Dear Mark Zuckerberg: Please don’t ban political ads on Facebook
Dear Mark Zuckerberg:
I am a performance marketer who has spent the last seven years utilizing Facebook to advertise mobile games and apps. By a conservative estimate, I believe that I have overseen a quarter of a billion dollars in advertising spend across Facebook, Instagram, and the Facebook Audience Network.
Additionally, I ran the digital marketing campaign for a Texas House candidate in the 2018 midterm election. I know the power of Facebook’s advertising platform in reaching a massive audience for the purposes of both commercial interests and political activism. And because I grasp that power, I implore you to not withhold the reach and relevance of Facebook’s advertising platform from political advertisers.
Twitter recently banned political ads from its platform, and I believe that its decision was a mistake. As you’ve noted yourself, Facebook is a utility: a social communications utility that facilitates connections between people and ideas. I think it is incumbent on the largest social media platforms to create an environment in which safe, verified, credible political speech is possible; it is an obligation.
Facebook has the largest and most targetable audience of any advertising platform that has ever existed. The word “targetability” is often wielded as an insult to impugn digital platforms on the basis of privacy invasion, but it is also an incredible tool for performance marketers to use in matching content with the people that care about it. There’s no question that Facebook is superior to traditional advertising channels for exposing specific people to relevant messaging; for political advertisers, Facebook’s platform is unmatched in terms of reaching people with advocacy on the issues that matter the most to them.
What’s more, Facebook is where younger voters are reachable: television viewership skews older, and thus political television commercials serve to activate older voters. According to the New York Times, the youngest median viewer age of the Top 10 most-watched television shows in the 2017–2018 season was 47.8 for Empire (with the oldest being 58.6 for The Good Doctor). Facebook is the most effective channel with which to engage young people on the political and social issues that affect them. The issues that matter to young people are unique: their voting participation will naturally decline if they can’t engage with political messaging.
Finally, Facebook has more resources to deploy against abuse than potentially any other consumer platform. The will of campaigns to reach potential voters will always exist, and campaign budgets must be deployed somewhere. If Facebook bans political ads, then political advertisers will simply spend their budgets on other platforms which, almost by definition, will have invested less money into fortifying themselves against abuse than has Facebook. Ironically, it is precisely because Facebook’s platform was abused in the 2016 election that it is the most secured against similar abuses in 2020. Platforms that have never experienced this type of exploitation will be wholly unprepared to deal with it a priori.
You cannot accept only the benefits of becoming a ubiquitous communications channel without any of the responsibilities for policing speech on it just because doing so is difficult. The reason you must allow for political advertising is that policing it is difficult: no other platform is as equipped as yours is to build the systems needed to monitor and curate political advertising. Yet others will gladly accept that revenue if given the opportunity.
I believe you have a viable alternative to implementing a wholesale ban on political advertising. I propose the following five-part framework for allowing political ads to be run on Facebook:
Limited Targeting. Not all campaigns have access to the same extent of voter data through which custom and lookalike audiences are built, and sizable custom and lookalike audiences confer massive competitive advantage in advertising targeting. In order to level the playing field, you can restrict political ad targeting to gender, age, and voting district. Limited targeting would keep ads relevant on the whole without allowing the campaign with the most data to outmaneuver competitors with hyper-targeted advertising. This restriction would also prevent campaigns from seeking to buy user data from unscrupulous sources (eg. Cambridge Analytica), as well as prevent them from exposing contradicting messaging to different sets of people, since so many people would see any given ad.
Minimum Audience Size. For national campaigns, implement a minimum reach size for any political advertisement — say, 1 million people. This means that campaigns would not be able to engage in the kind of hyper-targeted advertising that consumer app advertisers do in order to personalize messaging, but they’d still be able to present relevant messaging to specific groups of people.
CPM Only. Only allow political advertisers to run campaigns on a CPM basis (ie. they are only charged for impressions, not for conversion events like clicks, donations, etc.), and charge all political advertisers the same CPM. This would disincentivize the type of manipulative, emotion-animating ads that are utilized in optimizing campaigns for high click-through and conversion rates. Additionally, this would insulate Facebook against accusations of political bias, since all parties would pay the same rate for user attention.
Equal Time. One common component of political advertising regulation for broadcast media is an equal time restriction: that all parties be given the same opportunity to appeal to voters on broadcast channels, at the same price and with spots that are roughly exposed to the same number of people. For national elections, reserve the same volume of impressions on Facebook’s platform for all parties, giving each the same opportunity to make a case to an electorate regardless of how well it has fundraised.
Transparency. Build absolute transparency into the political advertising process. The Facebook Ads Library and political ads API are a good start, but they don’t go far enough. Allow the public to see how much money has been spent on any given political ad, how that ad was targeted, and what its click-through rate was. And don’t limit this to active ads; compile and present this data for all political ads historically. Make ads searchable by themes and keywords so that the public can more easily hold political advertisers to account for false messaging.
This framework will be difficult to implement and would require a massive commitment of resources — and almost certainly for a financial loss. But with 2.45 billion monthly active users as per your most recent quarterly report, nearly 1/3rd of the entire planet uses your company’s products every month, meaning you have a broader reach than any other utility on the planet. It is in service of that worldwide user base that you must allow for political advertising: those 2.45 billion people deserve to be advocated for and reached with relevant political campaign messaging. If you abdicate that responsibility and burden other platforms with it, you virtually guarantee that the abuse of 2016 happens again in 2020.
This post was a collaboration between Eric Benjamin Seufert and Simon Lejeune, who advised the Belgian government on strategy for implementing political advertising regulation.
Eric Benjamin Seufert is a media strategist and quantitative marketer who has spent his career working for transformative consumer technology and media companies, including Skype and Rovio. Eric runs Mobile Dev Memo, a trade publication dedicated to advertising and freemium strategy on mobile, and QuantMar, a knowledge-sharing site for performance marketers. Additionally, Eric authored the book Freemium Economics, which was published by Elsevier in 2014. Eric holds an MA in Economics from University College London.
Photo by Elliott Stallion on Unsplash
