You're listening to the Affiliate Marketing Podcast brought to you by FIFA.com, the chapter and verse of everything you need for running successful affiliate programs and partnership management. This is a podcast for digital and affiliate marketers, publishers, networks, agencies, and more tech providers who operate in affiliate marketing. If you want to launch, scale, and grow successful affiliate marketing programs, you're in the right place. In this podcast, you'll learn how affiliate and partner marketing is changing. Gain behind the mic access to affiliate marketing veterans. Listen and learn tried and tested program management tactics. Discover what's new and trending in affiliate and performance marketing. The truth is, you simply won't find this information anywhere else.
SPEAKER_02Welcome to this week's affiliate marketing podcast with me, your host, Nianne Johnston, and today I'm super excited because I've got somebody who I met almost six months ago who I have absolutely enjoyed getting to know and who has an amazing wealth of experience on compliance and affiliate marketing and lead generation. President of IntegraShield, Gayla Huber, who is joining me on the podcast this week. Gayla, it's a pleasure to have you here with me.
SPEAKER_01Hi Leanne, it's so good to be here.
SPEAKER_02Thanks for having me. I can't wait to get into like knee deep all the things that we've been discussing since we first met. But first of all, what I want to do is ask you to tell us your backstory because even that is interesting, how you got into this industry. And I always like to start podcasts off with that with my guests, because absolutely everybody that comes on here has got an interesting story about how they landed up in performance marketing or partnership marketing. So take us back to the beginning. Tell us how you entered this industry and how you landed up being the president of Integrit Shield today.
SPEAKER_01Yeah, that's it was quite a change going into compliance from what I did previously. So I actually got my start about 20 years ago. I've done everything from corporate marketing to league aggregation, digital advertising, and everything in between, I'm pretty sure. So when I first got my start, we were doing corporate marketing. I decided, though, when digital advertising was getting hot, to go ahead and make a switch. And one of my claims to fame, I guess, would be that I got to be the person that was developing the ad serving engine that on your mobile phones back in the day when you had the ads that were the banners at the top and the bottom of your mobile phones. So that's really what got me into a combination of digital advertising, but then also I was really interested in the actual engine that was serving the ads, so the technical piece of that. So from there, um, I went into lead aggregation. And I think that's where I've really developed uh all of my skills when it comes to what I'm using now on the compliance side. And the reason being is because lead aggregation or lead gen and all that good stuff, you touch so many different pieces of the ecosystems that are out there, all of the affiliates, the brands, everything. And I realized that, you know, when I went to college, got my MBA, we didn't learn about compliance. Uh, and everything was getting really highly regulated in about 2010 here in the US. And no one knew what they were doing. My customers didn't know what they were doing, my affiliates didn't know what they were doing. It was a disaster. And so I spent my weekends trying to figure out what we can do about this, right? I don't want anyone to go out of business just because of regulations. And so we ended up uh deciding there was nothing out there that we could use. We developed our own technology, got really, really lucky in that we had a genius engineer with us, uh, still do have some genius engineers with us, and developed um our own proprietary technology that goes out and crawls the web. So that's how I got into compliance. Left uh the digital ad space, whenever to do what I'm doing now.
SPEAKER_02You make it sound so simple, like it just crawls the web, but we're gonna get a little bit deeper into what Integrity actually does because it's super interesting. And before we move on though, like you you touched on a really good point in the in the fact that most people don't actually know what compliance is. And in this industry, in the performance marketing industry, we're still struggling to understand what best practices are and what compliance is, and how affiliate managers should be managing compliance, or should be should there be separate tools and and departments that actually come in and sit on top of affiliate programs, especially in regulated markets like finance, insurance, um, you know, those industries where and even gaming, gambling, uh those industries where there has to be an ethical component to everything that we do, and and there's advertising guidelines. And you know, we're all talking about GDPR over here in Europe. I know it's kind of coming to the US, and we'll touch on that too. But I think it's been an evolutionary process, is what I'm I'm trying to say. It hasn't it hasn't happened overnight. We didn't wake up one day and go, okay, we need compliance. Like you were literally in the 2010, like what I call the golden era of digital marketing, figuring out what is compliance and what do these tools need to do. And yes, they scrape the web, but then what do you do with all of that information? So maybe now is a good segue to talk a little bit about what IntegriShield does and how you help your clients.
SPEAKER_01It definitely is more complicated than I make it seem. But um, because we built our own proprietary technology, we're sort of we're not um limited to platform APIs, different things like that that exist out in the world. And so our tool goes and essentially it's it's a it's a complicated rule set engine, if you can think of it that way, where it's gonna go out and identify content wherever it lives. And so we can definitely target certain areas, like we might want to target native ads, or we might want to target paid search, we might want to target um just search engine results, different things like that. Uh, but whatever brands or affiliates uh who hire us need us to look for, we're gonna go out and target that information. So you brought up GDPR, that that was a really interesting era when that was launching. We did have a lot of requests for us to go out and make sure people had the right disclosures on their page, that things were, you know, what they needed to be for the consumer side. But if you think of it in terms of what we're looking for, uh, it can be anything from what a brand needs to look for to what an affiliate needs to look for. So think of it in terms of disclosures, consumer consent, check boxes, are they pre-checked or not pre-checked, advertising disclosures, claims, that's a big one, right? So different claims that are out there, and you touched on insurance and gaming and all of that. Uh, every industry has their own specific regulations that they have to adhere to, finance, you know, they've got a ton that they have to do as well. And the rule sets that we build inside the tool are to essentially go out and make sure that wherever our brands are represented, that or our affiliates and their partners are represented, that the information that the consumer is actually going to see is compliant or matches a brand's guidelines, right? So that could be regulatory or just on the brand side, either one.
SPEAKER_02Yeah. And that's quite interesting because the just recently now, and and I hate to time these podcasts, but this is the 17th of May, in case you're listening to this back, we've just seen in The Guardian here in the UK, there was a big piece about, I think it was Bet Vector, who had approved some affiliates onto their program. The affiliate had written a piece of content. The Guardian then picked it up and said, This is you know, bad piece of content, which is branded as as Bed Vector, has been put in front of mothers that have just had babies. So on websites where mothers are actually reading and saying, Hey, go and play bingo to like stress relief. Now that uh isn't compliance. That's like we need the tool to tell us that this content is out there, but we also need the human to to think about the context of the compliance as well. So I think on the one hand, it's great that we've got these tools, but on the other hand, we also need to educate affiliate managers because they need to know what to do with this information and and how to use these tools efficiently in their programs. And this is just a time timely thing that happened to come up. But one thing that I found interesting about what you just said is that your tool can actually crawl everything from website to search terms to does it also work on mobile as well?
SPEAKER_01It does. So desktop, mobile, and we also were really excited that um our optical character recognition technology is running. Because in our world, well, I mean everyone's world, because we are all in affiliate marketing, so social media runs our lives now. And so the social media side of things, what we found is that when the shorter reels became popular with TikTok and all that good stuff, then shorter reels, in order for people to get their message across, a lot of times what they'll have to do is they'll either just play music during that short time or they might say something, but in reality, the image in the video might be the thing that could get a brand in trouble or an affiliate in trouble. And so there could be anything from sort of the type over text that people kind of put and layer in on their videos. You know, we have certain industries where people will have different things behind them in the background, or they'll be holding up a picture of something. And so if you think of it in terms of like uh in the lending space, you know, somebody says, Oh, you can get a loan and they hold up something that looks like a government check, that is absolutely not okay. And so in that case, they didn't say anything that we would transcribe as noncompliant, they didn't do anything else. It's just the imagery is what is actually going to be misleading to the consumer. And so absolutely it's all about what people don't know that is out there.
SPEAKER_02I'm pretty sure. I mean, can you talk us through some of the big industries or or big like cases that you've uncovered using the tool that you know really made a difference to your customer because they just didn't know that this stuff was happening? And it's impossible to have eyes everywhere, and that's why you know, betting your partners before you bring them onto your program and having rules and regulations in place, terms and conditions, all of those things are important. But have you ever had a case where you had a client where they were like none the wiser? You kind of worked with them for three months, did a scrape, and something big came out. Like, have you got any of those kinds of stories?
SPEAKER_01Never ever, one time even, had a client that knew what was out there. So, opposite of what you're saying, like, do I have an example of one? No, every single client had stuff that they did not know was out there. Um, so it can be, I'll give you some stats because I love stats. I'm kind of a data junkie, but uh, so we crawled billions of URLs, and I took just our small dollar lending industry. So that could be a combination of like small dollar loans at credit unions, or it could be what we would call payday lenders in the US or small installment loans or things like that. And we took 59 brands uh that were in that industry, took data from 2018 to 2022, and we do this every year, so it just kind of grows. But when we looked at their entire totality of what we identified for those 59 brands, we found 22,000 URLs that had violations on them. Out of those URLs with violations, so remember, I told you a violation can be anything from just a missing disclosure, or it could be just maybe a banned term. They don't like to use a certain type of terminology or something like that. It can be anything. Out of the 22,000 URLs, 16,000 of those were fraud. They were scammers, they were not the brand. They look like the brand, but they were not the brand. So think of how many consumers would actually go to those websites and those pages, put in their bank account information, their social security numbers, and fill that information out. And it just goes into you know the air, right? And it's never coming back. So um that, you know, it's pretty significant. So 73%, just for that one tiny, so that's not even just finance, right? So we do a lot in finance, that's just one little niche area of finance, and that many pages um had issues. So 73% had fraud, and out of that 73% from 2018 to 2022, over 20% of those fraudsters do it every single year. Wow.
SPEAKER_02So they just keep coming back, coming back all the time. So compliance is so broad, right? It's it's it's from checking that the content on the site is compliant, checking that it's not somebody who's like brand bidding or squatting on your brand or doing something illegal on your brand. And then it's also making sure that your brand is being protected in terms of like from the marketing perspective as well. So all three segments are things that your tool can actually help brands develop. Now, what about from the publisher side? Because we do have publishers that listen to this podcast too. What are some of the common things that the publishers are asking you to look for?
SPEAKER_01So we actually have a lot of those as clients as well. Um, when you think of it in terms of a business and long-term success, right, in the compliance space, uh, compliance is kind of a nasty word, nobody really likes it. Think of it in terms of risk mitigation. So when we look at a business and we say, you know, what can you control, what can you not control? Uh, you're really just taking a look at what risk are really gonna put you like in the sights of a regulator or in a lot of litigation, things like that. And so for the compliance side, we tell the publisher side, one, you've got to have policies, right? So it's a really important that you have a really good vendor due diligence policy, that you're going through all the questions, forming those relationships, um, and then making sure that you have policies in place that folks need to adhere to. And then from there, once you have it written and you're make sure you're following those policies, then you need to make sure that you're monitoring what people are doing because you really don't want anything coming in from bad sources, essentially, right? And a lot of times it's not what we know, right? So it's probably not the folks that we're working with directly. It's gonna be folks that they're working with, but maybe they didn't have the good due diligence process in the beginning or form that relationship. And today, I mean, think in terms of TikTok, there are so many people who just produce content, right? They didn't go to school for this, they have no idea what the regulations are. They're just producing content to get clicks, right? So there's just a lot of education that has to happen. And so it's not that it's always a fraudster or a scammer or a bad guy. A lot of times it's just education. And so um, when we work on the publisher side, it's really just getting with them and scoping out and looking at their entire network and like where's everything coming from? And then from there identifying who's doing it on purpose and who's not doing it on purpose. What do we need to do to fix it, right? Because you don't, it's all about ROI. And so our goal is not, because I've been a marketer, which I think that's one thing that makes our company so different than everybody else. I know that the goal is not to take down. We don't want to get rid of revenue. The goal is just to fix, right? So just fix it, don't take it away. Um, just work for the folks, educate them, make sure that they know what they can and cannot put out there.
SPEAKER_02And I mean, a lot of affiliate managers have to be experts across multiple industries. Because I know what happens in the US is very different to what happens here in Europe. Uh GDPR rules, and I'm gonna bring you back onto that um in a minute because I know that you're doing a lot of stuff with uh US regulation, so we'll we'll we'll talk a little bit about those things. But um keeping abreast of all of that is part of your self-development and learning because like you said, it's uh you know, uh publishers they're making content, they're either buying ads and reselling that inventory, or they, you know, very good with keywords and SEO, or they know where to find, you know, traffic sources that nobody else has touched because that's kind of what they live and eat and breathe and do. But none of them have had this education in terms of like advertising standards codes, which is what we have here in the UK. You know, even in the gaming industry, for example, from the point when a customer clicks on a link to the point when the customer signs up and registers, it has to be only three clicks. So if you're thinking about a publisher that has an ad on their website, the customer clicks on the ad, goes to sign up their um account, and the ad that they saw has to give them the bonus that they received on the end of that click within three clicks. Like that's how granular sometimes the compliance is across multiple different industries. So it's you know, everybody talks about oh, you have to be a great relationship manager. Everybody talks about the fact that you need to be a good negotiator and salesperson. The compliance bit is the bit that still gets stuck in the back office and everybody forgets about it until it becomes a problem. But it doesn't have to be that way.
SPEAKER_01Yeah, absolutely. And so when you were talking about the three clicks, that's funny. Um, we kind of live on a one-click policy around here, just the US in general, best practice, you know, one click away. But it is something that a lot of folks, especially the newer folks coming into the industry, they don't know. I mean, you couldn't even, I I think it was probably five years ago I saw the first compliance degree at a university in the US. I was like, oh my gosh, how sad nobody knows what they're doing. And we love our attorneys, right? We work really well with attorneys, and attorneys are great, but they don't really have the practical application side of understanding how all that works to know whether or not how to make it compliant or whether or not it is compliant technically. And so I do think, like for the folks listening, if we have any of the sort of people newer into the industry, like a lot of our OGs are going to be like, yeah, we've been there, done that, you know, we've lived it all. But for the newer folks, um, I think it's imperative that they actually take the time. I call it my morning reading. And I was doing this as an aggregator. So I, you know, I wasn't doing compliance yet. But my morning reading is keeping up with what's impacting my industry or industries. Like you said, some people are gonna have more than one industry, and it is a lot to keep up with, but there are so many great resources out there that will compile all of that sort of, you know, news and all of that for you so that you don't have to go looking for it everywhere. What are some of the resources that you read? Yeah, so I like, well, I'll read anything. So I have Google Alerts set up on a lot of things. My morning reading is a little bit wild. My nighttime reading too. So my morning reading, JD Supra, is one of my favorites, but I have a lot of law firms like Venable and Minat and Troutman, uh, a min firm that's out there. I read anybody who's putting out great content and consistently putting out great content, that's who I'm gonna be looking at. And so if anyone is on the like consumer consent side, the Troutman and Min firm they put out, TCPA after dark and things like that, and they're getting into AI, which is so exciting. Uh, so they have really good content. JD Supra, they're gonna take it from a lot of different areas. Um, but I would, I mean, Google Alerts, there's a lot of little nuggets that I find when I set up my daily Google Alerts that will just bring back some sort of random content that not everyone has noticed yet.
SPEAKER_02That's good reading, guys. So get on your Google alerts and if you want to brush up on your compliance rules in whatever country you're in, like set up a couple of alerts and see what comes in. Now you spoke to me about some of the new potential regulations that are coming in the US for lead generation. Can you talk us through what's happening, what's potentially going to happen, and you know, what people need to be thinking about right now in terms of working with partners and managing their programs, especially stateside.
SPEAKER_01Yeah, so lead generation has always been a target. It's gone up on the list of targets here recently, uh, to the point where I really believe that some of the regulators are trying to just squash the lead generation industry. The FCC specifically put out a notice of proposed rulemaking where they included in that. So it has a lot of really good points that protect consumers that are completely logical and great for consumers, that businesses should be okay with. But they did include in there some different points that, if the rule were to go forward, would be a real issue for lead generators. And that would be things like a one-to-one consent is a huge concern, meaning that in the US, if a consumer were to consent for a text or something like that, it would have to be directly to that one brand. And as we know in lead generation, you know, three to six times is what a lead's probably gonna sell, um, at least three to eight, maybe over here. But um marketing partners, I mean, some folks could have 20 marketing partners, and I think that's completely realistic because there are so many different benefits to consumers for having multiple partners on certain types of lead generation, right? You know, if you're gonna buy a new house, you might need to find a mortgage, but you also might want to put solar on your roof, or you might want to, I mean, there's so many different things uh that it makes sense for consumers to have access to all of that information and be able to comparison shop. And so the one-to-one consent is probably my my biggest thing. Um, but they were also trying to, and this is gonna be everyone in affiliate space like hates this one, is they wanted to make it where the disclosure would have to live on the same page of all the advertisers as the submit button. I mean, we all are in mobile, we know how mobile works. And can you imagine every single form with a submit button is gonna be like an Apple phone, you know? Scroll, scroll, scroll, get to the bottom. Consumers are gonna read it. And so to me, that's just anti consumer protection uh because consumers are gonna want to just scroll past that to get to the submit that to the alpha. Yeah, absolutely. So that one doesn't even make sense to me. But the one to one consent is really concerning. Because think of it in terms of a consumer and how we live today. Can you imagine having to go to each brand directly or to only be able to give that consent one time? And think about how many times you put in your information if you had to do that. And I just told you that in just one little niche, 16,000 pages on the internet were scams before we took them down. You would have entered in that information how many times? And it would be everywhere. So that to me, in the compliance space, that's just completely not okay for consumers at all. Definitely not okay for business, but really not okay for consumers.
SPEAKER_02So what's happening now? I mean, how's that going to impact the industry? I mean, do we just sit back and wait? Or no.
SPEAKER_01Yeah. So we've been getting really involved. I've been to DC, oh my gosh, I don't even know how many times in the last two months to go around and talk to folks and kind of inform them on the reality of what is going to happen to consumers if this were to happen. I'm also on the board of REACH, which is the responsible entities against consumer harassment. We've developed comments that we're submitting to the FCC. Our organization has submitted comments. I think a lot of others that are part of REACH and then also part of PACE, which is a consumer consent group, we've submitted comments. And so a lot of when the proposed rulemaking comes out, it's really about educating lawmakers. This may sound good, right? It may sound like it's doing something good for consumers, but in reality, it is gonna hurt consumers. And so just making sure that we're getting the word out there, like on your podcast right now, you know, hopefully people will hear this. And if they have not already gotten involved, they still have time to get involved and submit comments to the FCC. Uh so I would highly recommend it.
SPEAKER_02I mean, because if you think about it as well, it's gonna change the face of how your affiliates are driving traffic to you right now. So whilst it might not impact you directly because you don't need to do lead generation, your partners do. So how are you gonna go and support your partners to continue to actually drive that traffic to you? Because if this ruling comes into play, they would have to change a lot of their infrastructure, a lot of their you know, web pages and the way and a lot of the partnerships that they probably have that drive those leads to your offer or to your product or service or whatever it is that you're selling. Now, is this only gonna impact the US? Because I haven't heard about anything around this in in Europe, but we've got different rulings to you in terms of uh GDPR compliance, which also is another thing, you know, in in America, for those of you that are running programs in the US, everything is also federally you know managed. Like is this gonna apply to everybody across the US or is it only gonna be in different states? Have you had any kind of feedback on that?
SPEAKER_01Yeah, so the FCC is federal, so it would be a federal rule that would go into place if it were to happen, really hoping to stop that though with our education. Um, but similar to GDPR, so we do have states that have a similar GDPR rule that has not gone federal yet. That's another thing I go to DC all the time and try to get a federal standard uh because we don't, you know, the internet doesn't have borders, so it doesn't make a whole lot of sense to have different rules in every single state. But yeah, the the rules that we have, um, and and there's a lot more, right? The FTC is starting essentially if you see in the US um and sort of talking about it going over to Europe or something like that, if you guys do something, we tend to start to see that happen here, right? So we all kind of learn from each other. And then if we do something that everyone's like, oh hey, that was good, then we'll start to see it over there. So things kind of go back and forth. So the expectation would be that um no matter where you're at, you do have a stake in it. So GDPR, I'm in the US, but I definitely was a part of that and I was staying on top of that, um, trying to understand it and have comments on it, just because whether I'm there or not, it will eventually impact me. And so it really doesn't matter where we're all at. Um, everything will impact everyone in the affiliate space because the internet doesn't have borders. So that I to me I think is really crucial that um everyone stay on top of that regardless of where the rules are at.
SPEAKER_02Well, the other thing as well is just from a like professionalism perspective, because we have come a long way in the 20 years that you know affiliate marketing has been in existence and now we're moving to a partnership economy and all these other lovely buzzwords that are being um bandied about. But ultimately it still boils down to you know building a compliant business because ultimately, if you're a publisher and you're building your business, at some point you're gonna want to sell. So making sure that all of these policies, these processes like compliance forms the basis of any single business that actually launches, whether you in it for the short term or the long term. So it's it's best to kind of understand what these rules are and get these pr processes and practices in place at the start, and or get tools like yours in place to actually automate this process and and and self-educate. Because it's impossible to expect affiliate managers to be doing everything. They can't sell and account manage and you know, keep abreast of everything that's going on in the legal and compliance world. And, you know, I I think we're getting to the point now where if you are going to invest in this channel, you need to have the proper resources in place to actually run this compliantly and properly, because otherwise you will land up getting into trouble, like some of the things that we've discussed on this podcast. You know, not by intent. You're not getting into trouble by intent, you're getting into trouble because other people are seeing loopholes and scamming and doing all of those things, but that's got no relevance to what you are trying to do with your brand, you know, in a case where you shared, you know, those 16,000 URLs that you had to get taken down. So, you know, I think compliance is going to impact companies that operate in lead generation and affiliate programs for years to come. But if if you get it right at the beginning, you don't necessarily have to be worrying about it because slowly but surely you'll be like tackling it day by day. So it's not like a one and done thing.
SPEAKER_01No, it doesn't end. And the repeat offender stat should probably tell people it never ends. But I think you touched on it with the partnerships piece of it, right? Because in the space that we're in, um the evolution of that right now has been that relationships are so much more important than they used to be. Um, I we were joking, I was joking with Amanda and Sarah at Link Unite, um, and we were talking about how people just used to come by our booth and we'd be like, a little piece of paper or a card be like, here's my CPL. I mean, that doesn't, you know, and drop your card and we'll talk. It just doesn't happen that way anymore. Everything, companies are starting to see that those relationships and partnerships are really important. And that's like step one of compliance, right? Is making sure that you have a you know who you're working with, you've done your due diligence, um, you're staying on top of it every single year, doing that due diligence again. Um, and going back to when you talked about selling, um, I mean, people should know that when like we get hired a lot when a company is being looked at to be purchased, they hire us to see how much risk there is. And so that it will come back to haunt you if that's ultimately your goal, right? So there's sort of like, you know, the quick growth and sell, but then there's also long-term success. But regardless of which direction you're gonna go, their compliance is something that people are taking into account now when they're purchasing a company.
SPEAKER_02So, what's the one piece of advice that you want to leave our listeners with as we face this volatile market that we're heading into and all of these potential changes that are going to be coming? What can they do today to kind of safeguard for the future?
SPEAKER_01Well, the best piece of advice I could give people is do the right thing. That is uh ultimately, I think, what will drive success long term, if that's what you're looking for, is long-term success. But do the right thing, work with people that agree with what your mission is and what you're trying to accomplish. Um, and don't forget that the customer is the ultimate decision maker in the whole process, right? So it really doesn't matter where we go in our industry, we're just following the consumer and the customer. Um, and they want to be treated, you know, a certain way, they want to be handled in a certain manner, and you don't want your business tied to something that will give you a bad reputation. And so do the right thing.
SPEAKER_02Do the right thing and get compliant and know who you're working with. Like don't just accept anybody into your program, actually do your due diligence on these guys before you let them in. Gayla, it's been an absolute pleasure to have you on this podcast talking about some of the changes that are happening in the US, which I really hope that you guys will start to set up your Google Alerts and listen to and and read and keep abreast of, because that is part of your job as affiliate managers. Um, but also if you're managing international programs, you know, maybe stop by Jeffrey Shield's website and have a look at what they do to see if they can help you uh remain, remain or become more compliant. It's been an absolute pleasure to have you here talking about the past, the present, maybe where we're going to be in the future, and sharing all of your knowledge on industry regulation and compliance in the performance space.
SPEAKER_01Thank you so much. This is great.
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