this was paid-for news’ (Cusick, 2018b). During the period of the partnership the newspaper also carried no reference to the widely publicised lawsuit Syngenta was facing in the United States, nor to ‘large scale lobbying being conducted by the firm over the potential changes in food laws likely to follow the UK’s exit from the EU’ (Cusick, 2018b). Such apparent correlation between paid-media partnership and editorial coverage links to the criticisms made by Oborne discussed in Chapter 8, although self-censorship is a notoriously difficult charge to demonstrate. It also links to centuries of criticism about the influence of advertisers on editorial (McChesney and Scott, 2004; Chapter 10). The paper asserted that no commercial arrangement would compromise editorial integrity to include ‘favourable’ coverage. However, this links back to the problems of editorial-advertising demarcation discussed in Chapter 7. Where a brand pays but does not exercise editorial control no disclosure is required by the CAP/ ASA. Where a media publisher claims to exercise editorial control, the reader need not be advised of the financial arrangement when they read and assess the article. Such a disclosure is required under EU law incorporated into UK law, yet the regulatory authority, the CMA, does not investigate and enforce the requirement on individual firms. The standards claimed by the Standard may or may not be exercised. A systematic content analysis would provide valuable evidence of editorial coverage, yet the commercial relationships and editorial arrangements are not obliged to be accountable or transparent. Even where payment is identified, in this case through investigative journalism, the issue of control is difficult to determine and relies on self-declaration by those with strong interests in denying control, especially in circumstances where non-disclosure would breach legal requirements.

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While the details of the arrangements are disputed, this illustrates the significant gap in UK regulations, which allow a third party to pay for editorial without that having to be disclosed, where editorial control can be claimed to remain with the publisher rather than the payer. Brand-sponsored content is in tension with normative criteria for media, especially informational media, that are rooted in democratic theories. The Evening Standard example highlights the potential of payment being used to influence public awareness and attitudes on public policy issues, matters of importance for democracy. However, this framing poses problems, too. It identifies core values to be protected, but the positive case for protection risks abandoning content that is not deemed valuable for democracy. A narrow definition and defence focused on news, even so-called ‘hard’ over soft news, risks evacuating the grounds to critique and challenge commercial speech across the wider expanse of communications and cultural expression. The same value, and governance, issues arise in debates on media ownership and pluralism, whereby some, including radical media reformers, delimit protection to news and information. Instead, a broader account is needed that incorporates cultural pluralism, cultural diversity, and plurality of voice, matters addressed in the third problem area discussed below.

Problem 3: Marketers’ power and share of voice Payment buys voice and with voice comes the capacity to influence. Marketers have a power not granted to any other section of society. They can pay for presence in communications to reach out to readers and viewers. In Communications (1976: 13), the critical scholar Raymond Williams writes, ‘[i]n commercial communications, control and authority is exercised via commodity logic: “Anything can be said, provided that you can afford to say it and that you can say it profitably”’. Williams added, ‘All the basic purposes of communication – the sharing of human experience – are being steadily subordinated to this drive to sell. […] The organization of communications is then not for use, but for profit’ (Williams, 1976: 11). Historically there have been limits placed on the exercising of this power. Societies have established regulations that set limits on the freedom to advertise. Media arrangements, technological conditions, and professional values have all contributed to setting limits on how, where, and to what extent marketing communications can appear in communication spaces and ad-carrying vehicles. All the conditions that have given rise to branded content (Chapter 1) have been alterations to conditions that together restricted branded content. Now, though, the power to pay for presence has extended beyond designated advertising and commercial space. In doing so, it threatens to undermine the expectations of editorial and aesthetic independence created through institutional values, practices, and reader expectations, as problem area two addresses. Those expectations may be characterised as archaic associations for declining media, such as newspapers, except that they exist in ‘new’ media, too, for instance in the criticism and concerns about authenticity and paid posts in influencer communications. Marketers are buying space that is ‘non-commercial’ in the sense that it is

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associated with speech, sound- and image-making that is not produced directly in response to or at the bidding of an actor that can exercise control by virtue of payment or transactional exchange. Yet, there are concerns beyond the erosion of qualities of editorial and aesthetic integrity, which concern share of voice. The extension of marketers’ power and voice into non-commercial spaces increases inequality in communication power. Such a concept as share of voice may appear inexplicable in a world of ever-increasing data, opportunities to speak and reach vast numbers of people in the hands of billions, even with billions more lacking such access. Yet, before we reach the aggregate level, it is relatively easy to identify how the ability to pay for voice can be problematic when the range of actual voices with reach and influence is in the tens or hundreds. To give one small example, in February 2017 the Birmingham Mail (Whinyates, 2017) carried an advertorial, ‘Why Handsworth Grammar School has been rated “outstanding”’, identified as ‘special features’. There is a perfectly valid news story here, an independent report by school regulator Ofsted into an outstanding grammar school. However, it is an entirely laudatory account that is controlled by the marketer. There is no space for voices other than the brand or those, like Ofsted, it chooses to include. Further, the ‘space’ that is being occupied here by that item is precisely one based on the notional independence of editorial voice. So, a piece of content and communication is moving from advertising to editorial space, and in doing so it affects that space because it supplants the more independent reporting voice that might have included other perspectives on the school, or indeed link to the paper’s other reporting of the Government’s grammar school policy, a matter of national controversy and so public policy interest. A self-laudatory advertorial on behalf of a marketer is common and unremarkable as such. The charge is that payment affects how matters of public policy, democratic concerns, are addressed. Such concerns are at their highest, arguably, when governments or leading political actors pay for presence. In another example, Simon Jenkins (2015) writes ‘Even the Guardian cannot be regarded as immune from such pressures. In March 2007 Labour’s short-lived Pathfinder scheme, involving dire housing demolitions in the north, was inexplicably eulogised in a Guardian supplement in return for an undisclosed payment from the government’. Most would agree on a broad hierarchisation placing greatest concern, and need for protection, on speech affecting people in their role as democratic citizens, and so the accuracy and quality of news and information that empowers them to act according to their own and others’ interests in civil life. However, the problems of marketers’ voice extends far beyond political speech, narrowly defined, reaching across entertainment and interpersonal communications. The division between the protection and regulation of political speech and commercial speech is at once important and disabling. It structures both practices (institutional, industrial) and governance. It structures, to varying degrees, both the agendas of dominant policymaking as well as media reform. With the implications of communication for democracy and for progressive political change rightly being the focus for reformers, commercial speech issues fall into a subordinate space. So as well as the broader arguments calling for a reconfiguration and re-conceptualisation of media

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reform issues, it is highly relevant to see how the two (political/commercial) intersect around the issue of paid content by governments, political parties, corporate businesses, and others seeking to influence opinion.

Branded content and broader problems of marketing/media This chapter, and book, focuses on the specific problems arising from communications being sponsored by brands. Yet, why that is problematic needs to encompass a much broader set of problems concerning advertising, media and communications, marketers as social actors, the entire system and social relations of production, promotion and consumption, and their consequences. This section can only summarise connected sets of problems of media and marketing but does so to seek to clarify and broader the framework for critique.

Capitalism and dataveillance The driving dynamic of the economic growth of social media platforms is the extraction and profitable exploitation of data. We now have powerful studies of this now dominant political economy in studies of surveillance capitalism (Zuboff, 2019) and data colonialism (Couldry and Mejias, 2019). Brands ‘work with the predictive and analytic capacities of social media to stimulate users to produce machine-readable data, which in turn augments a brand’s capacities to attune itself to cultural life’ (Khamis, 2020: 9). For Carah (2017: 386), brands use this cultural engagement and exchange ‘as a platform to leverage consumer participation in channelling life into databases’. The powerful actors have taken advantage of regulatory conditions, notably in the US from where many of the global tech giants grew. They have also invested enormous resources in lobbying and policy advocacy (Chapter 8). So, the regulatory field is influenced directly and indirectly by the stance taken by these more powerful actors whose share of economic activity provides pressures, incentives, and protection from politicians. The state of data management, privacy, and data protection in the UK adtech industry is laid bare in the drily worded but powerfully indicting report of the Information Commissioner’s Office (ICO, 2019). ‘The complex nature of the ecosystem means that in our view participants are engaging with it without fully understanding the privacy and ethical issues involved’; the ‘lack of maturity of some market participants’ and ‘ongoing commercial incentives to associate personal data with bid requests [mean that] [w]e do not think these issues will be addressed without intervention’ (ICO, 2019: 6). ‘For some market participants, these [laws/regulations] were at best not fully understood or at worst ignored’ (ICO, 2019: 15). On industry selfregulation, the ICO has ‘not seen compelling evidence that any of these initiatives are fully mature, would sufficiently address our concerns in their current state, or that the current market would adopt such measures voluntarily’. The technologies enable the ever more sophisticated sifting of communications, services, offers, and benefits to consumer ‘targets’ and the removal of messaging

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from those who are not valued by marketers as prospects – ‘waste’. Turow (2011; 1997) has examined the socially divisive processes and outcomes of this marketing system, including its effects on the kinds of media and communication services financed and provided. One of the expanding areas in branded content marketing is out-of-home (OOH). Branded content can be targeted and displayed in ever more sophisticated ways. Drivers can be identified by a car number plate so that a selected and targeted message is displayed as they drive by. This moves targeting and waste to new kinds of social interaction and visibility. The selectively of address that exists in advertising on billboard posters was powerfully analysed by John Berger (1972) and in subsequent critical social, cultural, and semiotic analysis (Goldman, 1992; Williamson, 1978). Branded content takes us beyond the time/ space limited formats of conventional advertising into forms of content provision whose advertising/content/service status is merged and indistinct. The social effects of targeted messages and services being played out across the spaces of social life and interaction, rather than principally in the more intimate spaces of our computer devices or screens in the home, has yet to be fully mapped, and critiqued.

Marketing and consumer society Critical political economists generally share broader, ‘classic’ critiques of advertising as the leading ideological agency for capitalism due to its role in promoting consumerism and possessive individualism, and for its regressive, stereotypical representations of gendered, racial, and other identities. Advertising has been examined as part of a system of communications that ‘engineers consumption to match production and reproduces the ideological system that supports the prevailing status quo’ (Faraone, 2011: 189). All those criticisms remain salient, but only in modified forms that take account of the complexity and contradictions of brand communications. Some brands have championed a range of progressive causes and challenged the ideologies sustaining social injustice. Some commercial brands have embraced ‘brand activism’, yet this is also intrinsic to the work of campaigning organisations; causerelated marketing is intrinsic to the purposes and identity of some organisations, such as the non-profit People for the Ethical Treatment of Animals (PETA), embedded throughout practices for commercial enterprises (the Body Shop, Lush), or a component in a more complex mix, such as vegan and cruelty-free products and brands within the corporate giant Unilever. The critiques of advertising and marketing have always been at risk of totalising accounts that extrapolate from the dominance of corporate and commercial marketers and fail to account for enterprises shaped to varying degrees by non-commercial or anti-commercial values and purposes. So the actual complex ecology of commercial, social enterprise, non-profit, public, and civil society organisations and networks involved in promotion must be incorporated. Some brands are making important steps across their own activities and using their communications, paid and unpaid, to raise awareness. Branded content can and does serve to promote progressive values. In Branding Diversity, Khamis (2020)

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examines the brand activism of Budweiser, challenging Trumpism, Gillette challenging toxic masculinity, Vogue making very belated but important steps to celebrate human diversity in fashion, and Patagonia moving beyond conventional forms of corporate social responsibility (CSR), to creating shared values (CSV). Brand activism ‘borrows from … social movements to contribute to the social production of the identity of citizen-consumers’ (Manfredi-Sánchez, 2019: 343). At the Cannes advertising festival in 2018 and 2019, key terms repeated from podium speeches were inclusion and unstereotyping. The global marketing giant Unilever committed to build on its #Unstereotype commitment to promote more inclusive representation and gender diversity in marketing through ‘multi-milliondollar content partnerships’ (Sustainable Brands, 2018). One involved Unilever brand, Dove, in partnership with Cartoon Network’s Steven Universe to create original programming involving the characters of the show ‘to educate and build body confidence amongst the next generation, helping to expand Dove’s reach to provide 40 million young people with self-esteem education by 2020’ (Sustainable Brands, 2018). Marketers’ power of voice has been wielded in femvertising (Akestam et al., 2017) to promote gender equality and challenge the barriers to the advancement of women, with campaigns such as Dove’s Like a Girl and original branded content such as Fearless Girl. The Fearless Girl bronze statue of a girl facing down a large bull, placed in Wall Street, was commissioned by asset management company State Street Global Advisors (SSGA) to promote the launch of its Gender Diversity Index of companies, for International Women’s Day in 2017. A celebrated and award-winning effort, this was also criticised as inauthentic if not hypocritical given the parent company State Street Corporation’s poor record in supporting gender diversity as a shareholder. Dove’s Like a Girl was another award-winning, emotionally powerful response to the fall in confidence of girls after puberty, challenging gender stereotyping. Here the messaging fit well with the brand’s purposes and values, albeit a subsidiary of the giant Unilever. Yet it also demonstrated the limits of ‘branded wisdom’ (Klein, 1999). As Emily Shire (2014) commented, ‘[i]t demonstrates real problems – femaleness as a derogatory statement, decrease in self-confidence as women mature – in a beautiful and clear way, but then pretends a corporate manufacturer of panty liners meant to “help you feel fresh ever day” can solve them’. A branded content video for ANZ bank tackled the rarer topic of economic justice, albeit with children to soften the message about gender pay inequality (AdNews, 2016). Racial justice has also been engaged with, and while the limitations of brand speech should be identified, so too should the value of brands contribution and those inside and outside brands advocating for this within politically polarised contexts such as Trump administration America. Yet, the limits of brand articulations are highlighted by critical scholars. Sobande (2019: 2739) identifies ‘how brands are attempting to market themselves as being “woke” in ambiguous enough ways that they neither explicitly state nor deny their stance on significant socio-political issues concerning racism, sexism, transphobia and interlocking forms of oppression’. The power to pay for communications can be exercised to produce important, socially valuable messages. New industry-supported organisations such as the

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Unstereotype Alliance and Conscious Ad Network are seeking to harness advertising for socially progressive purposes, creating codes of practices designed to address abuses. The Google and Facebook-led Coalition for Better Advertising, involving the IAB and other international trade associations, shares some of this agenda, although it is also a means to counter threats of statutory regulatory action. However, the power to pay for communications includes power to shape and control communications. All the issues on which brands can demonstrate and advance values can also be used instrumentally, opportunistically, and/or without merit. The accumulation of terms for appearing to be what you are not speaks to the growth of brand claims and criticisms: greenwashing, woke-washing, purpose-washing, and sport-washing. Of course, those criticisms are advanced from reactionary as well as progressive perspectives. The more profound problem raised by these brand practices is accountability. First, even where there are clear codes and rules on what claims can be made in advertising, their application is not clear along the advertising-editorial border. Sponsored communications, especially but not only at the pro-am end of influencer marketing, can make claims that are not identified or addressed by those enforcing advertising codes. Lines of accountability can be blurred and exploited along the transactional/communication chain by brands, marketing agencies, and communicators, or by those sharing or modifying messages. Next is the accountability problem arising from governance of communications. If PR supplied material about brands is used without payment, that is ‘earned media’ (or churnalism to use Nick Davies’ (2008) critical term). If it is paid and controlled by brands, it should be identified as such (depending on place of publication and national rules, etc). In between, we may not know or be able to determine brand/source influence from the content alone. The obligation to ensure any relevant brand relationship with published content is transparent and disclosed does not exist across formal media and advertising regulation, nor in the rules the agencies involved choose. Even where such disclosure rules are upheld ‘in house’, there is an accountability problem arising from the lack of independent verification. Finally, there is an accountability problem if there is a lack of sufficient, ready access to sources of authority that are independent of brands’ own communications or sponsored sources. Accountability requires a thriving, socio-culturally diverse, and pluralist media system. This links to other calls for accountability, such as Sobande’s (2019) calls for brands to ‘be held to account for attempting to market themselves as being concerned with issues of inequality and social injustice (woke-washing), including in ways that involve stereotypical representations, particularly when the brand’s actions do not indicate any sustained commitment to addressing such matters of injustice’. She calls for ‘more effective governing [through] regulatory frameworks that include understandings of issues concerning racism and sexism’.

Brands as patrons of arts and culture Brands have long been involved in the sponsorship of activities that have an independent existence, multiple sources of funding, and hence multiple influences. That balance can shift when there is a principal brand as sponsor who can exert

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greater influence and where the sponsored activity is itself created or shaped in accordance with the sponsor, a pseudo-event (Boorstin, 1962). With branded content, the brand is the patron who commissions the work itself. This funds the work of those involved in the creative production and circulation of content. The outcomes cannot be read off either in terms of aesthetic value, creative independence, or brand control. There are no grounds to celebrate or condemn such work in toto. This can only be done by examining these areas of concern in analyses of production processes, contents created, and user engagement, and building up from specific studies an account of recurring features. There are studies highlighting the tensions between modes of advertiser (patron) control in the production of advertisement with the modes of production of creative content based on greater autonomy for writers, directors, and producers. On the basis of such studies we are likely to have an account indicating the rich complexity of brand involvement. Brands advance causes and fund socially and culturally progressive work and workers, including voices and issues marginalised across media. Brand patronage can boost media pluralism and cultural diversity. The simplistic alignment of commercial funding with reactionary messaging, and public funding with progressive content, has been under assault from media developments, and within media analysis, for some time in all dimensions, including its poverty when applied as an evaluative template internationally. Branded content studies will continue to illustrate that the range and quality of work will not fit narrow, pre-set evaluations. Individual creative work will be good and bad, overly controlled in messaging, branding, and product placement, or adding creative value and voice, or, often, a complex and contradictory mix. What can be argued with more certainly is that the manner in which branded content is organised and financed will affect content in aggregate terms. The critical problem of brand patronage is not in individual outcomes but in the consequences of that selectivity for content decisions. This is the problem of marketers’ share of voice.

Inequalities The evaluation of brand-sponsored content must also be situated in the broader context of the consequences of all forms of financing media content and services for content, content/service decisions, access and inclusion. Sustaining media services by marketer funding can enable these to be available ‘free’ to users, and can fund innovation in services to improve consumer welfare over the longer term. The media ecology is increasingly divided into ad-free and ad-full services. The rich can pay to evade ads through premium subscriptions to audiovisual (Netflix, Disney, Amazon Prime), audio (Spotify), and so on. When they do, they usually encounter embedded advertising (Chapter 3), yet enjoy ‘non-interruptive’ services. As Borum (2016) puts it, ‘When consumers can pay pennies a day to avoid advertisements and receive premium features, they’re more than happy to jump at the opportunity’. When so many online and mobile services are financed largely or entirely by ‘native’ advertising, calls to restrict branded content must address the

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socio-economic and cultural implications. Reducing ad income is likely to increase inequalities in access to content and services, adding to deepening digital divides. These are issues that need careful consideration at macro, meso, and micro levels, but I would give two overall responses. First, the rebuilding of a 21st century separation principle needs to capture ad finance while protecting against ad influence. That is how advertising and sponsorship has been managed historically to balance advertisers, media, and societal interests. That is required today and discussed further in Chapter 11. Second, the limitations of a commercial ad-funded model for media, cultural production, and communication services requires the provision of publicly funded services. I join with those advocates of democratic media reform who argue that democratically accountable, public service media needs to be at the centre of provision (Chapter 11), but these are matters whose developed discussion needs more space than this book allows.

Conclusion Media–marketing convergence is advancing rapidly, yet remains conflict-ridden and contested. As this chapter has outlined, critical concerns go beyond issues of disclosure and consumers’ identification of marketing communications, to include concerns about the integrity of communications channels, editorial independence and artistic integrity for creative producers and consumers, and marketers’ influence and ‘share of voice’ in the communication spaces on which we rely.

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10 MEDIA AND MARKETING CRITIQUES Renewing the radical tradition

One of the great strengths of the critical political economy of media tradition has been its attention to the influence of advertising finance on the nonadvertising content of media. However, this needs updating so that it engages adequately with the full range of contemporary communications and media– advertising relationships. This is a topic I have addressed in previous work (Hardy, 2014; 2015; 2017), each time seeking to revise and update in the light of changing conditions, wider scholarship, self-critique, and fresh thinking. I do so again here. This chapter combines some of that review and mapping of approaches with further effort to update for contemporary conditions and analyses. It explores the strengths and limitations of political economy perspectives and offers guidelines for contemporary analysis and critique of marketer influences on communications.

Critical political economy and advertising studies The advertising industry ‘involves two interconnected systems of activity that are crucial to Western society’: systems of ideology and of media support (Turow and McAllister, 2009: 2). Critical political economists have made contributions to analysis across the full range of industry arrangements and practices, yet a distinctive contribution has been to address how advertising finance influences media content, provision, and access to communication services. Classic critical political economy (CPE) contributions examine advertisers’ influence on non-advertising content and media firms’ behaviour. The problems they identified are of central concern today, but critical political economy theory and analysis needs to be updated to deal with transformations in the ways marketing communications are produced and circulated within the changing dynamics of media–advertising relationships. DOI: 10.4324/9781315641065-12

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Critical political economy refers to approaches that examine and critique the processes and power relations shaping problems and inequities in the production, distribution, and consumption of resources. In media and communication studies, it forms a distinctive sub-field, articulated in writings from the 1970s onwards. Its central claim is that different ways of organising and financing communications have implications for the range and nature of media content, and the ways in which these are consumed and used (Hardy, 2014). Critical political economists generally share broader critiques of advertising (Chapter 9); my focus here is on another path of CPE enquiry that considers the consequences of media dependence on advertising finance and marketers’ influence on media content and on what range of content and services media provides. Such analysis of the relationship between media and advertising is where I argue CPE has made its most distinctive contribution (Hardy, 2014; 2015).

Affirmative and critical scholarship Critical scholarship must first be understood in relation to alternative perspectives. There was a period in the 1970s when radical Marxist and para-Marxist approaches had a structuring influence on pedagogy and scholarship in some emerging departments of media and communications studies, during a period of broader academic influence in social sciences and to a lesser extent humanities in the US, UK, and other Western systems. This occurred in a period of radical and Marxist influence in Latin America and in some of the emergent independent, decolonised states. Yet, radical approaches have tended to be relatively marginal to mainstream approaches. In Western communications scholarship, the dominant political perspective has been liberal pluralism. In such accounts, advertising has been a largely beneficial force. Ellman and Germano (2009: 680) distinguish a ‘liberal’ view of media history which ‘claims advertising has a positive effect on the media, highlighting how the revenues enable newspapers to be independent from states and political parties’. They distinguish a critical perspective, which in their account is associated with French historians of the Annales school. This ‘regulatory view … argues that media may distort their coverage to accommodate advertiser concerns, even claiming that excessive commercialism in news and media content weakens the participatory foundations of democracy’ (Ellman and Germano 2009: 680). Another division, too crude to serve as more than an entry point but nevertheless salient, is between critical and affirmative research. This may be mapped across advertising and media studies in general, but it is more relevant for this book to focus on branded content. Affirmative-tending research is characterised by support for or alignment with goals of improving marketing effectiveness for branded content and profitability for dominant commercial media and marketers. The majority tradition in business and marketing research follows industry agendas to address questions of effectiveness in implementing marketing strategies. Becker-Olsen (2003) found brand-sponsored content improved consumer purchase intention and disposition towards brands compared to banner ads. Fulgoni et al. (2017) discuss industry research showing higher reader

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engagement with sponsored stories over display ads and call for time-spent metrics to be included in evaluating branded content impressions. Another strand of media economics and business research examines branded content as a necessary response to challenges for news publishers. Some of this literature acknowledges dis-benefits but argue for the economic necessity of sponsored content to fund directly or cross-subsidise journalistic purposes, and to aid news publishers in challenging market conditions, including their relationship with platforms (Watson et al., 2018). Another strand draws variously on organisational sociology, management, and culturalist traditions to align with managerially defined discourses of innovation against traditional resistance. Here, separation norms are recast as defensive moves by professional elites and the embrace of marketing as unavoidable, innovative, and responsive to market demand and users. For instance, Deuze (2005) regards journalists’ defence of editorial integrity against marketers (the firewall) as part of a conservative ideology to resist change and welcomes greater accommodation and collaboration with marketers. Certainly, analysis and understanding of changing perceptions among practitioners is vital and valuable. Scholarly alignment with the perspective of selected actors or stakeholder interests may also be perfectly justifiable, but should be reflexively acknowledged. Research should aim to explicate but not merely replicate discourses that engage with ‘resistance’ or adaptability to change. Such reflexivity necessarily involves and requires greater dialogue and engagement across critical and affirmative research.

Advertising influence: Critical approaches Classic CPE contributions examine advertisers’ influence on non-advertising content and media firms’ behaviour, with debates on the salience of instrumentalist and structuralist explanations. Instrumentalist explanations focus on the intentional actions and behaviour of actors who seek to control communications. These may range from marketers’ efforts to shape specific content or to influence the editorial environment, to efforts to influence the broader orientation of media firms’ output and their allocation of resources for telling stories and reaching particular audiences. Numerous accounts such as Soley (2002) and Bagdikian (2004) examine instrumental power in the form of marketers intervening to censor or shape media content. Bagdikian describes how Proctor & Gamble took action against outlets that breached its policy, restricting reporting that ‘in any way further the concept of business as cold [or] ruthless’ (Bagdikian, 2004: 239). Procter & Gamble also would not allow its advertising in any issue of a magazine that included reporting on ‘gun control, abortion, the occult, cults, or the disparagement of religion’ (Baker, 1994). Other studies have assessed advertisers’ use of economic pressure and the threat of or actual withdrawal of advertising as a means of influencing media coverage and the extent of acquiescence or resistance by staff (Nyilasy and Reid, 2011). Warner and Goldenhar (1989) found that an editorial bias (suppression of news on tobacco health risks) increased in magazines that benefited from the shift in spending of tobacco advertisers in the wake of the 1971 US ban on advertising tobacco on TV. Political economists insist on examining interrelationships between corporate media, advertising agencies, and big business. For

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example, the tobacco giant Phillip Morris held seats on News Corporation’s board, while News Corp. head Rupert Murdoch remained on the Morris board for 12 years. The pharmaceutical giant Pfizer had directors on the boards of Time Warner, Viacom, and Dow Jones. Such corporate interlocks indicate the ‘continuing symbiotic relationship between news, advertisers, and advertising’ (Bettig and Hall, 2012: 165; Bagdikian, 2004). Instrumentalist interventions by marketers certainly continue, as discussed below, yet a rival structuralist explanation proposes that advertising more usually operates as an ‘impersonal force’ (Curran, 1986) created by the cumulative decisions of advertisers seeking the most cost-effective vehicles to reach target consumers, thus creating a source of finance that is unevenly distributed across media. Advertising subsidy functions as a de facto licensing system, determining which ad-dependent media have the resources to survive and thrive. One basis for structuralist explanations lies in economic analyses of ad finance, whilst another is rooted in historical scholarship that considers how the professionalisation of marketing nevertheless resulted in a shift to less politicised and more ‘neutral’ decision-making about advertising effectiveness, as media planners relied more heavily on quantitative data over subjective judgements (Curran, 1978; 1986). Advertising influence can be impersonal, too, in that the ‘licensing’ effect arises from the innumerable decisions of individual advertisers: Advertiser influence is so built into the market context that not only is it often difficult to prove, but advertiser influence frequently occurs without the advertiser’s inducing it by any specific act, sometimes even without the advertiser’s wanting it. (Baker, 1994: 103) The implications of the uneven distribution of commercial subsidy for media serving poorer, ethnic minority audiences in the US are explored by Gandy (2000: 48; 1982; 2004) who finds: ‘[t]o the extent that advertisers place a lower value on gaining access to particular minority audiences, those who would produce content for that segment will be punished by the market’. Accounts such as Herman and Chomsky’s propaganda model combine structuralist and instrumentalist explanations with advertising finance amongst the five ‘filters’ that shape what news content is published by encouraging media to become advertising-friendly in order to compete for advertiser patronage (Herman and Chomsky, 2008/1988: 2, 15). Instrumental and structural are different kinds of influence that may operate in conjunction, and be mutually reinforcing. For instance, the journalist Ian Jack (2015) discusses how the Observer’s opposition to the UK government over what is known as the Suez Crisis in 1956 led to ‘patriotic’ brands not wishing to be associated with a ‘treasonous’ paper (instrumentalist). The paper lost some older readers who condemned the paper’s stance, and the paper’s criticisms of Israel also lost it a formerly strong Jewish readership, but attracted new readers; yet for advertisers these ‘were of the wrong kind – students, not nearly as affluent as those they replaced’ (structuralist).

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For Baker (1994: 44), the influence of advertising on non-advertising content can include favourable editorial coverage of advertisers’ products and corporate interests, creating an editorial environment conducive to marketers’ promotions, favouring higher-income audiences, and reducing partisan or controversial content that may divide or delimit target audiences (Baker, 1994: 44). Advertising favours content conducive to and connected to marketable goods and services and to disfavour content valued by or useful to poorer groups in society. The level of economic dependence on advertising revenue has always been a key factor shaping the structure and content of different media. Baker (1994: 45–9) and Rinallo and Basuroy (2009) usefully summarise factors that can affect the extent on advertising’s influence within a given media outlet. These include the level and kind of economic dependence on advertising, whether widely distributed amongst many advertisers or concentrated on individual advertisers or organised groups. Advertising influence then depends on such factors as economic dependency: the proportion of income derived from advertising; reliance on particular advertisers; and wider market conditions. Another factor is the acceptability of advertising influence on content decisions (and the ‘cost’ of public disapproval arising from knowledge of influence), which varies according to the media institutional arrangements and user expectations. When this ‘cost’ is internalised by media managers and workers, the influence of ‘professionalism’ may act to resist advertiser pressure, with ‘accepted industry practice’ another factor influencing behaviour. Consumer expectations and awareness of ad disclosure and ad separation from editorial are other, increasingly significant factors. Finally, Baker includes the implications of conglomeration, citing examples of advertisers applying pressure on one part of the conglomerate’s business in order to influence another.

Challenges to political economy approaches The critical perspectives discussed above have come under criticism from sustained efforts to displace CPE within self-styled ‘new’, or ‘critical’, media industries studies (Havens et al. 2009; Havens and Lotz, 2012). Three overlapping approaches have emerged: ‘convergence culture’ (Jenkins, 2006); ‘creative industries’ (Hartley et al., 2013); and ‘critical media industries’ research. These differ in the degree to which a critical mantle is advanced, but have in common an anchorage in cultural studies and repudiation of more explicitly Marxian or anti-capitalist critical work as rigid, reductive, and outdated. I refer to these as culturalist media studies (CMS). At a broad level, critical scholarship that draws on Marxist, anti-capitalist, and radical democratic theory is criticised as offering crude and reductive accounts of media and creative industries. The CMS approaches place justified analytical emphasis on complexity and contradiction in analysing the practices and positionality of media workers. Yet all three perspectives advocate adopting a more positive account of capitalist accumulation as a mechanism for cultural innovation, diversity, and empowerment. This amounts to a repositioning towards a more affirmative account of commercial media provision and arrangements in what I call market pluralism. Their accounts of marketing communications pull away from forms of criticality associated with the disparaged ‘Marxist’

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scholarship and towards either more descriptive or more positive evaluations. For instance, Havens and Lotz (2012: 42) argue: Now we find our entertainment content again infiltrated with sponsored messages and product placement in addition to pods of commercial messages. This product placement seemed quite jarring and unnatural in the early 2000s, but by the time you read this, it, too, might seem unexceptional and quite natural. They describe how following the introduction of advertising between programmes in US TV, ‘it became unnecessary to integrate the goods into the program in some way, as viewers quickly came to understand the commercials as separate from the content of the shows’ and state, ‘[g]iven this history, perhaps it is somewhat surprising to witness the return to older strategies with the increasing prevalence of product placement and integration in the last decade’. They express concern that certain types of content may be favoured, ‘which in the long term might curtail other types of programming’, but this is followed by paragraphs of reassurance. Advertisers intervene less directly than in the past; media creators ‘must negotiate a fine balance with both viewers and advertisers’ (Havens and Lotz, 2012: 117). Critical political economy is critiqued as offering a macro, aerial view of media industries, by implication broad-brush and crude. This is contrasted with a closer, ‘helicopter’ level view offered by new studies, sustaining richer and more nuanced evaluation of practices, including advertising influence (Havens et al., 2009). In their ‘critical media industry studies’ analysis of social media entertainment, Cunningham and Craig (2019: 264–5) celebrate ‘the entrepreneurialism of creators [who] harness the commercial platform features and user affordances available on and across multiple platforms through programmatic advertising and influencer marketing’, as well as traditional IP revenues, fan funding, and merchandise. The authors are right to reject what they posit as crude binarisms of creativity and commerce, and to highlight the significant advance for diversity and inclusion across emergent digital content production in which commercial funding is an integral part. My argument is not that the new sources and uses of advertising should be condemned, any more than simply celebrated, although we may expect self-styled critical media studies to do more than merely endorse them. Cunningham and Craig (2019: 268) describe the ASA’s requirement ‘that creators disclose when they are being paid to promote products, brands, or services’ as ‘onerous’. In an oblique argument, they express the fear that policies and regulations, including measures to ‘thwart misleading advertising practices and prevent labor exploitation’, may be subject to regulatory capture favouring corporate players and platforms, thereby ‘suppressing creator agency, innovation, and entrepreneurialism’ (Cunningham and Craig, 2019: 276). Advocating the liberalisation of advertising disclosure rules is common across ‘affirmative’ scholarship and commentary, but it deserves more explicit elaboration and justification here. We can identify gaps and deficiencies across scholarship in a generous manner, acknowledging the contexts and contribution of particular researchers’ work, while highlighting the need to address new conditions and data, neglected concerns, and

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promising insights. Doing so is what I mean by regarding CPE as necessarily a reflexive, continually revising approach. However, the critiques made in the CMS literature above go further, seeking to persuade readers that CPE has inherent, insurmountable limitations: economism, Marxist influence, and insufficiency in social theory. Researchers are warned that CPE represents an exhausted tradition, of limited value or contemporary salience (for review, see Wasko and Meehan, 2013; Hardy, 2016). The culturalist critique makes valid points but the attack is lopsided, and CPE is misrepresented. My argument (Hardy, 2014; 2016) is that, while this culturalist scholarship is valuable, not least advancing necessarily close, rich, and careful studies of communications practice and practitioners, it offers a problematic evaluation of media and marketing derived from its affirmative reading of shifts towards greater consumer empowerment under capitalism. The intensification of marketing communications within media content has been accompanied by largely uncritical responses from academics, including within the CMS literature. The critical political economy tradition is needed here for its greater attention to power asymmetries under the structuring influence of capitalism, and for its attention to regulation and governance, not least the weakening of protections designed to prevent advertisers influencing content. This chapter argues that ongoing updating and revision of critical scholarship is needed, but that this can build on and integrate work from within as well as without the critical political economy tradition.

Frameworks for analysis I have proposed a framework for analysis of marketers’ influence (Hardy, 2014; 2015) that seeks to map the factors that tend to strengthen advertiser influence on media communications as well as countervailing forces that can serve to mitigate or contest advertiser influence. Such an approach seeks to bring the insights of earlier accounts into a more appropriate framework for examining emergent practices in convergent media. It proposes a broader and more open analytical framework than those derived from mass media influence (radical functionalism) or reception (manipulation). To do so, it incorporates political economic dynamics, regulatory contexts, work cultures and practices, as well as multiple sites of agency and user interaction. This chapter section summarises but also develops that framework in the context of emergent trends in advertising and their implications for analysis. Studies of how the various agents operate and reflect on rules of exchange, including automation, can better illuminate how contemporary media–advertising relationships are produced and negotiated. Intermediaries have always existed between marketers and media in such forms as multi-agency creative work, media planning, and buying. The digital era has added to the chains of intermediaries particularly through automation. As key examples of this, the growth of real-time bidding (RTB) and programmatic advertising show the rapid evolution and proliferation of ad-management using computing technologies. Intermediaries between the advertiser and publisher now consist of agency trading desks, demandside platforms, ad exchanges and services from audience-targeting firms, to

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verification and fraud prevention (World Federation of Advertisers, 2014). As a result, analyses of advertiser influence on media need to take account of more complex attenuations of power, as agency work spreads across digital advertising networks and into automation, including ad content recommendation engines used to place branded content onto publishers’ websites. Granting that earlier accounts engage with instrumental and structural explanations of power, such approaches need to be extended to incorporate more complex networks of actors and processes of automatisation. For example, there is scope here to draw selectively on aspects of Actor-Network Theory (ANT) in examining the involvement of human and non-human actants in advertising networks, while sustaining critiques of ANT’s relative neglect of the temporality, wider power dynamics, and social consequences of networks (Couldry, 2008). More synthesising critical scholarship might also draw on insights from ‘new institutionalism’, ‘convergence culture’, and media industry studies on the cultures, practices, and governance of institutions, individuals, networks, and groups. These themes are further developed in feminist, Marxist, and culturalist studies of digital labour, precarity, work practices, and performativity (Fuchs, 2014). Greater attention to work cultures helps expand an account of governance, including how formal regulation and informal rules influence commercial integration. While the radical tradition highlights key problems arising from media dependence on advertising finance, investigating and challenging these problems persuasively requires the examination of the configuration of influences in a more dynamic and open manner. Critical work needs a revised mapping of the main factors that tend to strengthen marketers’ influence on media and communications services, as well as a new mapping of countervailing forces, in order to aid more open interrogation of marketer influences operating in specific instances. Here, I draw on Curran (2002) in seeking to identify for media–advertising relationships what that essay considers for media in general. My focus is on the power of marketers to influence editorial, operational, or strategic decisions by communication providers in ways that favour marketers’ messages and interests. For each of the factors identified below, we need to consider a structural dimension (economic), sectoral dimensions (institutional cultures shaping relationships in how communication services are organised), and behavioural dimensions (interactions and relations between specific actors, such as particular brand marketers, agencies and media firms, and computer systems). We need to consider specificities of firms, forms, and formats, which have different norms and expectations influencing behaviours and which together form the institutional and cultural contexts. In 2020, marketers used the affordances of adtech to exercise instrumentalist control. Advertisers used programmatic advertising technology to block ads from appearing next to stories that mentioned the coronavirus pandemic (Sweney, 2020). The article describes how UK newspapers faced losing £50 million in digital revenues as advertisers used keyword blacklists, whereby the presence of words such as ‘attack’ or ‘death’ would ‘automatically stop ads running in potentially problematic stories that feature them’. While published on 1 April, this was

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no April Fool’s story, nor was it awarded the added profile and reach of being carried in the print edition, and was only published online. The decision to disassociate from ‘negative’ content has editorial as well as economic effects, as a long history of market censorship by advertisers shows (Soley, 2002). Yet the involvement of technology makes for a more complex account of human decisionmaking, extending (and attenuating) through automated systems designs such that neither classic instrumentalist nor structuralist accounts suffice. Earlier studies of factors affecting advertiser influence on media tended to regard media and advertisers as separate entities, whereas we must now examine integration across corporate ownership, practices, and norms. To update studies, we can include the range of actors and processes through which governance arrangements are produced and sustained across material-discursive spaces: Level of economic dependence on advertising finance and support Formal regulatory arrangements (legal-regulatory authorities) Industry self-regulatory arrangements (sector(s)-wide; organisation-level) Professional norms of relevant media workers and managers Behaviour and influence of media owners Influence of relevant institutional traditions of media–advertiser relations. Influence of users (direct and indirect, including anticipated consumer responses) Influence of other stakeholders across policy networks and in communications spaces (including media reporting and commentary) 9. Norms and practices across all intermediary agencies 10. Automated processes and human–computer interaction associated with all of the above 1. 2. 3. 4. 5. 6. 7. 8.

The main factors that tend to enhance advertiser influence on (non-advertising) media content and services are: (1) the commercial orientation of the media entity and corporate level promotion of advertising revenue maximisation; (2) the media entity’s dependence on advertising finance; (3) the level of competition to attract marketing finance and the influence of competitor behaviour; (4) corporate-level relationships with marketers and marketing agencies; (5) institutional/operationallevel organisation and promotion of advertising integration (technical, labour, content creation, media–marketer interactions and transactions); (6) professional/ pro-am normalisation of advertising integration; (7) user involvement, user support/acceptance of advertising integration; (8) regulation and governance arrangements that are permissive of advertising integration. These should be addressed together with the main factors that constitute countervailing influences: (1) the non-commercial orientation of the media entity (public service, community, radical, etc.); (2) low dependence on advertising finance; (3) market conditions favouring media sellers rather than advertising buyers; (4) corporate/institutional level separations between media and marketers; (5) professional and pro-am practices, cultures, and norms resisting advertiser influence; (6) users’ actual/ predicted responses in regard to their capacities as consumers and influential publics;

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(7) governance and regulation restricting advertising integration; and (8) civil society action and influence. CPE attention to advertising as a support mechanism for media remains of central importance, but it needs updating as ‘possibilities for the direct influence of content keep changing’ (Leiss et al., 2005: 120). The classic CPE frameworks conceive of marketers as external to media firms in ways that no longer fit emergent patterns of corporate and operational convergence of media and marketing. Where postmodernists have tended, in the pre-digital past, to argue that the separation of media and advertising is irretrievable (Wernick, 1991), a revised radical approach can inform a more nuanced analysis of the conditions in which commercial communications and media content combine and influence one another.

Media integration and communication studies A multi-layered convergence is underway: a convergence of marketing communications and media across corporate arrangements, production practices and identities, cultural forms, and relationships with users. Media and marketing communications are converging across digital platforms, communication forms, and spaces, with profound implications for academic domains as well as for industry arrangements and practices. The institutions and practices of advertising, public relations, marketing, and media are integrating. The field of communications has certainly begun to address this but the institutional and conceptual architecture lags behind developments. This next wave of convergence is something that media and communication studies is relatively illequipped to address. Advertising studies and public relations remain siloed, specialist sub-fields. Marketing communications and public relations have tended to be specialist subfields with limited overlap with the rest of the field. The overwhelming preponderance of academic output on marketing communications embraces ‘administrative’ rather than ‘critical’ research in Lazarsfeld’s (1941) terms, thus seeking to assist marketers in improving advertising effectiveness. When not explicitly affirmative, such scholarship tends to be descriptive, with normative-evaluative debate subsumed under managerial and operational concerns (such as minimising ad clutter or consumer resistance) or narrowed to ethical considerations. While media and advertising integration is addressed in mainstream economic and business literature, it offers limited articulation across the full range of dimensions that media studies grapples with, which include the economic, political, organisational, practice-based, ethical, symbolic, social, and cultural. By contrast, such broader articulation of media and advertising integration is addressed by two key traditions, critical political economy and culturalist scholarship. Culturalist approaches have emphasised people’s immersion in branding and brand culture, and turned away from what were regarded as crude, Marxian theories of domination. The culturalist critique makes valid points, but I have argued that the attack is lopsided. Critical scholarship is not wedded to presumptions of strong ideological effects or manipulation associated with mass media domination paradigms. Instead, it is distinguished by the concern to identify and address problems arising from

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the manner in which resources, including communication resources, are organised in social life, problems that are downplayed in culturalist accounts celebrating market provision. The radical tradition can be renewed by addressing the ways in which marketer power can be realised and undermined, challenged and contested. This requires analysis of practices, policy (including regulation and governance), and problems (the formulation of critique). The CPE tradition is guided by critical social theory to identify and address problems. The extension of advertiser power in the digital age, as well as its limits, cries out for further study and public discussion. Ambitions for critical scholarship must include gathering evidence for a persuasive case to influence public policymaking, defending space to carry out that work in the academy, and drawing on the strengths of strong student interest in these topics to help counter the threats to provide courses that are entirely framed within affirmative, pro-industry perspectives. What is needed is critical scholarship that is informed by the theoretical sophistication of culturalist media studies, that gives close attention to material practices, but that continues to ask and address larger, critical questions about the ways in which advertising shapes our communication environments. This requires ongoing engagement, synthesis, and development in scholarship. There are differences in the formulation and advancement of criticality, but that should be combined with a commitment to open enquiry, dialogue, and learning across all sources of knowledge and closer dialogue with shared efforts to understand communication practices and processes.

Conclusion This chapter has discussed and illustrated the challenges to revise critical political economy (CPE) approaches to media and advertising relationships so that they are adequate for the theoretical, methodological, and empirical investigation of contemporary media industries. Critical governance analysis has been advanced as a tool for integrated analysis of communications practices, environments, rule-shaping, and problems. This can provide renewed resources to address key questions asked by the radical tradition: how is advertiser power strengthened or countered across contemporary communications systems, and what are the consequences?

Bibliography Bagdikian, B. (2004) The New Media Monopoly. Boston, MA: Beacon Press. Baker, C.E. (1994) Advertising and a Democratic Press. Princeton, NJ: Princeton University Press. Becker-Olsen, K. (2003) ‘And now, a word from our sponsor’, Journal of Advertising 32(2): 17–32. Bettig, R. and Hall, J. (2012) Big Media, Big Money. Lanham, MA: Rowman and Littlefield.

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Couldry, N. (2008) ‘Actor network theory and media: do they connect and on what terms?’ in A. Hepp, F. Krotz, S. Moores, and C. Winter (eds) Connectivity, Networks and Flows: Conceptualizing Contemporary Communications. Cresskill, NJ: Hampton Press, pp. 93–110. Cunningham, S. and Craig, D. (2019) Social Media Entertainment. New York: NYU. Curran, J. (1978) ‘Advertising and the press’, in J. Curran (ed.) The British Press: A Manifesto. London: MacMillan, pp. 229–267. Curran, J. (1986) ‘The impact of advertising on the British mass media’, in R. Collins, J. Curran, N. Garnham, P. Scannell, and C. Sparks (eds) Media, Culture and Society: A Critical Reader. London: Sage, pp. 309–333. Curran, J. (2002) ‘Media and democracy: The third way’ in Media and Power. London: Routledge. Deuze, M. (2005) ‘What is journalism? Professional identity and ideology of journalists reconsidered’, Journalism 6(4): 442–464. Ellman, M. and Germano, F. (2009) ‘What do the papers sell? A model of advertising and media bias’, The Economic Journal, 119(537): 680–704. Fuchs, C. (2014) Social Media: A Critical Introduction. London: Sage. Fulgoni, G., Pettit, R., and Lipsman, A. (2017) ‘Measuring the effectiveness of branded content across television and digital platforms’, Journal of Advertising Research, December: 362–367. Gandy, O. (1982) Beyond Agenda Setting. Norwood, NJ: Ablex. Gandy, O. (2000) ‘Race, ethnicity and the segmentation of media markets’ in J. Curran and M. Gurevitch (eds) Mass Media and Society. London: Arnold. Gandy, O. (2004) ‘Audiences on demand’ in A. Calabrese and C. Sparks (eds) Toward a Political Economy of Culture. Lanham, MD: Rowman and Littlefield. Hardy, J. (2014) Critical Political Economy of the Media. Abingdon: Routledge. Hardy, J. (2015) ‘Critical political economic approaches to advertising’ in C. Wharton (ed.) Advertising: Critical Approaches. London: Routledge. Hardy, J. (2016) ‘Money, (co)production and power’, Digital Journalism 5(1): 1–25. Hardy, J. (2017) ‘Marketers’ influence on media: Renewing the radical tradition for the digital age’ in J.F. Hamilton, R. Bodle, and E. Korin (eds) Explorations in Critical Studies of Advertising. New York: Routledge, pp. 13–27. Hartley, J., Potts, J., Cunningham, S., Flew, T., Keane, M., and Banks, J. (2013) Key Concepts in Creative Industries. London: Sage. Havens, T. and Lotz, A. (2012) Understanding Media Industries. Oxford: Oxford University Press. Havens, T., Lotz, A., and Tinic, S. (2009) ‘Critical media industry studies: A research approach’, Communication, Culture and Critique 2: 234–253. Herman, E. and Chomsky, N. (2008/1988) Manufacturing Consent: The Political Economy of the Mass Media. London: Bodley Head. Jack, I. (2015) ‘Reporters hold their nose about advertising in newspapers’, The Guardian, 20 February. Jenkins, H. (2006) Convergence Culture. New York: New York University Press. Lazarsfeld, P. (1941) ‘Remarks on administrative and critical communications research’, Studies in Philosophy and Social Science 9: 2–16. Leiss, W., Jhally, S., Kline, S., and Botterill, J. (2005) Social Communication in Advertising, 3rd Edition. London: Routledge. Nyilasy, G. and Reid. L. (2011) ‘Advertiser pressure and the personal ethical norms of newspaper editors and ad directors’, Journal of Advertising Research 51(3): 538–551. Rinallo, D. and Basuroy, S. (2009) ‘Does advertising spending influence media coverage of the advertiser?’, Journal of Marketing 73 (November): 33–46.

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Soley, L. (2002) Censorship Inc. New York: Monthly Review Press. Sweney, M. (2020) ‘Newspapers to lose £50m in online ads as firms use coronavirus “blacklist”’, The Guardian, 1 April. Turow, J. and McAllister, M. (2009) ‘General introduction’, in J. Turow and M. McAllister (eds) The Advertising and Consumer Culture Reader. New York: Routledge. Warner, K. and Goldenhar, L. (1989) ‘The cigarette advertising broadcast ad ban and magazine coverage of smoking and health’, Journal of Public Health Policy 10(1): 32–42. Wasko, J. and Meehan, E. (2013) ‘Critical crossroads or parallel routes? Political economy and new approaches to studying media industries and cultural products’, Cinema Journal 52 (3): 150–156. Watson, S., Bell, E., Rashidian, N., and Hartstone, A. (2018) The Future of Advertising and Publishing. Columbia University Academic Commons. Wernick, A. (1991) Promotional Cultures. London: Sage. World Federation of Advertisers (2014) WFA Guide to Programmatic Media. http://www.wfa net.org/media/programmatic.pdf.

11 ADVERTISING AND MEDIA (REPRISE) Contesting normalisation

Media and marketing communications are merging. Their integration is arguably the next phase of convergence, following that of the convergence of mass media, telecommunications, and computing. The integration of media and marketing is occurring across corporate ownership, joint ventures, operations and practices, forms and formats, and relationships with users. Marketers like Red Bull have become broadcasters and publishers. Media firms have responded by offering their media vehicles for branded content, but also by setting up hybrid media–advertising agency units to create branded content themselves, such as the New York Times’ T Brand Studio and the Guardian’s Guardian Labs. Advertising agencies have moved into media content production, offering another route for marketers’ branded content. Increasingly, both commercial media and marketing firms recognise themselves as being in the same business, concerned with selecting and offering suitably engaging content to reach target consumers in the most cost-effective ways. Such media–marketing convergence remains conflict-ridden and contested, however. Critical concerns go beyond issues of disclosure and consumers’ identification of marketing communications, to include concerns about the integrity of communications channels, editorial independence and artistic integrity for creative producers and consumers, and marketers’ influence and ‘share of voice’ in the communication spaces on which we rely. This concluding chapter reviews themes and arguments but also extends analysis of how branded content is challenged and contested. If there has been a normalisation of branded content outlined in previous chapters, this final chapter considers the scope and prospects for contesting that normalisation. This chapter puts forward arguments and proposals for action, assesses prospects for reform, and likely scenarios for practices and governance.

Reviewing arguments The core argument of this book is that some branded content presents problems that are inadequately addressed in governance arrangements. Before advancing to DOI: 10.4324/9781315641065-13

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consider those propositions further, it is important to pause and consider objections and alternative perspectives. Branded content forms an important part of contemporary marketing communications, funds jobs, supports and encourages creativity, and is an integral feature of the media and communications economy and ecology. The vast majority of those engaged in branded content are supportive. There are full-throated supporters who are equally passionate and sincere about rooting out malpractice and poor practice. There are some who take a nuanced, complex stance on benefits and dis-benefits, on effective and ineffective, good and bad practices. There are young people, students, and others seeking to build careers across the media and marketing industries for whom branded content is integral to the world that must be learned and joined. Challenges to media technological innovations have often had greater impact and influence on their development and governance than they are credited for, yet the palpable march of innovation often makes those calls seem futile and misguided. Branded content is already so well established that calls to object, revise, and reset may appear as futile and forlorn as those that have greeted successive waves of media technological innovation.

Everything is promotional With internetisation and digitalisation, there has been a massive expansion of the communication activity that can circulate, the types of actors and numbers of actors who can engage in socially influential promotional activities, from self-promotion to the promotion of ideas, goods, and services. Brands can and do feature in everything from our dress, accessories, the images we share, and the conversations we have, unmediated and mediated. This promotional exchange and reflexivity supports the holistic definition of branded content by Asmussen et al. (2016: 10) as ‘any manifestation associated with a particular brand in the eye of the beholder’: The defining insight of this perspective is that the legal trademark or brand owner is not necessarily in control of the creation and/or distribution of content related to its brand. All kinds of stakeholders are able to create and distribute branded content – including but not limited to the customers or critics of a brand. This can be naturalised, even conceived in the language of power, democracy, and ‘participation’ (Fuchs, 2011). The definition reflects an all-encompassing perspective found in their literature review, yet was considered by only a minority of the 30 practitioners and experts interviewed, with most favouring the managerial conception. The holistic perspective is based on the recognition that the diffusion of opportunities to create and distribute digital content makes a perspective based on the extent of ‘control’ by brand owners insufficient. You might be a corporate brand manager and see a video on YouTube created by somebody outside your organisation and you might think, ‘this has nothing to do with my brand’. But if, for instance, a few thousand people

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associate it, for whatever reason, with your company then you have a case in which content was produced by an external stakeholder affecting your organisation’s brand, positively or negatively, whether you realise it or not. (Asmussen et al., 2016: 10) So, this holistic definition highlights that brand communications extend beyond brands’ control to the communicative activities of others and encompasses ‘any perceptible (e.g. visible) outward expression of the brand’ (Asmussen et al., 2016: 10). As well as the issues of control and constestation of brand meanings, this approach fits a recognition of the participation and ‘work’ of users in the promotion and circulation of brand communications. That is the focus of analyses of shareability in social media, as well as cocreation and user-generated content involving brands, but it can and should be extended much further to encompass all the ways in which brands are made communicative. How brands appear is a combination of controlled communications (advertising) and communications that include aspects beyond control. If a branded T-shirt represents some elements of control (the IP rules governing the licensing and display of logos), then the journey of that product, perhaps to a discount display in store, to the immeasurable variety of associations with its wear and wearers, illustrates a spectrum of control. Asmussen et al. (2016) identify two main limitations of the holistic definition. First, it goes far beyond branded content encompassing all marketing communications, products, and services of brands, and second, it provides no guide to effective marketing practice. To this a further key limitation can be added, which is that in going beyond brand control it removes control altogether. The proposition that branded content is any communication about or involving brands does engage usefully with the myriad ways in which brands circulate and are given meaning. Yet this also naturalises or occludes key elements of control, agency, and transaction. The key issue, however, is brand presence arising from a transactional relationship, as arises in paid ‘product placement’. So, we need a critical analysis that engages with cultural processes combined with analysis of power and control. We need to investigate how power relations are realised and altered in contexts that include the use of communication capabilities. The arguments of this book arise from the managerial definition of branded content (Chapter 1) because that introduces key criteria that distinguish some promotions, and promotional capacity, from others, namely payment, control, and through these power over resources and communication power. A critical approach is to reject an abstract theory of promotion based on communication channels and capacity (a medium theory) and instead investigate how power relations are realised and altered in contexts that include the use of communication capabilities. Promotion is everywhere and multi-level. BuzzFeed acceded to the wishes of some of its lead writers to allow them to promote themselves in other media, such as YouTube, and began using this also as a vehicle to extend branded content partnership deals and their reach. According to Digiday (Barber, 2019): BuzzFeed has since expanded opportunities for in-house talent with The Creators Program, in order to strike the balance of retaining top talent while

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also allowing them to build their own brands with personal YouTube pages and the like. […] In all, Creators Program has 36 personalities and has brokered 65 branded content campaigns this year, already double the number the program ran in all of 2018. The article notes that some former BuzzFeed writers have now disassociated from BuzzFeed. The intermingling and commodification of this self-promotion and corporate promotion is a rich topic for promotional culture analysis, yet the qualities of promotional communication examined need to be grounded in political economy. The key point for this analysis is how promotion is activated for brand promotional purposes, and how brands can use their economic resources to leverage communication power.

Is the merging of media and marketing fateful? Branded content is unstoppable. For many this contention may well run powerfully against the premise of this book, that branded content can and should be problematised. For the young especially, those seeking to navigate and find a place in the creative industries, the drive to know what is going on and how to survive and be part of it can be overriding. The argument of this book is not that branded content should be stopped. It is that some kinds of branded content activities generate problems that should be remedied. It is also the argument of this book that such remedies should be proportionate. Commercial communications provide great creativity and value. Branded content is good as well as bad. As this book has argued, the principal problems specific to branded content arise with the integration of marketing with media. The loss of principles of separation of marketing and media matters because that separation does more than protect consumers by helping them distinguish between ads and content. It underpins protection for the content itself, and the protection of users not just in their identity as consumers of marketing messages but as consumers and users of communications. It is important to stress that this is not a total, general critique of advertising. Culturalist approaches to advertising have emphasised people’s immersion in branding and brand culture, and turned away from what are regarded as crude, Marxian domination theories. These are characterised as rooted in a critique of consumer capitalism but focusing their displaced ire on advertising, to the detriment of a full understanding of the cultivation of demand and desire and the appropriation of value and meaning by people. Advertising serves as a target for an attack on consumer capitalism. ‘Sociological critiques of advertising are, in any event, really critiques of market society’, says McFall (2011: 93). Such an ‘anti-advertising’ perspective is articulated, but it is not representative of critical political economic scholarship and serves as a caricature, or chimera, to buttress (and obscure) alternative perspectives. The focus of critical scholarship is not blanket condemnation, but analysis of power interests and dynamics. The salient division is not between totalistic versus more nuanced and sophisticated

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analysis. We should all strive to be on the side of the latter. Rather, it concerns how problems are identified and evaluated and remedies considered and advanced. The central divide concerns the adequacy of resolving the balance of benefits and dis-benefits within capitalism, within industry self-regulation, and within governance arrangements. Critical scholarship is identified with advancing a crude dualism between commercial or non-commercial production (Banet-Weiser, 2012; Cunningham and Craig, 2019: 150–9). Whatever case for accuracy of the charge can be debated, it is not the argument of this book. Branded content is most certainly an agency of creativity, of meaningful engagements that cannot be defined or delimited within explanatory frameworks of commodification. The argument of this book does not hinge on divisions between, or assessments of value across, content and content production, which must be attendant to all the complexities and positionalities that might inform such judgements. Rather, the argument is first that payment and sponsorship should be disclosed and managed to serve the values and purpose outlined, which may be summarised as consumer and communication rights. Second, that however diverse may be the sponsors’ payment methods and relations, forms of influence, and types of content and outputs, these are ordered and concentrated through economic power. There are therefore special concerns about disclosure and management arising from the ordering and inequality of resources. This is not a crude version of Marxist economism. It does not argue that there is a preformed alignment of economic power, cultural expression, and influence. It does not argue that economic power, here the resource to pay for communications, is a sufficient explanation for communication flows and influence. What it argues is that the strengthening of the power to pay for influence is a matter of particular concern for democracy and cultural diversity because that resource is aligned with political and economic influence and is unevenly distributed. There is a powerful imbalance in the resources to fund effective public communications. Professional journalism promised to ameliorate that imbalance by producing communications according to values that serve democratic and cultural life, including accuracy, balance, and editorial independence from vested interests. Yet, branded content favours resource-rich, commercial sources, sponsor-friendly coverage, ‘best-selling’ stories, and soft news. The central dilemma of native advertising is that revenue gain comes at the expense of eroding reader trust and undermining core jobs for news media (Piety, 2016). It might be objected that calls to better identify, label, and ‘separate’ advertising forms will cut the resources needed to sustain a flourishing creative, diverse, participatory, democratic, and pluralistic media. Small independent filmmakers have relied on product placement for financing creative work. Independent media publications, including ones carrying radical and counter-hegemonic journalism, rely on branded content deals to sustain publications that would cease if reliant on the declining revenue from conventional advertising. Addressing and resolving these issues needs engagement, discussion, analysis, and action sector by sector. The qualities of flexibility and adaption that have featured in the advancing normalisation of merging media and marketing need to feature in counter-strategies that

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can build effective support for communication standards. Resolving the tensions surrounding advertising finance and control need to be worked through to win collective support for communication rights across practitioner and public stakeholders. Doing so requires engagement and deliberation, but it returns to core discussions on trade-offs to achieve a rich, plural, and diverse media. Brand-funded content should (and will) be a key feature of a diverse media ecology. Do we need to accept a lack of transparency, erosion of identification, as the price of that presence? Can those values of creative pluralism be achieved if the problems of branded content outlined in this book are unaddressed? I will add here several more key reasons why I would personally reject totalising critiques. It would be obfuscatory and hypocritical about my own imbrication in branding, as well as in the immense pleasure and appreciation of advertising. It seems deeply unappealing to condemn others’ investments in a branded world while evading my own. But I am also committed to engagement with industry and with all the actors, based on principles of mutual listening, learning, and respect. My work to lead an open research network, the AHRC-funded branded content network, and establish the Branded Content Research Hub, is based on commitment to dialogue and exchange. A totalising critique would be a barrier to starting such exchange, of course, but it is also very far from the analysis I would wish to offer based on that collaborative work. Industry perspectives should be recognised and considered in their complexity, as I have sought to argue in this book. There are enormous economic pressures, personally experienced, and ideological support for expansion of commercial speech. But there is also deep concern with ethics, some instrumental, but some altruistic and societal. My engagement is based on an educational ethic, that students and research are best served by making the greatest effort to understand the phenomena, and by a policy agenda which considers that there is value in any engagement concerned with doing things better, and that such micro-actions need not be dismissed even if we hold that much greater action will be necessary. The key questions I’d pose here are whether, over the coming years, some parts of the branded content industry will ask that more is done by other parts of the industry, and whether they will seek to differentiate along lines such as transparency and disclosure. The stakes are high, as the values in play are precious and volatile substances: trust, openness, permission, invitation, pleasure, interest, entertainment, and culture. At the heart of much debate are questions of trust. Native advertising has been described as ‘a rare win-win for the industry: more effective for advertisers, more valuable for publishers and more acceptable for users’ (Hammett, 2016). Michael Frohlich, CEO Europe, Middle East, Africa at Ogilvy Public Relations, said that people want honesty. Advertorials used to be a dirty word for us – but now we write when things are paid for or sponsored, it’s no longer a dirty word. […] Transparency is key, as well as honesty, so writing that something is sponsored and letting them know that is important as they are not stupid, they can see right through it. (Davidson, 2016)

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However, this study has shown how these claims are undermined by practices, flouted rules, user confusion, and at least traces of the ‘consumer cynicism for the format’ some feared (Hammett, 2016). The reputational damage for marketers and publishers arising from undisclosed ads, as well as from poor-quality ‘clickbait’ from content recommendation engines, may yet strengthen industry self-regulation.

Power shifts? The power dynamics explored in this book are certainly complex. Seeking, safeguarding, and balancing values of economic ROI, cultural reach and impact, brand messaging, credibility, and authenticity all shape the interactions between marketers, agencies, communication carriers, and creators. The forces and interests advancing commercialism or protecting culture are not neatly demarcated but often complexly combined, with advertisers articulating the need to balance brands and consumer interests, and offering qualified protection for media integrity, within the antimonies of industry discourses (Chapter 8). Power dynamics run through the tensions between brand patronage and control, the qualities of the media vehicle and creative resources brands seek to harness, the intermediary creative/commercial role of marketing agencies and other intermediaries, all within fast-changing, highly competitive environments. For many industry analysts, the rise of branded content is a response to an underlying power shift from advertisers to consumers (Donaton, 2004). In this account, branded content is responsive, and granted permission to exercise its acknowledged power, by the greater power of consumers. As Serazio (2013: 13, 12–14) argues, an espoused ‘myth’ of ‘an empowered audience gives marketers license to react defensively’. Donaton (2007) argues that consumers’ embrace of ‘pull’ branded content emboldened marketers: this gave advertisers permission to move more boldly in the direction of creating original content rather than just inserting their products in other people’s TV shows and films. Brands discovered they could bring content directly to consumers and that audiences would seek out and share work they enjoyed. Finding ‘little or no evidence of a backlash of any kind’, he concludes: ‘[t]o the contrary, younger viewers not only accept but expect the marriage of marketing message and content, and they will not only tolerate it but seek it out – if it delivers value’. This accurately anticipates the expansion, and general acceptance, of branded content. The greater choice and control over communications afforded to digital users, while stratified by economic resources and other access barriers, has undoubtedly been a shift of power from marketers to consumers. Yet, such accounts rely on a misleading disavowal of continuities in marketer practices and marketer control of communication interactions, and, as this book argues, the extension of marketers’ control over communications content and environments. More generally, attention to the shifts of power between marketers and consumers that undoubtedly result in ever-increasing challenges for marketing effectiveness, tends to displace acknowledgement of the shifts of power between marketers and media.

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The power dynamics shaping contemporary marketing communications are complex, and volatile, with some considering advertising as a whole in crisis (Auletta, 2018). Marketers and media are both in positions of dependence on regionally dominant platforms, such as Google and Facebook. Yet, the drives to build economic value, from individuals to business strategies for media and marketers, and the ordering arising from the exercising of that unequally distributed economic power, are core to understanding. Marketers command the economic resources to exercise power over media which is driving the integration of marketing communications and media. It may be argued this integration is responsive to consumer activity, and even popular, but it is seriously misleading to present it, overall, as a realisation of consumer power, while it is most certainly an extension of marketer power. Advertising integration and disaggregation trends are obviously contrary tendencies: the embedding of advertising within content, and the disembedding of advertising from content publishing and packaging online. However, both tendencies spring from the same underlying dynamics and reflect responses to increasing dependence of media on advertising finance.

Governance and contestation In Chapter 7, the key agencies of governance were identified as formal regulation, self-regulation, the market, and civil society. So far, the focus in Chapters 7–10 has been on regulation and self-regulation, highlighting problems with the regulations themselves, and with commitment by industry. What about other agencies of change? After regulation and self-regulation, a third key source of governance is the market. The behaviour of firms is shaped by competitors, consumers, suppliers, and other market actors. Consumer activity has influence, from the aggregation of individual purchasing decisions, to discussion and feedback, to more collective responses such as boycotts. For branded content governance, ad-blocking is a powerful instance of consumers exercising market power, with 36 per cent of users in the UK and an estimated 26 per cent of users in the US in 2020 using app and browser ad-blocking tools (Statista, 2020a; 2020b). The rise of ad-avoidance and ad-blocking provides some support, too, for Donaton’s claim of a power shift to consumers. According to Donaton (2004), marketers and commercial media will lose power to consumers. Yet, branded content is itself a response to ad-blocking, complicating that account of a power shift. There are many influences on industry and we need to consider these carefully before concluding that it is consumers who are driving change. For instance, Google is leading its own initiative to block ads, establishing the Coalition for Better Ads, but this is selective, and responds to pressure from major advertisers, such as Unilever, not just users. Chapter 9 has discussed research indicating problems in the recognition and decoding of commercial communications embedded in media. I want to consider here the evidence and the potential of users to act in ways that counter or challenge branded content, but also evidence of the range and strength of opinion. Users represent a wide range of views, with younger users in advanced economies

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increasingly tolerant if not supportive of branded content. The research on user identification and processing of branded content suggests that general claims of an empowered consumer need to be qualified at the very least. Research on persuasion, using the Persuasion Knowledge Model (PKM) discussed in Chapter 9, finds that consumers exercise cognitive mechanisms that help them to cope with or resist commercial communications. Consumers who detect persuasion efforts can deploy various coping behaviours in response. Surveying the research literature, Amazeen and Wojdynski (2018) find that ‘consumers often engage in resistance when confronted with a persuasive attempt’, with counterarguing a commonly used and effective tactic. In the context of brand-sponsored content in publishing, ‘counterarguing may entail resisting claims in the news article, resisting the article format, or complaining about a publisher or brand engaging in sponsored content’ (Amazeen and Wojdynski (2018: 227–8). The research conducted on cognitive processing is valuable but also has the limitations of experimental research studies which test interactions outside of the wider context of media practices, media use, and social activities in which ‘users’ are embedded. There is the psycho-cognitive and affective processing involved in interactions with specific content, which experimental studies seek to replicate and examine. There is the wider context of individuals’ education, class, gender, race, and other markers influencing how they access and engage with media. There are the political economic influences of the organisation of media within and across media systems, public policy, education provision, socio-cultural development, and governance arrangements which all influence the conditions in which users access and interpret communications. While research design must usually be delimited, this wider framing counters the tendency in micro/decontextualised research to treat such conditions as extrinsic, when critical communication studies show they are not. In addition, we need to identify the full range of activities of ‘users’. This includes the mix of active production and creation identified in digital content producer-consumers, ‘produsers’, and ‘prosumers’. It also includes the spectrum from personal consumption to protest and forms of resistance, themselves on a spectrum from personal acts to collaborative and collective ones. There is considerably more research that tests sample users’ individual responses to content, than examines actions and attitudes of resistance, but we do have some research indicating selected users’ attitudes towards branded content, and its regulation.

Attitudes to regulation There is a valuable source of user data which also includes rare features of comparability across different countries and time periods such as the annual Edelman Trust Barometer. IPSOS MORI’s Veracity Index is based on a survey of UK adults asked to assess which of a list of professions they generally trust to tell the truth. Advertising executives ‘regain dubious accolade of Britain’s least trusted profession’ (Gwynn (2020), as Campaign’s headline put it. Immediately above them were politicians, government ministers, and journalists. Most trusted, in a year of Covid19, were nurses followed by doctors, with professors ranked sixth after engineers,

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teachers, and judges. An IPSOS study found that only 4 per cent of respondents believe the advertising industry behaves with integrity: ‘consumers are scrutinizing brand messaging and public profiles more than ever before and are quick to condemn brands they feel are being deceitful or inconsistent’ (Minnium, 2018). Minnium (2018) argues, ‘behavioral science insights, coupled with an understanding of consumer attitudes, can help brands create authentic content that engages audiences without inspiring cynicism and mistrust’. Yet, if falling consumer trust in conventional advertising has been a driver for branded content, forms of the latter contribute to increasing distrust. Overall, research shows a wide spectrum of responses to branded content and native advertising, from positive endorsement through to criticism of stealth marketing practices. While branded content research is limited, there have been numerous studies of attitudes towards product placement. Some are over-reliant on assessing universitylevel students. However, a cumulative, general finding is that overt criticism tends to be concentrated in older demographics, while tolerance of or positive endorsement of product placement predominates in younger demographics. It is likely that similar patterns prevail across varieties of branded content. However, contexts change and research needs to do justice to the multiplicity of perspectives. Much of the research on product placement was conducted in contexts of techno-optimism, the embrace of commercial internet services, and consumerism. The rise of climate emergency awareness, anti-consumerism and waste, techno-scepticism, and pessimism demand a fresh wave of studies. Public attitudes towards the regulation of advertising are of huge significance within governance systems predicated on the legitimacy of rules to protect and serve consumer–citizen interests (Lunt and Livingstone, 2012). Important for research and understanding, accounts of public attitudes are also tools used in policy advocacy and so the questions academics ask of the provenance, design, and explanatory value of such data are especially pertinent. However, there are problems with the research available and its instrumentalisation and usage. There are excellent research resources on media users’ practices and attitudes, such as Ofcom, yet user consideration of the choices and implications of different ways of financing media and regulating advertising is often best achieved by more deliberative methods, such as citizens’ juries. According to commercial research by Bazaarvoice (2018), more than half of surveyed audiences in Europe feel that influencer-sponsored content ‘takes advantage of impressionable audiences by being too materialistic (55%) and misrepresenting real life (54%)’, with 49 per cent calling for stricter content rules. Such responses manifest in market power activity, but also influence regulatory agencies, political actors, and policy networks. A commercial agency survey of 2,000 UK consumers investigating online influencer marketing, where similar issues of disclosure of branded content arise, found that 71 per cent believed the ASA should be doing more to enforce disclosure, 71 per cent of UK consumers wrongly believe that influencer marketing is not regulated at all, with a further 61 per cent saying they don’t think brands are being transparent about how they use influencers to promote their products online ( Prizeology, 2018). These findings are

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sufficient to indicate significant public concern and support for stronger regulation. They challenge the construction of a public aligned with integrated advertising and against ‘outdated’ restrictions. However, no position in the debate can safely co-opt user responses to fashion singular responses towards practices or their regulation. We don’t know enough. Instead, ongoing research will provide the best means to understand and engage ‘users’ and co-design solutions based on fully representative and rebalanced stakeholder involvement. There is another key finding, but one arising from the discussion in the next section. User action will certainly prompt industry responses but does not yet represent a force, or articulated set of demands, for strengthening regulation. The final source of governance agency is civil society. This includes ‘organised’ civil society, such as health and children’s NGOs, trades unions, and communications reform groups. It includes campaigns such as Stop Hate for Profit in the US, and organised culture jamming, brandalism, and subvertising initiatives that parody corporate or other advertising. It extends into more ‘disorganised’ movements and citizen-consumer action, aided by social media, such as the protests against the Kendall Jenner Pepsi ad in 2017 (Dzamic and Kirby, 2018: 77–8), a loud refusal to give Pepsi permission to appropriate the iconography of Black Lives Matter. Civil society is heterogenous, representing different and antagonistic interests across a contested arena, yet one where ‘through social interaction and struggles, excluded, marginalized, exploited and dominated social groups and individuals, are empowered to participate in decision making processes, to build platforms of action, to build movements, and to forge civil and political action’ (World Health Organization, 2007: 12). The structures and capacities of civil society vary enormously across political and media systems, but generally comprise organised groups and loosely affiliated and networked actors, involved in interaction, and hybridisation, with governmental and commercial sectors. The combination of organised civil society and user action is illustrated in US litigation in 2014. Google was sued for data mining in a case brought by the Electronic Privacy Information Center on behalf of a group of Californian students who challenged Google’s collection of student data from its Apps for Education service. The case was settled with Google signing the Student Privacy Pledge, a voluntary public commitment not to use students’ personal information for commercial gain. A subsequent case in 2017 saw Mississippi state attorney general Jim Hood allege that Google’s policies and practices regarding online tracking of students remained unclear, despite the company’s public pledge to not collect and use student data for commercial purposes, such as targeting advertisements to students (Herold, 2017). Politicians, policy-makers, regulators, and powerful industry actors do respond to civil society advocacy and campaigning, but various conditions are usually required. First, there needs to be media exposure and access. This highlights the crucial networking roles for academic research to link to civil society research and to investigative journalists and public media platforms. Second, there usually needs to be amplification and engagement from major civil society blocs, such as across health and children’s welfare, since media policy reformers alone are comparatively weak (Leys, 2003). Third, there needs to be evidence of wider public support and engagement so that advocates can advance the

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voices of shared concerns. Since communications policy is usually settled within the relatively closed circuits of bargaining amongst the most powerful industry and governmental interests, it is also important, if not essential, that inter- and intra-industry divisions allow the expansion of regulatory space, to give alternative proposals a hearing and carriage into core policy networks. To date there has been little coordinated protesting against branded content and native advertising, although a combination of market signals and policy advocacy by civil society groups challenges industry practices and governance arrangements. Yet each and every protest matters and the promise is there for the myriad acts of investigating, discussing, and advocating to connect, and for those connections to be aided by us all. Relatively isolated actions may cohere and build. For instance, in 2020, 70 former staff at the Canadian Broadcasting Corporation wrote to the regulator (CRTC) asking it to investigate the company’s plans for its new marketing division, Tandem, to create branded content for corporate clients to show on its digital platforms, with a campaign and petition signed by current and former journalists and other stakeholders (Gollom, 2021).

Branded content reform agendas To be effective, democratic media reform measures need to fit the local conditions and context they are designed to address and to be moulded and advocated by the social forces they are designed to aid. They need to build upon what works and what advances the demands of progressive civil society. Reform agendas should be localised. At the same time, there is strength and value in sharing proposals and building up reform agendas, best practice analysis and research, policy influence, and advocacy experiences. The media and marketing industries examined have policy advocacy trade body organisations with many decades of institutional experience. The more recent associations for the digital age vary in size and scope, but are closely networked and have built up significant resources for lobbying and advocacy. Civil society has organisations advancing media literacy, digital rights, media reform, and consumer welfare, but with a few exceptions, marketing communications is part of a much broader policy agency and does not command the dedicated attention to match industry bodies. While it would be inaccurate to identify industry bodies as resource-rich and civil society bodies as resource-poor, taking the advocacy resources of each sector as a whole would highlight massive disparities. Pro-industry advocacy can be sustained by the paid and cross-subsidised services of lawyers, professional lobbyists, and others. Those advocating for civil society organisation and interests tend to rely on voluntarism supported by a small base of paid staff, time-poor and under-resourced.

Separation principle The principle that we should know when we are being sold to is one underpinning the ‘separation principle’ that advertising material and media communications should be distinguished. Yet that principle also protects communication

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rights. We have a right to know the provenance of communications, to know the sources and interests that may lie behind communication messages. We have obligations here, too; it is reasonable to expect some facility to identify and decode media, depending on audience composition and content. Yet there is a further right: we have a right to communications content that is not shaped by the payment and control of sponsors. In the case of media platforms, publishers or other providers that purport to provide or host content that is ‘independent’ of sponsor influence, then the elision of independent and brand-sponsored content is particularly pernicious and so effective measures to ensure separation are required.

Labelling standardisation European Union countries are required to alert consumers to product placement, the paid presence of brands in television production (European Parliament and Council, 2018). Users must be informed about brand payment through a single, standardised sign, in the UK a P sign. Even that regulated signage is problematic: ‘even if the most media literate viewer were to stumble upon the “P” logo, the regulatory scheme does not make obvious the precise location of a placement’ (Gibbons and Katsirea, 2012: 186–7). They add, ‘[t]he situation is still more complex if the viewer succeeds in spotting some placed products, but there is no “P” logo to accompany them. It will hardly be possible to tell whether these are illegal placements, prop placements of no significant value, or whether their inclusion is merely fortuitous and unintended.’ Yet, no such standardisation is required for publications, platforms, or other content providers carrying editorial-like content produced by, for, or in association with third-party marketers. My recommendations include more consistent labelling. There should also be discussion of a mandatory, or voluntary, universal logo, akin to the P-sign, which is required to alert consumers to the paid presence of brands in UK television production. There should be a single standardised sign displayed for publications carrying editorial-like content items produced by, for, or in association with thirdparty marketers, to feature prominently at masthead and individual item levels. This might be a B sign, for branded communications, or an S sign for sponsored content, with the selection on what is most suitable made following wider consultation with stakeholders and testing for user recognition and effectiveness. As a report by Newman (2018: 16) recommends, there needs to be ‘better source labelling, signals of quality, and improved news literacy’. There needs to be better labelling of sources for content (including brands), better signalling and kitemarking (for both branded content and also high quality independent journalism), and improved news and media literacy (part-funded by levies on platforms and aggregators).

Technology and labelling The programmatic native advertising system described in Chapter 5 involves standardised identification that allows the various processes of bidding, buying, selling,

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assembling, and publishing advertising to work. Such systems could be modified to serve users by incorporating published labelling that enables users to identify the status of the content as advertising. Industry lobbying calls for flexibility in labelling to match the platforms, contexts, and user experience. This is also advanced to challenge requirements for standardised labelling as likely to be outpaced by the speed of creation and innovation in ad-carrying platforms and lead to outcomes that are ineffective for their consumer protection purposes as well as damaging the international competitiveness and growth of companies. There are pro-user protection grounds to ensure sufficient flexibility and adaptability in rules. Yet the call for flexibility has masked the various ways in which delivery has failed to match stated commitments to user awareness and identification. Chapter 9 reviews the now very extensive research demonstrating depressingly obvious findings that inconsistent labelling reduces user awareness. There are technological affordances built into the core systems for digital advertising, including native, that can be used to provide hitherto unseen levels of consistency and clarity. The research on user awareness, while it varies according to context and factors of age, education, media use, and so on, shows not only poor capability to identify instances of branded content, but poor levels of awareness of practices and formats in general. As with other digital issues, common industry discourses present the young as both more accepting but also more aware. Yet this is also overstated. Ofcom’s (2016) research on public understanding of how media are financed and operated found that only half of those aged 16 and over could correctly identify sponsored search listings, even though these were distinguished by an orange box and labelled ‘Ad’. In the US, FTC Commissioner Rohit Chopra has called for labelling and disclosure ‘requirements for technology platforms (e.g. Instagram, YouTube, and TikTok) that facilitate and either directly or indirectly profit from influencer marketing’ (FTC, 2020). The FTC announced in February 2020 a review of its endorsement rules. Chopra supported the 5–0 decision by the FTC commissioners, but added a separate statement in which he argued: ‘Misinformation is plaguing the digital economy, and recent no-money, no-fault FTC settlements with wellknown retailers and brands to address fake reviews and undisclosed influencer endorsements may be doing little to deter deception’. Chopra (FTC, 2020) highlighted how ‘[f]ake accounts, fake likes, fake followers, and fake reviews are now polluting the digital economy’, and added ‘Tech companies may have little incentive to address this misinformation’. Chopra proposes a shift from admonishing ‘small influencers’ to taking stronger enforcement action against advertisers: When individual influencers are able to post about their interests to earn extra money on the side, this is not a cause for major concern. But when companies launder advertising by paying someone for a seemingly authentic endorsement or review, this is illegal payola. If these companies are also pressuring influencers to post in ways that disguise that their review or endorsement is paid advertising, those advertisers especially need to be held accountable.

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The technological solutions for identification of branded content, kitemarking, monitoring compliance, and enforcement will need to be carefully discussed and tested, and developed in relation to the broader commercial, social, and governance systems through which online content and advertising are organised, as well as in relation to systems designed to circumvent or block advertising. The liability for disclosure should apply to marketers but extend to all providers of public communication services, including platforms that should be under legal obligation and so incentivised to ensure compliance among their users (Pflücke, 2020: 321).

Identifying sources Recent years have seen greatly increased attention by policy-makers towards problems involving the identification of sources. There is growing concern about the provenance of content online. These include political advertising; fake news, misinformation, and disinformation; harmful claims from influencers or other communicators; and misleading or criminal activities in online selling and marketing. In some cases that can be justified as providing the necessary delimiting and specificity to achieve the aim of enquiries. Yet it is clear that, however intentioned, it has been advantageous to branded content. Arguments to strengthen disclosure of funders of political advertising have not been expended to apply the same requirements to commercial funders. The differential treatment of political advertising from commercial has continued in UK policy-making, including the Online Harms White Paper consultation outcome (DCMS, 2020). It is vital that reform agendas do not replicate, in themselves, such policy compartmentalisations, which serve as barriers to more effective, comprehensive measures. That is one reason to connect branded content to a broader set of concerns and remedies for the identification of sources, but there are others. First, the principle that users should be aware of the source of the content, and should be made aware of material interests relevant to their assessment of that content, stands for a wider class of material than commercial communications, and indeed for all public communications. Second, for branded content itself, this book has explored the problems of governance and practice concerning paid, earned, shared, and owned media. The sources of ‘earned’ media should be identified and disclosed in content just as ‘paid’ media. That is a realisation of the principle outlined above whose time has come. In addition, the efforts of marketers to evade and bypass sectoral rules applied to particular media is well documented. Strengthening rules on advertising to children in the US and elsewhere led to efforts to bypass restrictions with brand-controlled online spaces, sponsorship, and child influencers on social media (Dean, 2020; Coates et al., 2019; Lunt and Livingstone, 2012: 143–62). In the US, campaigners challenged the FTC over the failure to maintain separation between advertising and media on YouTube Kids, where channels devoted to Logo, McDonald’s, and other brands, ‘unboxing’ videos, infomercials, paid influencers and preroll ads merge into a commodified flow (Kunkel, 2015). In 2019 the FTC received a further complaint about undisclosed advertising deals on Ryan ToysReview (now called Ryan’s World), a top YouTube earner ($29.5 million in 2020) – Ryan Kaji’s hugely popular channel has almost 30 million subscribers (McNeal, 2019). Based on this wider

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historical record and the examples presented in this book, it is to be expected that tightening rules on paid branded content would lead to increasing unacknowledged brand involvement, from transactions surrounding ‘earned’ media, to brand-supplied content and increasing ‘unbranded’ content. Above all, there is the positive, societal case for identifying sources. The UK media reform group MediaWise (2015) advocates greater transparency, arguing that: Accountability and transparency should be the bywords of independent journalism. It is vital that those who purport to produce it should declare their affiliations, ethical stances, and funders, if only to distinguish them from the weirder socalled news sites that waylay the unwary and poison intelligent debate. My own earlier research examined the uneven but broadly effective disclosure of commercial interests that Rupert Murdoch’s News International newspapers agreed to insert in reporting on the papers’ owners’ co-ownership of Sky TV (Hardy, 2010). MediaWise (2015) asks, ‘Why shouldn’t publishing companies reveal their other business interests and those of corporate shareholders?’ That would allow readers to ‘form a judgement about what might be influencing their news agendas – and why the fortunes and failure of some companies do not feature in their columns’. Mediawise call for a ‘public statement on their editorial policies, and the house rules under which their journalists operate’. The Cairncross Review (DCMS, 2019) proposed a ‘news quality obligation’ should be imposed upon social media companies, requiring them to improve how users understand the origin of a news article and the trustworthiness of its source, a proposal under consideration by the UK government (DCMS, 2020). The call for disclosure of sources is also advanced by journalists seeking to strengthen quality and accountability (Bakir and McStay, 2018). The identification of sources and the separation of media and advertising both link to articulation of a broader ‘separations principle’ to ensure that state and private interests are not able to control content and the circulation of opinion in society (Wu, 2018). This seeks to ensure that private actors, such as online gatekeepers, are accountable to the public yet independent of government (Mazzoli and Tambini, 2020: 48), but also advocates transparency at the level of content. Any strengthening of disclosure requirements needs to be conducted within a media pluralism and human rights framework that strengthens safeguards for the protection of journalistic sources. International human rights law has established the importance of this protection for whistle-blowers, for the protection of journalists, and for safeguarding freedom of expression and disclosure of information. The bribery of journalists through payment by third-parties is recognised as a threat to media freedom and integrity worldwide, so requirements to disclose sources is also a tool in combating corruption. The problems surrounding sponsor (source) and communicator identification, raised acutely in some influencer marketing, require stronger standards and clearer rules on disclose of material interests and relationships. It is essential that any contracted agreement (AIMCO, 2020) is disclosed, but this needs to go further to include any material connections that should be revealed so that the reader/user can make a suitable assessment of claims.

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Such an approach would re-integrate the policy action on misinformation, and on the disclosure of political and commercial funding of communications to the mutual benefit of these often siloed policy agendas. An illustration of their interconnection is the lack of transparency in political advertising on TikTok. In the US presidential election campaign in 2020, right-wing accounts such as Conservative Hype House, with 1.5 million followers, urged support for Trump, with some irony since Trump was threatening to close TikTok’s US operations (Galer, 2020a). Unlike the paid ads on Facebook and Twitter, TikTok prohibits political advertising, yet ‘so long as no money changes hands, users can voice support for either presidential hopeful – and funnel others towards their official campaigns’ (Galer, 2020a). According to Ciaran O’Connor of the Institute of Strategic Dialogue, ‘[i]t’s not clear what the nature of the relationship is between the Conservative Hype House and the president’s campaign … there is no information to evidence a more formal partnership for promotion or advertising purposes’ (Galer, 2020a). This is also an example that shows how disclosure is vital in combating the alt-right and exposing the corporate and anti-‘philanthropist’ spending that supports astroturf campaigns. In another example, TikTok removed several videos from a voter registration initiative whose messages were deemed partisan and so fell outside Federal Election Commission rules allowing non-partisan ‘get-out-the-vote’ material not to be classified as political advertising (Galer, 2020b). Staff at the company behind the promotion, Big Tent, acknowledged the videos should not have included anti-Trump messages, while one of the influencers involved ‘said they had no idea that disclosure of payment was required’ (Galer, 2020b). There are some indications of a more integrated approach to source identification developing, although it is still fragmentary. Within policy-making networks, sponsored content has been addressed in policy areas, including the regulation of platforms, adtech, data management and privacy, online harms, harmful advertising, digital literacy, and misinformation. The EU High Level expert group (European Commission 2018: 32–33) recommended that sponsored content is ‘clearly identifiable’, that platforms ‘should ensure that sponsored content, including political advertising, is appropriately distinguished from other content’ and that ‘Source transparency indicators should be developed based on professional codes of conduct and users’ expectations for what constitutes credible and trustworthy content, adjusted to cater for online journalistic practices’. The EU Policy Department for Citizens’ Rights and Constitutional Affairs’ report Disinformation and Propaganda (2019) includes among its recommendations that platform providers should be responsible ‘for distinguishing sponsored content and ads from other content, identifying and disabling fake accounts, protecting the privacy of users, including those who are not members of their services’. The European consumer organisation BEUC voted against the report, arguing that consumer exposure to disinformation needs to be addressed primarily at its source and in relation to the ad revenue practices of platforms, and that the absence in the report of any reference to clickbaiting was unacceptable. Nevertheless, this is indicative of a broader shift in policy discussion towards consideration of source identification that extends beyond branded content and includes action such as publisher kitemarking for

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agreed standards of source transparency as well as legal-regulatory or self-regulatory rule-making on disclosure and other aspects. Reviewing transparency for sponsored content in codes of ethics from the US and Finland, Ikonen et al (2017: 176) advocate a joint code of ethics, arguing that ‘[a]s sponsored content combines a hybrid of professions and practices, no single profession can alone produce full transparency’, though they also argue this ‘may be unrealistic and take time as professional identities and production units and departments often remain separate’. Using the language of the FTC, material connections between sources and public content should be evident or declared in both third-party and self-published content. Payment or consideration related to the published content should be declared for all third-party content. This should be a mandatory requirement. Action might include a simple, automatic penalty for failure to declare payment, with bands set for the severity of the offence, the type of actor responsible, and reach of the published material. Repeat offences would result in a more thorough investigation leading to action including fines, monitoring, copy-approval mechanisms, and disbarring from access to platforms. The latter indicates the value and importance of the interlinking of industry self-regulation with formal regulation to create a culture of professional (and pro-am) awareness and standard-setting, with the public accountability and enforcement action that only statutory regulation can guarantee.

Recommendations    

Standardised identification for all marketing content on a specific platform. Common (cross-platform) identification where appropriate (as #ad requirements and other disclosure labels provide to a degree already). Kitemarking for quality standards/code adherence. Mandatory disclosure of material connection between sources and content.

Children To address children’s communication rights and protection, a good starting point is the principle set out in the European Commission (2016: 6) report that ‘[c]hildren should not be exposed to online marketing when it is likely that they will not understand the persuasive intent of the marketing practice’. The report for UNICEF (Nyst, 2018: 28) recommends that ‘[a]ll advertising to children should be identified as such. Branded and immersive environments should be used with caution, and only under circumstances in which children understand that the content is advertising. Children’s games should not include advertising.’

Digital literacy The evidence of user awareness of branded content presented in this book demonstrates the importance of media literacy initiatives, both in formal education

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and in lifelong learning, which labelling and identification prompts can encourage and support. In the US, networks of educators have produced lesson plans and resources to help young people to recognise and evaluate branded content. All aspects of marketing communications forms, persuasive claims, image manipulation, selectivity, and stereotyping need to be addressed, with the recognition of branded content just one part of more holistic educational initiatives that can engage with the most important concerns of young people themselves. Media literacy can provide the foundation for individual ‘inoculation’ as the PSK researchers put it, but also for a socially shared discussion about practices and regulatory remedies, about normalisation and contestation of branded content.

Structural reform Clear labelling would not only notify users in each instance but serve a wider purpose of increasing awareness of the phenomena of brand-sponsored content and of the platforms and publications willing to host it. Better identification of branded content is important but insufficient. It would not counter the erosion of separation of media and advertising; it would not protect existing communication spaces from brand payment for presence; and it would provide no basis to halt or challenge the expansion of brand presence across emerging media forms and platforms. Those could only be achieved by sustaining separation. The old division sought to separate advertising from media. Branded content built an intermediate space, mixed both, challenging governance during a period of unprecedented adaption in communication systems but with market liberalism ascendant, increasing the autonomy of private actors across media and marketing. A new settlement is required. Branded content needs to be designated, labelled, and subject to clearer and more consistent rules relating to those labels. Much branded content needs to be separated and designated as advertising. Some branded content needs to be identified with ‘sponsorship’, for content that is produced by and distributed by parties other than the brand, but that needs much clearer and consistent codified rules to match expectations of editorial and aesthetic autonomy and independence from brands. There may well be the need for new labels as branded content evolves to meet the same objectives. Separation is a principle of division, not necessarily of binarism. In my view, achieving and realising this separation principle needs a mix of governance tools and effort, from voluntarism (self-regulation) to the enforcement of statutory regulation. No single tool of regulation is sufficient to be effective in highly adaptive environments such as digital communications. Voluntary measures need to be encouraged so that standards and norms are enacted at the source of practice, built into training, support, management, the offer made to users, and the professional standards and values upheld across converging industries. Such voluntarism will not be effective and durable without the underpinning of stronger, statutory measures. Those statutory measures are also needed because communications governance must serve the public interest as defined through a framework of human rights and democratic systems of decision-making, public accountability, and public participation. Those cannot be

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secured by governance limited to industry actors. Discussion about suitable rules needs to be informed by a much wider range of societal interests than those of marketers, agencies, and media alone. Two more fundamental issues arise. The first focuses on news and information media in particular, and asks whether commercially funded journalism can meet the needs and requirements of democratic societies and give voice to and serve the voices and interests of culturally and politically pluralist and diverse societies. The second is the case for noncommercial provision of communication goods and services to meet the needs and requirements of democratic and culturally pluralist and diverse societies. I have added voice to those highlighting that branded content as a ‘solution’ to the funding of journalism causes such damage that only public funding can remedy the crisis of provision of independent journalism (Hardy, 2017). Drawing on the work of Curran and others, I advocate a mixed ecology of media that includes extensive and innovative commercial provision but which places publicly funded, public service media at the core of provision of information, education, and entertainment media (Curran, 2002). Yet, Western media systems and policy-making has advanced market liberalism and commercial expansion for at least half a century and so commercially funded media can be expected to remain at the centre of provision, not public service. In my view, that makes it all the more important to identify and advance all the steps, from baby steps to giant ones, that can reset the relationship of marketers and media and in doing so establish a 21st century principle of separation of advertising and media. There are vital debates about value across communications – economic, social, cultural – that encompass ways of realising creativity, access, remuneration, (cross-)subsidy, and support. The argument of this book is not that those should be short-circuited but rather that they should sit on top of a shared, and guaranteed, set of obligations for transparency, identification, and separation of marketing communications. That ‘separation’ will be difficult, will need to be realised in different ways across evolving forms, tested for effectiveness, revised and adapted, but the underlying principles are clear and available from the common, espoused values found within policy, industry, and civil society discourses.

Trajectories, scenarios, and prospects Branded content is at the leading edge of digital advertising in contemporary digital platforms. The forms branded content takes are constantly, and rapidly, evolving, extending from text-based to visual and auditory content, live events, virtual reality (VR), and augmented reality (AR). According to the IAB UK’s Clare O’Brien (Hansen, 2017): The future of native advertising I think is a shared future with the future of digital advertising. I think through native we’re finding a way to make advertising work on this rich and complex medium. In the same way that TV advertising really isn’t like radio advertising and outdoor posters aren’t like press advertising, we’ve got to find a way to make advertising work digitally, and I think native is leading the way.

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Scenario 1: A short-lived phenomena Native advertising featured in Gartner’s hype lifecycle, falling into the ‘trough of dissilusionment’ together with content marketing by 2017 (Chaffey, 2020). Velocity Partners’ (2013) report Crap: The Content Marketing Deluge identified content as a superficial rebranding of existing practices but was also a call for investment in content marketing expertise. Some industry antagonism stems from the competitive threat posed by branded content investment to other activities, but much stems from concern about the consequence of hype for longer-term trust and business relationships. For Holt (2016), brands’ investment in content was predicated on gathering audiences around them, but they have lost out to ‘crowdcultures’ on social media and overestimated the interest of consumers in their content: ‘While companies have put their faith in branded content for the past decade, brute empirical evidence is now forcing them to reconsider. In YouTube or Instagram rankings of channels by number of subscribers, corporate brands barely appear.’ Likewise, Southern (2017), while confident in the growth of effective, ‘native’ BC strategies, highlights the overproduction of ineffective branded content: ‘the stats show that sixty per cent of the content produced by the world’s leading 1500 leading brands has zero or very little impact on consumers’ lives’. Holt’s advice for brands to ‘target crowdcultures’, has been pursued, however, most notably through influencer marketing. One of the prominent early advocates of branded content, Donaton (2007), is careful to describe it as a path: Notice I’m not saying the path forward. I’ve found over the years that those most likely to be dismissive of the very idea of treating branded entertainment with respect are those who believed it was put forth as the successor to the 30second TV commercial and therefore as the centerpiece of a new marketing model. To the contrary, I have always viewed this as only one tool marketers will need in a diversified arsenal. It is one of the answers to the question of what happens to marketing in an age of consumer control, but far from the only one. Designating the vast majority of social and mobile advertising as ‘native’ inflates the rate and share of growth or branded content, but spending in many areas remains a very small share of overall marketing spending. Persuading clients to fund branded content over the long term faces significant challenges. There are problems of measurement to demonstrate ROI. In 2015, the executive vice president of the Association of National Advertisers, Bill Duggan, complained, ‘For all the buzz around native advertising, you don’t hear a lot about measurement and ROI’, and argued ‘[t]he industry would benefit from a deeper understanding of the metrics that matter most for native’ (Heilpern, 2016). Since then, there have been considerable advancements, yet each new platform and form adds to measurement challenges. Ultimately, aside from regulatory interventions, the durability of branded content will depend on effective measurement tools that convince clients of the longer-term benefits for ROI.

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Another, much-debated, issue is scale. Stephanie Losee, Head of Content at Visa, reported on retrenchment in the mid-2010s (Hansen, 2016): Some publishers are closing their custom content studios because it’s too hard and it’s not profitable enough and they don’t see it scaling. And they’re right. […] By definition, custom content doesn’t scale, but I think that that is the wrong approach […] we’re all going to have to go in this direction because I don’t see any other direction. According to AdWeek’s tech editor Josh Sternberg (Patterson, 2018): I think the distribution outlets, like the NewsCreds, Contentlys, Nativos […] came up as a way to mollify the naysayers of branded content who would say that branded content can’t scale; meaning, if I write branded content for the New York Times, it can only run on the New York Times, because it’s designed, and created, and produced for the New York Times, which is why it’s a premium product. So a lot of folks said, ‘Well, you may not like banner ads or display ads, because they don’t really work. You get a 0.01% click through rate. But they scale.’ […] So these companies rose up, basically, as a way to spread sponsored content, native advertising, branded content, marketing contents, what have you. For marketers and marketing agencies, much discussed challenges include scale, both in terms of exposure and reach and return on investment (Richter, 2017). For example, Davies (2018) describes a Guardian Labs award-winning campaign The Chain for Google’s Pixel 2 mobile handset. Guardian Labs recruited model and activist Adwoa Aboah and nine other leading fashion influencers and invited them to film how they challenged the status quo. The content was then produced as a glossy print magazine distributed at fashion outlets around London and a shortform video which ran on the Guardian site and on Instagram and Facebook, generating 430,000 video views (Guardian, 2021). Such work illustrating publisher-asagency is strong on brand values but high cost and low margin for publishers. As Davies (2018) notes, ‘Producing high-quality content and distributing it at the necessary scale makes for tight margins’. For both legacy and digital publishers, the investment to secure and retain brand clients has often been considerable and reduced profitability. In particular, publishers have often undertaken paid advertising to boost engagement with their hosted branded content, adding to costs. Such activities lead to considerably lower profit margins than for display advertising. Moses (2017) discusses challenges at the New Republic’s content agency Novel, including ‘high content creation, overhead and distribution costs as well as rising competition’. Moses cites a 2016 report by Polar that found 79 per cent of publishers were using paid distribution (mostly Facebook or other social media ads) to achieve the scale for clients that their own properties could not achieve. One executive describes how higher margins required efficiencies achieved only over time, such as ‘using a regular stable of freelancers and by getting smarter about

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buying distribution and volume discounts from those distributors’ (Moses, 2017; Davies, 2018). Publishers created branded content units that replicate some traditional features of advertising agencies, yet unlike those agencies, publishers are usually not ‘retained’ by brands but paid for individual creative executions, or campaigns. Some publisher branded content teams were configured closer to salariat norms than the disposability of labour more common in ad agencies. So, research that examined growth must be re-aligned with more recent studies of contraction, outsourcing, and precarity. The global Covid-19 pandemic in 2020 has produced a profound cyclical impact, but also exacerbated pre-existing structural trends shifting resources and power further to platforms and away from publishers. According to a 2019 forecast, by 2021 the combined digital ad revenues of Google, Facebook, Twitter, and Snapchat are expected to represent 70 per cent of the total market in the UK (eMarketer, 2019). Revenue from all forms of advertising was in steep decline for many legacy publishers before the 2020 pandemic, but then collapsed as the virus outbreak led to worldwide restrictions on public life. Those platforms are not unitary, with entertainment IP-driven content firms (Netflix, part of Amazon) and the tech companies monetising social media entertainment (Facebook, Snapchat) advancing shared and competing interests (Cunningham and Craig, 2019). Finally, the prospects for a short-lived phenomenon are increased by consumer disenchantment. Perhaps capitalising on this prospect to bolster the case for earned public relations, a PRCA member and PR coordinator Simona Morar (2020) predicts that ‘as consumers become more skeptical of sponsored content they instead look to friends on social media for advice’ and she advises PRs that ‘[e]stablishing a strong, organic connection with these new types of influencers will be instrumental for engaging campaigns’. So, in scenario one, branded content may be a short-lived phenomenon.

Scenario 2: Transitional Branded content may be relatively short-lived, not because it will decline but because it will transform further. Branded content may be indicative of a transitional phase as media systems move to even more integrated forms. The division and relationship between media and advertising that this book problematises will continue to dissolve. Content marketing may be symptomatic of a transition from traditional advertising to new arrangements, with divergent elements from brand storytelling to consumer interactions and ‘touchpoints’ across voice, in-store, chatbot, and so on; for McStay, ‘content marketing is a placeholder for an understanding of tomorrow’s marketing environment’ (cited in Dzamic and Kirby, 2018: 20, 19–21). These are important arguments and invite attention to underlying patterns and deeper reconfigurations over more superficial or ephemeral changes. However, like marketing, academic research, driven by its own competitive economy, faces pressures to identify and announce the new, and to focus on the leading edge, at the head, over the main body and tail. The notion of branded

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content as part of a transitional phase rather than ‘destination’ is very valuable in prompting deeper analysis of continuities, changes, and future trends. However, it also risks deflecting from and underestimating the significance of the present phase and considering all its implications.

Scenario 3: Expansion If countervailing forces are weak, then the expansion of branded content is the likely scenario to prevail. This book has charted the rapid growth of branded content and presented the activities and vision of actors confident, over the medium term at least, of continued growth. For a visual image of that expansion, we have the commercial colonisation of space represented by Elon Musk’s SpaceX test launch of its Falcon Heavy rocket in February 2018. The payload on the rocket was a Tesla roadster car, with mannequin driver, propelling product placement for Tesla into outer space. Before the impact of the Covid-19 pandemic, Polar forecast branded content global revenue would double in 2020 to $13.4 billion (McCarthy, 2020). The expansion scenario is advanced on the basis of market growth, market tolerance (aggregate user acceptance), but also governance trends. These should not be generalised at the cost of suitably detailed examination of regional, national, and sub-national variation. However, the trajectory in Western communications policy over the last half century has been permissive to the commercial expansion and integration of media and advertising. That has not been uncontested and legal-regulatory tools and values have been advanced to set limits and to protect consumers, competition, and media. These protections are very important achievements to the credit of policy-makers, regulatory agencies, civil society groups, activists, and everyone who signed petitions or otherwise acted in support. Even current rules set limits on marketing. Yet, these rules have set limits within a context of expansion. Commercial publisher moves to increase native advertising are likely to be accepted, as the economic case to sustain commercial publishing in the absence of sufficient alternative funding and subsidy remains strong. In audiovisual, product placement liberalisation is also likely to advance, as discussed in Chapter 3. Underlying this are processes in governance whereby practices are simultaneously problematised and normalised. For example, the ASA (2020) says that native advertising, which it describes as a ‘context-driven approach’ ‘isn’t a problem in and of itself, but marketers must ensure that ads remain recognisable as ads’. The same briefing paper states, ‘Whilst an ad may look “at home” within editorial content it must not appear to be editorial content when it is not’. Nativeness is, thus, both condoned and problematised. Ads must not appear to be that which they emulate or risk being confused for. They can be disguised (‘native’) but must declare themselves. These measures propose a resolution in which qualities of blending in are corrected by qualities of standing out. Such a balance can be advanced in ideal terms, but it is also apparent that such balance may well not be achieved.

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Scenario 4: Compound, uneven development Which of these scenarios may prevail in different contexts is subject to the ways economic, political, technological, and socio-cultural forces will interact. Modified and new scenarios will be identified as conditions change requiring new mapping. The most likely scenario is that branded content will continue to grow in scale, scope, and share of marketing expenditure (Scenario 3), but specific forms and formats will indeed be short-lived (Scenario 1). Branded content will also evolve and form part of transformed meanings and practices across ‘media’ and ‘marketing’ as a transitional scenario (2) may emphasise. Branded content will continue to transform and influence transformation at the levels of concrete phenomena, institutional arrangements, and discursive, ideational, and attitudinal formations. Equally importantly, the configurations of branded content will remain a dynamic blend of transnational/transcultural and localised. The forms of normalisation and contestation that take place will need comparative research of a kind that is undeveloped. So, in a relevant, but not uncommon, academic move, I propose that the most likely scenario is a compound one, in which we might look to identify and understand what mixture and ordering of these (and other) scenarios may predominate within media systems overall and at more meso (sectoral) and micro levels.

Resources for hope Branded content might be regarded as a loose collection of evolving forms of marketing communications. There is some value in that reading, reflecting scepticism about hype and awareness of rapidly shifting trends. However, treating branded content as just tools in the marketing mix risks missing more profound shifts. There is a deeper convergence occurring between media and marketing, across corporate arrangements, practices, personnel, governing values, forms, and formats. Leading brands have become content studios; media companies have established content units to serve marketer clients. The hybridisation of advertising formats (Balasubramanian, 1994) is now infused and increasingly normalised across marketdriven media. Some sponsored content phenomena may indeed be short-lived. Yet, the shifts from media and advertising integration with separation to integration without separation are profound and far-reaching. Branded content illustrates the proliferation of new kinds of promotional communications forms and spaces that offer tremendous opportunities for cultural expression, rewarding exchanges and even social change, but which also have profound implications for communication industries, consumers, and societies. The confidence of Donaton in Madison & Vine is misplaced, and should be challenged; there has been a power shift to consumers, but it has been an incomplete one. The ‘dominant forces’ (Benson, 1977: 4) of branded content governance are the commercial brands, media, and marketing firms, influencing industry practices and values, and exerting pressure on regulatory systems whose institutional histories include various kinds of consumer and public interest protection, but

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which fail to match industry convergence and have overseen the expansion of commercial integration of brands across media forms and platforms. To sum up prospects for action, there are opportunities in the increasing attention given to supporting media and digital literacy as part of the solution to navigating modern communications, for adults as well as children. A range of industry interests may coalesce to support calls for stronger regulation, from media publishers seeking to demonstrate high-quality journalism, to marketers wanting to show responsible branded content. Politicians and regulators face pressures to establish more coherent rules and regulations across converged communications. Yet, against those influences to reform and strengthen regulations, there are very powerful forces and interests to liberalise, with marketers, media, and marketing agencies all so dependent on branded content and embedded advertising. Politicians are generally not disposed to challenge such formidable industry interests, except in selected areas, usually where powerful interests around children, health, and welfare are mobilised. So, there are grounds for pessimism: very powerful commercial interests across media and marketing industries want to advance the merging of media and advertising, and do not want to invite stronger regulation, or wider public scrutiny and critical debate. Yet, this is a moment of opportunity, justifying hope. Issues of how commercial communications reach us and are identifiable link to the broader set of issues concerning the provision and governance of communications. If Donaton’s account reflects, in part, a moment of techno-utopianism, digital disenchantment fuels demands to deliver the digital empowerment we were promised, and advance an agenda for better media that is strengthened by each voice. In daily life, individuals, families, and social networks engage in efforts to manage and create a better communications environment. The energy released from connecting these individual and civil responses will increase pressure and amplify calls for stronger identification of commercial sources, and greater separation of advertising and media in protected communication spaces. I am optimistic that tackling problems of branded content will become a bigger issue – because it is part of an even greater issue – how modern communications are organised and regulated to serve societies.

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Ikonen, P., Luoma-aho, V. and Bowen, S. A (2017) ‘Transparency for sponsored content: Analysing codes of ethics in public relations, marketing, advertising and journalism’ International Journal of Strategic Communication, 11 (2), 165-178. Kunkel, D. (2015) ‘Digital deception: Legal questions surround new “YouTube Kids” app’, LSE Blogs, 30 November. https://blogs.lse.ac.uk/parenting4digitalfuture/2015/11/30/ digital-deception-legal-questions-surround-new-youtube-kids-app/. Leys, C. (2003) Market-Driven Politics. London: Verso. Lunt, P. and Livingstone, S. (2012) Media Regulation. London: Sage. Lynch, L. (2018) Native Advertising: Advertorial Disruption in the 21st-Century News Feed. New York: Routledge. Mazzoli, E. and Tambini, D. (2020) Prioritisation Uncovered: The Discoverability of Public Interest Content Online. Strasbourg: Council of Europe. McCarthy, J. (2020) ‘How publishers are getting around the branded content slump’, The Drum, 1 October. https://www.thedrum.com/news/2020/10/01/how-publishers-aregetting-around-the-branded-content-slump. McFall, L. (2011) ‘Advertising: Structure, Agency or Agencement?’ in M. Deuze (ed) Managing Media Work. London: Sage. McNeal, S. (2019) ‘Kids YouTube channel Ryan ToysReview has been slapped with an FTC Complaint’, BuzzFeed News, 10 September. https://www.buzzfeednews.com/article/stepha niemcneal/youtuber-ryan-toys-review-ftc-complaint. MediaWise (2015) ‘Who pays the piper?’, Mediawise, 23 February. http://www.mediawise. org.uk/who-pays-the-piper-2/. Minnium, P. (2018) ‘Brands strive for authenticity as audiences turn a skeptical eye toward ads’, Marketing Land, 23 March. https://marketingland.com/brands-strive-for-authentici ty-as-audiences-turn-a-skeptical-eye-toward-ads-236295. Morar, S. (2020) ‘Showing off PR in 2020’, PRCA. https://www.prca.org.uk/PR2020. Moses, L. (2017) ‘“The model can’t hold”: Publishers face content studio growing pains’, Digiday, 9 March. https://digiday.com/media/model-cant-hold-publishers-face-contentstudio-growing-pains/. Newman, N. (2018) Journalism, Media, and Technology Trends and Predictions 2018. Oxford: Reuters Institute for the Study of Journalism. Nyst, C. (2018) Children and Digital Marketing: Rights, Risks and Responsibilities. New York: United Nations Children’s Fund (UNICEF). Ofcom (2016) Adults Media Use and Attitudes. https://www.ofcom.org.uk/_data/assests/pdf/ file/0026/80828/2016-adults-media-use-and-attitudes.pdf. Patterson, D. (2018) ‘Why native advertising and branded content works’, TechRepublic, 12 May. https://www.techrepublic.com/article/why-native-advertising-and-branded-contentworks/. Pflücke, F. (2020) ‘Making influencers honest: The role of social media platforms in regulating disclosures’, in C. Goanta and S. Ranchordás (eds) The Regulation of Social Media Influencers. London: Edward Elgar. Piety, T. (2016) ‘Killing the Golden Goose. Will blending advertising and editorial content diminish the value of both?’, in M. Edström, A.T. Kenyon, and E.M. Svensson (eds) Blurring the Lines: Market-Driven and Democracy-Driven Freedom of Expression. Göteborg: Nordicom, pp. 101–108. Prizeology (2018) Under the Influence: UK Consumer Attitudes to Social Media Influencer Marketing. https://www.prizeology.com/wp-content/uploads/2018/02/Influencer-WhitepaperPrizeology.pdf. Richter, S. (2017) ‘The future of native advertising for brands and publishers’, The Entrepreneur, 9 March.

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Schwartz, J. (2017) ‘Young subscribers flock to old media’, Politico, 21 October. https:// www.politico.com/story/2017/10/21/millennials-trump-paying-for-news-244001. Serazio, M. (2013) Your Ad Here. The Cool Sell of Guerrilla Marketing. New York: New York University Press. Southern, L. (2017) Interview, 13 December. Statista (2020a) ‘Usage of ad blocking software in the United kingdom (UK) in 2018 and 2020’. https://www.statista.com/statistics/874736/ad-blocker-usage-in-united-kingdom/. Statista (2020b) ‘Ad blocking user penetration rate in the United States from 2014 to 2021’. https://www.statista.com/statistics/804008/ad-blocking-reach-usage-us/. The EU Policy Department for Citizens’ Rights and Constitutional Affairs (2019) Disinformation and Propaganda – Impact on the Functioning of the Rule of Law in the EU and Its Member States. Turow, J. (2011) The Daily You. New Haven, CT: Yale University Press. Velocity Partners (2013) Crap: The Content Marketing Deluge – the Single Biggest Threat to B2B Content Marketing, Slideshare, 10 January. Slideshare.net/dougkessler/crap-the-content-marketingdeluge. World Health Organization (2007) Civil Society Report. Commission on Social Determinants of Health. Geneva: WHO. Wu, T. (2018) The Curse of Bigness: Antitrust in the New Gilded Age. New York: Columbia Global Reports.

INDEX

Note: Page numbers in bold indicate a table. Aboah, Adwoa 263 Abramson, Jill 53 Accenture 132 Actor-Network Theory (ANT) 236 ad blocking 21, 41, 249 Adshead, S. 18–19, 93 ad skipping 19 adtech 106 advergames 214 advertisers’ influence: on non-advertising content 231–232, 235–238; payment for coverage 217–219, 246 advertising: ad-free vs. ad-full services 223– 224; consumer resistance to 21–23, 40– 41, 71–72, 249–253, 264; integration of 7–8; in post-broadcast era 127–128; power of, to pay for presence 217–219, 246; in print media 21; shifting relationship with media 7–13; on social media 20–21; in television market 19–20; see also specific types advertising agencies 131, 132 see also marketing agencies Advertising Association 95 Advertising Exchanges 106 advertising revenues: branded entertainment 27; and Covid-19 pandemic 264, 265; and digitalisation 26; digital native publishers 52; Facebook 40; Google 101– 102; internet 27, 39–40; native advertising 105–106; of news media and

publishing 21, 39–41, 48–49; product placement (PP) 80; social media 13, 104– 106; television 19–20 Advertising Self-Regulatory Council (ASRC) 148 Advertising Standards Authority (ASA) 153, 154–156, 178 advertising studies 229–233 advertorials 41–42, 44–45, 175–176, 187 AIMCO see Australian Influencer Marketing Council (AIMCO) Airbnb 207 Alibaba 101 Almiron, Nuria 39 Alps, Tess 189–190 Amazeen, Michelle 209, 210, 211, 212, 250 Amazon 101, 102 Amazon Prime Video 20, 80 Amenábar, Alejandro 92 American Society of Magazine Editors (ASME) 149 Anderson, Peter 38 Anheuser-Busch 87 ANT see Actor-Network Theory (ANT) ANZ Bank 221 Apple 93 apps 109, 112 AR see augmented reality (AR) ad formats Aroncyky, Melissa 90 Artemas, Katie 183 artificial intelligence (AI) 81, 94

Index 273

Artifishal 93 arts and culture patronage 222–223 Arvidsson, Adam 96, 127 ASA see Advertising Standards Authority (ASA) ASME see American Society of Magazine Editors (ASME) Asmussen, Bjoern 243–244 ASRC see Advertising Self-Regulatory Council (ASRC) Association of National Advertisers 132 The Atlantic 50–51 Audiovisual Media Services Directive (AVMSD) (2010) 72–73, 152, 162–164 augmented reality (AR) ad formats 93–94, 102 Auletta, Ken 47 Australian Influencer Marketing Council (AIMCO) 159, 178 AVMSD see Audiovisual Media Services Directive (AVMSD) (2010) award ceremonies 13 A–Z of Music 138 Bacardi 95 Bachmann, Phillip 46, 215 Bagdikian, Ben 231 Baker, C. Edwin 231, 232, 233 Baldasty, Gerald 45, 46 banner ads 21, 52, 104 Bartholomew, Don 9 Bartl, Mathias 115 Basuroy, Suman 233 Bauman, Zygmunt 60 Baumgartner, Felix 4, 89 BBB NP see Better Business Bureaus National Programme (BBB NP) BBC 126–127, 136 BCMA see Branded Content Marketing Association (BCMA) Beck, John 16 Becker-Olsen, Karen 230 Benito, Maria 92 Benson, J. Kenneth 144 Bergdorf, Munroe 189 Berger, John 220 Better Business Bureaus National Programme (BBB NP) 148 Bettig, Ronald 232 Bhushan, Sandeep 105 Birmingham Mail 218 Bishop, Sophie 117, 118 Black Lives Matter 97, 252 Blackwell, Lewis 91 bloggers 179

BMW 11, 12 Boerman, Sophie 209–210, 211 Boogzel, Helen 117 Borum, Pete 135, 185–187, 223 bots 94 Boyles, Jan 54 Bradshaw, Ben 73, 74 brand activism 220–221 brand authenticity 118 branded content: antinomies of 191; arts and culture patronage 222–223; and children 212–214, 256, 259; consumer attitudes toward 249–253; consumers’ ability to identify, as advertising 208–214; consumer trust undermined by 24, 51, 183, 188–190, 199, 211–212, 248; critiques of 186–187, 192–199, 245–248; debate over definitions 16–19; defined 14, 108; effectiveness of 187, 262; examples of 3; factors in rise of 19–27; future of 261–266; growth rate 3; history of, during late 20th century 11–13; holistic view of 243–245; lobbying on behalf of 171–174; lobbying through 174–177; media integrity as undermined by 206–207, 214–217; in news media and publishing 41–61; normalisation of 184–187; and provenance of online content 256–259; reform agendas 253– 261; types of 4, 6–7; see also integration, of media and marketing Branded Content Marketing Association (BCMA) 13, 96 branded entertainment 27 Brand Film Festival 13 brand value 90 Brexit 153 Bromley, Michael 196 Brüggemann, Michael 38 Buckley, Samuel 45 BudTV 87 The Bulgari Connection (Weldon) 93 Burnham, Andy 73 Butler, Gemma 78 BuzzFeed 49, 51–53, 56, 117, 154, 244–245 Caldwell, John 127 Campbell, Colin 44 Canham, Emily 158 Cannes Lions award ceremony 13 Canter, Andrew 11, 12, 133, 186 CAP see Code of Advertising Practice (CAP) Carah, Nicholas 219 Carlson, Matt 59–60, 183 Carr, David 50

274 Index

CARU see Children’s Advertising Review Unit (CARU) Carvossa, Abby 189 Cassell, Thomas ‘Syndicate’ 151 CEM see Consumer Experience Management (CEM) Chadha, Monica 54 Chaffey, Dave 94, 262 The Chain campaign 263 Chartered Institute of Public Relations 96 chatbots 94 children 212–214, 256, 259 Children’s Advertising Review Unit (CARU) 148 Chittum, Ryan 49 Chomsky, Noam 232 Chopra, Rohit 255 church–state firewall: attacks on 59–60; and editorial integrity 47; erosion of 57, 60, 183–184; failure of 193–199; and freelancers 59; and integrity 190–192; journalists’ attitudes toward 53; in news media and publishing 46–47; in practice 57–59; and regulatory norms 143–144; strengthening of 253–254, 257, 260; as traditional norm 7–8, 36; see also integration, of media and marketing cinema see films class status 197 clickbait 43, 55, 248 click-through rates (CTR) 110 climate change 175–176 CMA see Competition and Markets Authority (CMA); Content Marketing Association (CMA) CMP see Consent Management Platforms (CMPs) CMS see culturalist media studies (CMS) Coca-Cola 92–93 Code of Advertising Practice (CAP) 154–156, 162–163 Coles, Joanna 199 Colhoun, Damaris 198 Communications Act (1934) 72 communications policy-making 169–171 communication studies 238–239 Competition and Markets Authority (CMA) 153, 156–157, 163–164 complaints process 163–164 Condé Nast 56 Consent Management Platforms (CMPs) 106 Conservative Hype House 258 consumer content 14–15 Consumer Experience Management (CEM) 16 consumerism 220

Consumer Protection from Unfair Trading Regulations (CPRs) 153 consumers: ability to identify branded content as advertising 208–214; attitudes of, toward branded content 249–253; children 212–214, 256, 259; data tracking of 43, 55, 107, 111, 219, 252; and influencer authenticity 118; power of 5, 23, 30, 187–192; resistance to advertising 21–23, 40–41, 71–72, 249–250, 264; savviness of 191–192; trust undermined by branded content 24, 51, 183, 188– 190, 199, 211–212, 248; voice profiling of 111 content farms 55 content feeds 108 content marketers 12 content marketing 13–16, 27 Content Marketing Association 13 Content Marketing Association (CMA) 96 content recommendation industry 43, 55, 108 Conticchio, Bill 21, 187 contract magazines 86 Cooper, Christopher 175 Cornia, Alessio 183–184 Coronation Street 78 corporate social responsibility (CSR) 221 Costa, Laia 92 Couldry, Nick 207 Covid-19 pandemic 56, 101–102, 264, 265 CPE see critical political economy (CPE) CPRs see Consumer Protection from Unfair Trading Regulations (CPRs) Craig, David 234 critical governance analysis 144–147, 169–171 critical political economy (CPE): and advertising studies 229–233; analytical framework 235–238; challenges to 233–235; defined 29; and power dynamics 170 CRM see customer relations management (CRM) CSGO Lotto 151 CSR see corporate social responsibility (CSR) CTR see click-through rates (CTR) culturalist media studies (CMS) 233–235 Cunningham, Stuart 234 Curran, James 236 Cusick, James 216 customer relations management (CRM) 88 Daglish, Simon 135 Daily Mail 58

Index 275

Daily Telegraph 193–197 D’Arma, Allesandro 184 Data and Marketing Association (DMA) 96 Data Management Platforms (DMPs) 106 Davenport, Dylan 133 Davenport, Thomas 16 Davies, Nick 222, 263 Dell 50 Demand Side Platforms (DSPs) 106–107, 108 Dennehy-Neil, Christie 188–189 Desmond, Richard 161 Deuze, Mark 60, 231 Devlin, Ben 76 Deziel, Melanie 50, 209 Diageo 91 Dietrich, Gini 9 digital advertising: growth in 25–26; influencers 112–118; mobile advertising 109–110; native advertising formats 107– 112; overview of 100–101; platforms 101–103; programmatic advertising 106– 107; social media 103–106 digitalisation and internet 25–26, 39–40, 71–72 digital literacy 259–260 digital native publishers 51–53 disclosure requirements: and consumers’ inability to identify advertising 208–214, 255; and consumer trust 188–190, 247– 248; FTC regulations 148–152; Internet Advertising Bureau (IAB UK) 177; lack of enforcement 152, 155, 216–217, 222; as necessary 246, 254, 258; noncompliance with 179; range of 180, 181– 182, 182–183; regulation of 154–159, 161, 164; see also regulation; selfregulation Disney 137 DMA see Data and Marketing Association (DMA) DMP see Data Management Platforms (DMPs) Donaton, Scott: on consumer receptiveness to marketing 23; critique of branded content 187; on defining ‘branded content’ 17; on future of branded content 262; on The Hire 11; on integration of media and marketing 10, 20; on merging of ads and entertainment 5; on power shift toward consumers 5, 23, 30, 187– 188, 249; on product placement 70; on ‘pull’ content 248; on user resistance to ads 21–22 Dove 87, 221

DSP see Demand Side Platforms (DSPs) Duggan, Bill 262 DVRs 19 Dzamic, Lazar 16, 30, 89, 185 EASA see European Advertising Standards Alliance (EASA) editorial integrity see church–state firewall Einstein, Mara 13 Eisend, Martin 211, 212 Ellman, Matthew 230 employment status 55–56, 136 Estrella Dramm 92 ethical issues 188; see also church–state firewall EU see European Union (EU) European Advertising Standards Alliance (EASA) 159 European Union (EU) 152–153 Evans, Nathaniel 209, 210 The Evening Standard scandal 215, 217 Evolution 87 Exxon Mobil 175–176 The Eye 117 Facebook: advertising revenues 40; advertising services 102–103; corporate lobbying 176; dominance of 26–27, 48; unpaid advertising 105 FANGS (Facebook, Amazon, Netflix, and Google) 101; see also Amazon; Facebook; Google; Netflix Faraone, Roque 220 FCC see Federal Communications Commission (FCC) Fearless Girl statue 93, 221 Federal Communications Commission (FCC) 69, 72 Federal Trade Commission (FTC): and advertising regulations 147–150; on endorsements 159; industry noncompliance 179; on native advertising 42, 206; on product placement 69; requirements for native advertising 15, 46 Federal Trade Commission Act (1914) 147 Ferrer-Conill, Raul 42, 174, 184 films: marketing practices 136–137; and owned media forms 92–93; product placement in 69–70 Financial Times 59, 194 Fisher, Lauren 103 Forbes 48 The Force Awakens 137 Foreman, Gene 198 Fraser, Simon 190

276 Index

Freedman, Des 145 freelancers 59 Frizell, Martin 76 Frohlich, Michael 247 FTC see Federal Trade Commission (FTC) Fujawa, Jennifer 70 Fulgoni, Gian 22, 230–231 Fuller, Chris 77 The Furrow 10, 57 Gandy, Oscar 232 Gannett 47 Gardiner, Kate 57 Gatto, Joey 115 gender equality 221 Germano, Fabrizio 230 Gibbons, Tom 71, 73, 74, 76, 254 Giddens, Anthony. 146 Gilchrist, Duncan 211 Goeres, Eric 189 Goldenhar, Linda 231 Gomes, Vicky 176 Goodfellow, Jessica 158 Goodship, Pauline 157 Google 88–89; ad revenues 101–102; advertising revenues 40; advertising services 102, 103; The Chain campaign 263; data mining lawsuit 252; dominance of 26–27, 48, 101; and influencers 115; lobbying investment 173–174; and London 2020 project 215 governance 147, 249–250; see also critical governance analysis; regulation; selfregulation Graham, Meghan K. 190–191 Grainge, Paul 10, 11, 128 Greenslade, Roy 194–195 Greico, Elizabeth 56 Grimm, Pamela 44 Grover, Vandita 102–103 Guardian 49, 53, 176, 180, 182–183, 207 Guardian Labs 263 Guinness 91–92 The Guinness Book of Records 10 Gwynn, Simon 250 Hall, Jeanne 232 Hammett, Ellen 247, 248 Hancher, Leigh 145 Hanusch, Folker 184 Hardy, Jonathan 29 Harrison, Georgia 214 Havens, Tim 234 Hay, Colin 170 Hayr, James 80–81

Heater, Brian 102 Herman, Edward 232 hero, hub, hygiene schema 88–89 Higham, Nick 126 The Hire 11, 12, 86–87 Hodges, Sam 136 Holt, Douglas 12, 262 Hood, Jim 252 Hoofnagle, Chris 208, 209 Hotchkiss, Gord 189 Howe, Patrick 211, 212 Howell, Dan 156 HP 88 HSBC bank scandal 193–197 Hugh, Nick 21 Hulu 20, 80 Hurwitz, Dan 112 Hutchinson, Andrew 102 Hynes, Jessica 49–50 IAA see International Advertising Association (IAA) IAB see Interactive Advertising Bureau (IAB) IAB UK see Internet Advertising Bureau (IAB UK) ICO see Information Commissioner’s Office (ICO) IMC see integrated marketing communications (IMC) Impress 161 in-app advertising 109 Incorporated Society of British Advertisers (ISBA) 95 Independent 53 Independent Press Standards Organisation (IPSO) 161 Independent Television Authority 154 inequality 218, 223–224 in-feed advertising 101, 108, 110 Influencer Marketing Hub 115 influencers 158; authenticity 118; contractual arrangements 117–118; defined 112; marketing agencies 116; and media publishers 117; overview of 112–114; PewDiePie 113–114; platforms 114–116; power of 24; promotional diffusion 118–119; regulation of 148–151, 154, 156–159; YouTube 114–115 Information Commissioner’s Office (ICO) 219 Instagram 105, 115–116, 157, 178, 179 Institute of Practitioners in Advertising (IPA) 96

Index 277

integrated marketing communications (IMC) 90 integration, of media and marketing: arguments against 206–224; corporate expansion of 128–130; corporate transformations 130–134; employment status in 136; historical perspective 9–11; normalisation of 184–187; overview of 7–8, 134–136; see also branded content; church–state firewall integrity see church–state firewall; media integrity Interactive Advertising Bureau (IAB) 13, 103, 105 International Advertising Association (IAA) 95 International Public Relations Association 206 Internet Advertising Bureau (IAB UK) 96, 177 internetisation 25–26 IPA see Institute of Practitioners in Advertising (IPA) IPSO see Independent Press Standards Organisation (IPSO) Irish Independent 174 The Irish Times 174 ISBA see Incorporated Society of British Advertisers (ISBA) ITV 68–69, 72, 126, 133 Iversen, Magnus 212 Jack, Ian 197, 232 Jacob, Ralf 81 JD.com 101 Jenkins, Simon 195, 198, 218 Jenner, Kendall 97, 252 Johnson, Catherine 10, 11, 127, 128 Johnson, Dakota 92 Johnston, Marcia 17, 50 Jones, David 57 journalists: integrity of 193–199; roles and identities 59–61; on separation of media and advertising 53 J. Walter Thompson 10, 132 JWT London 130 Kaji, Ryan 256 Kantrowitz, A. 103 Katsirea, Irini 71, 73, 74, 76, 254 Kelly, Kate 76 Khamis, Susie 219, 220–221 Khan, Amena 189 kickbacks 132 Kim, Bong-Hyun 211

Kirby, J. 16, 24, 30, 89, 185 Kjellberg, Felix 113–114 Knudsen, Erik 212 Kollman, Ken 175 Kyle, Kriss 89 labelling standardisation 254–256, 260 Lambie-Nairn, Martin 126 Larson, Curt 108, 109 Latour, Almar 183 Lazarsfeld, Paul 238 Lazauskas, Joe 211 Lebedev, Alexander 215 Lee, Alexei 193 Lego Movie 92 Lehu, Jean-Marc 71 Lester, Phil 156 Levy, Keith 87 Linqia 116 listicles 52 live events 94–95 Living in an E World 12 lobbying 171–177 London 2020 215 Lord & Taylor 150 Lorenz, Taylor 117 Los Angeles Times 47 Losee, Stephanie 263 Lotz, Amanda 234 Luce, Henry R. 46 Lukes, Steven 145 Lury, Celia 96 Mackintosh, Millie 156 MacLennan, Murdoch 193, 194 MacManus, Theodore 44–45 magazines 56–57 Mandel, Jon 132 the market 249–250 marketing agencies 130–134 Marlow, Katherine 78 Marsh, David 201 Martin, Trevor ‘TmarTn’ 151 Martinson, Jane 198 Marx, Karl 68 Mashable 52 Mathes, Danica 24 McAllister, Matthew 229 McChesney, Robert 38, 160 McCormick, Robert 46 McDevitt, Casey 53 McDonald, James 179 McFall, Liz 245 McManus, John 38

278 Index

media: cross-promotion of 126–127; selfpromotion of 125–126; shifting relationship with advertising 7–13 media integrity: of journalists 193–199; as undermined by branded content 206– 207, 214–217; see also church–state firewall Meleshinsky, Eduard 208, 209 Michelin Guide 10 Microsoft 12, 151 Minnium, Peter 251 misinformation 256 mobile advertising 100–101, 109 Mobile Marketing Association 109 Mole, Andrew 23 Moor, Liz 96 Moran, Michael 145 Morar, Simona 264 Moses, Lucia 263–264 MTV 127 Murdoch, Elizabeth 137 Murdoch, Rupert 127, 232 Murdock, Graham 68 Murphy, David 179 Musk, Elon 265 Mutmainnah, Nina 211 Narcos (streaming series) 50 native advertising: benefit of 22; changes in 111–112; consumer ability to identify, as advertising 208–214; and consumer data tracking 43; defined 7, 15–16, 18, 42–43, 206; effectiveness of 110–111; formats 107–112; FTC requirements for 15, 46; growth rate of 27; market actors 110; in news media and publishing 42–43; vs. owned media 14; regulation of, in US 148–150; revenues 105–106; on social media 20–21, 104 Native Advertising Institute 105 native distribution 6–7 Netflix 20, 50, 80 neuroscientific studies 110–111 Newman, Nic 254 news media and publishing: advertising revenues 39–41; advertising revenues of 48–49; advertorials in 41–42, 44–45; branded content in 41–61; business models of, in US 54; changes in 36–41; content farms 55; decline of legacy business 37–40, 48; digital native publishers 51–53; economic trends in 37– 39, 48–49; employment status in 55–56; history of advertising in 44–47; and influencers 117; job losses in 37, 53, 56;

journalistic roles and identities 59–61; legacy publishers 53–54; native advertising in 42–43; separation of, from advertising 46–47; ‘separation principle’ in 36; sponsored content 48–53; sponsored content in 44 newspapers see news media and publishing New York Times 48, 49, 50, 53 Nickalls, Sammy 113 Night Mail (film) 11 normalisation 184–187 novels 93 Nownes, Anthony 175 Oborne, Peter 193–196 O’Brien, Clare 185, 188, 261 O’Connor, Ciaran 258 O’Donnell, Jon 216 Ofcom 162, 213 Ogilvy 130 Ogilvy, David 129 O’Gorman, Katie 93 Oliver, John 199 One Last Summer 92–93 OOH see out-of-home (OOH) marketing openDemocracy 215–216 openRTB protocol 108–109 opioid addiction 176 Orange is the New Black (streaming series) 50 Oreskes, Naomi 175–176 Osborne, George 215 OTT see over-the-top (OTT) advertising outdoor advertising 93, 94 out-of-home (OOH) marketing 220 over-the-top (OTT) advertising 20 Owens, Simon 52 owned media: artificial intelligence (AI) 94; chatbots 94; contract magazines 86; defined 6–7; documentaries 92–93; The Hire 11, 12, 86–87; history of 85–86; industry organization 95–97; live events 94–95; vs. native advertising 14; novels 93; outdoor advertising 93; overview of 87–91; risks of 96–97; short-form and long-form filmed entertainment 92; as type of branded content 4; virtual and augmented reality formats 93–94; The Wolf 88 paid, earned, shared, and owned see PESO model Parker, Guy 42, 178 Pasandaran, Camelia 211 Patagonia 93 payment for coverage 217–219, 246

Index 279

Payne, Chris 23 People for the Ethical Treatment of Animals (PETA) 220 Pepsi 97, 252 Pequeñas Cosas 92 Perelman, Jonathan 52, 154 Peretti, Jonah 52 El Periódico 174 Perrin, Nicole 106 Persuasion Knowledge Model (PKM) 209– 212, 250 PESO model 9 PETA see People for the Ethical Treatment of Animals (PETA) Peterson, Tim 114 PewDiePie 113–114 Pfizer 232 Phillip Morris 232 Piety, Tamara 207 Pilkington Committee (1962) 72 Pinterest 179 PKM see Persuasion Knowledge Model (PKM) Planet of the Apes 137 policy advocacy 171–174 political advertising 258 Ponsford, Dominic 53 power dynamics 145–146, 217–219, 246, 248–249 Powers, Devon 90 PP see product placement (PP) PQ Media 17, 20 Press Gazette 194 press releases 58 Price, Rob 176 print media 21 Procter & Gamble 231 product feeds 108 product placement (PP): artificial intelligence (AI) 81; changes in 71–72; critiques of 78–79; in European Union 73; in films 69–70; forms and formats 71; history of 10; history of, in television 69– 70; in post-TV landscape 79–81; regulation of 72–75; regulations on 161–163; revenues 80; spending on 70; in television market 20, 68; in UK 73–78 professional organizations 95–96 programmatic advertising 106–107, 235, 236–237 Promax 128–129 Prometheus 136–137 propaganda model 232 Pulizzi, Joe 6, 14, 17

‘pull’ marketing 22, 248 ‘push’ marketing 22 quality 190–192, 215 Quinn, Patrick 20 racial bias 117 racial justice 221 Ray-Ban 93 Real-Time Bidding (RTB) 106–109, 111, 235 Red Bull 4, 89 Redwood Publishing 86 Reeves, Richard 21 Refinery29 53 reforms: church–state firewall 253–254, 260; labelling standardisation 254–256, 260; structural 260–261 regulation: complaints process 163–164; consumer influence on 251–253; and consumer power 187–192; corporate influence on 171–174, 219; disclosure requirements 149–151, 155–159, 161, 164; enforcement action, in UK 154, 156; enforcement action, in US 150–152; in EU 152–153; Federal Trade Commission (FTC) 147–150; industry resistance to 173; of influencers 148–151, 154, 156–159; for legacy vs. modern media 160–163; limitations of 154–156, 160–164, 216–217; of native advertising, in US 148–150; overview of 143–144; of product placement 72–75, 161–163; types of 147; in UK 153–156; in US 147–152; see also lobbying; self-regulation Reno, Jean 92 Reuters 183 Richter, Scott 48 Rinallo, Diego 233 Riordan, Kellie 50, 198 Ripp, Joe 199 Rodríguez, Alberto 92 Rogers, Charlotte 77, 106 Rosenau, James 144 The Rotarian 44–45 Roxburgh, Helen 16 Rozendaal, Esther 213 RTB see Real-Time Bidding (RTB) Rusbridger, Alan 38–39 Russell, Cristel 71 Samsung 94 Sapeurs campaign 91–92 Sarwar, Nadeem 119

280 Index

Scherle, Elizabeth 114 Scientology 50 Scott, Ridley 136 Sebastian, Michael 5, 70 self-regulation: of advertising, in US 148; failure of 219; industry compliance 178– 179; lobbying for 173; overview of 171, 177; technological 178; see also regulation self-regulatory organisations (SRO) 148 separation, of media and marketing see church–state firewall Serazio, Michael 22, 248 Sharma, Kate 176 Shaw, David 47 Sheikhbeauty 157 Shiao, Dennis 14 Shire, Emily 221 Sinclair, John 30, 130, 131, 132 Singer, Jane 60, 61 Sky Television 127 Slater, Christian 88 Sloane, Garett 116 Smith, Martin 201 Smith, Scott 53 Snapchat 102, 104, 119 soap operas 10, 69 Sobande, Francesca 221, 222 social feeds 108 social media platforms: ad revenues 104– 106; as advertising market 20–21, 101, 103–104; native advertising 104; sponsored stories 104 social protest 252–253 Soley, Lawrence 231 Somethin’ Else 129 Sonderman, Jeff 54 Sony 151 SoundCloud 111 source identification 256–259 South China Morning Post 50 Southern, Luke 90, 97, 262 sponsored content 36, 44, 51 SRO see self-regulatory organisations (SRO) SSP see Supply Side Platforms (SSPs) Starr, Paul 160 Sternberg, Josh 59, 263 Stone, Deborah 184 storytelling 184–186 Stratos 4, 89 streaming video 71–72, 79–81 Suez Crisis 232 Sullivan, Andrew 198 Sunday Times 197 Supply Side Platforms (SSPs) 106–107, 108 Supran, Geoffrey 175–176

surveillance capitalism 219 Syngenta 216 talent agencies 116 Taylor, Charles 210 T Brand Studio 49, 50, 53–54 technological advances: AI, and product placement 81; as factor in rise of branded content 19–20; and growth in digital advertising 25–26; and influencers 117; and labelling 254–256; see also digitalisation and internet The Telegraph 58–59 Telegraph 176 television: branding as central concern 127–128; history of advertising in 68–69; product placement in 68, 69–70; shift in advertising 19–20 Television Act (1954) 68, 72 Television Without Frontiers Directive (1989) 72–73 terminology: of branded content in news media 41–43; debates over definitions 16–19; variety of 13 Teufel, Brady 211, 212 third-party media 4 TikTok 104, 158, 258 TiVo 19 Tran, Millie 54, 72, 80 transparency 188–190, 247; see also disclosure requirements Trinder, Mark 78 Trump, Donald 258 Tsang, Denise 78 Turow, Joseph 8–9, 111, 220, 229 Uber 215 UCPD see Unfair Commercial Practices Directive (UCPD) UK see United Kingdom (UK) Unfair Commercial Practices Directive (UCPD) 152 UNICEF 213, 259 Unilever 221 United Kingdom (UK), advertising regulation in 153–156 United States (US): advertising regulation in 147–152; business models of news media and publishing 54 US see United States (US) users see consumers Vale 92 Van Damme, Jean Claude 88 Verdier, Julien 106

Index 281

Verizon 18, 21, 109 Vice Media 52, 53, 56 view through rate (VTR) 110 virtual reality (VR) ad formats 93–94 vloggers 179 Vodafone 49–50, 90 voice profiling 111 ‘Volvo Epic Split’ 88–89 VR see virtual reality (VR) ad formats VTR see view through rate (VTR) Wall Street Journal 50 Ward, Geoff 38 Warner, Kenneth 231 Watkins, Anna 185 Watson, Tom 215 Weaver, Sylvester 69 Weise, Mike 12 Weldon, Fay 93 Wernick, Andrew 119

Whitney-Vernon, Kaaren 191 Who Killed Summer? 90 Wiley, Danielle 105 Willes, Mark 47 Williams, Raymond 217 Wineburg, Sam 209 Wojdynski, Bartosz 42, 43, 175, 209, 210, 212, 250 The Wolf 88 Wolff, Michael 37 Word of Mouth Marketing Association (WOMMA) 96 Wright, Peter 210 Wu, Mu 211 Young, Miles 17–18 YouTube 109, 114–115, 179 Zuboff, Shoshana 173