Facebook implemented sweeping changes to its paid advertising platform on August 26, 2019. These changes were in response to a series of lawsuits by civil rights organizations that argued that Facebook had enabled discriminatory ad practices. In particular, plaintiffs claimed that Facebook’s ad platform allowed advertisers to target Facebook users with housing, employment, and credit/loan ads through varied personal attributes including race, gender, age, ethnicity, sexual orientation, and religious views, among others. 

While Facebook has historically been an effective microtargeting tool that enables advertisers to reach niche audiences, it can also serve to exclude or deny opportunities to individuals or groups based on these and other personal attributes.

New HEC policy means major changes for ad targeting

As part of the settlement, Facebook agreed to change its advertising policies and the manner it sells ads pertaining to housing, employment, and credit/loans. The result was the creation of the new Housing, Employment, and Credit (HEC) flow in Facebook’s Ads Manager. This reduced the list of targeting options by removing over 5,000 targeting segments describing or appearing to relate to protected individuals or groups. Going forward, any qualifying HEC ads must be marked as a “Special Ad Category” campaign and will be subject to the following targeting restrictions:

• Age: Audiences must include ages 18 to 65+.
• Gender: Audiences must include all genders.
• Location: ZIP code targeting will no longer be available. Targeting will be limited to addresses, cities/towns, states, regions, or “pin drops” and must have a minimum 15-mile radius.
• Lookalike audiences: The ability to target lookalike audiences will no longer be available.
• Interests: Ads may only target interests for inclusion; the ability to exclude interests will no longer be available.

How does Facebook determine HEC ads?

While Facebook requires advertisers to self-identify any HEC ads, they also subject ads to an automated review process. This means that even if an advertiser does not fall within the special ad category, they are still subject to the new ad policies. Additionally, Facebook takes into consideration the landing pages ads are driving to and therefore have the potential to be flagged as HEC content on this basis.

When do HEC ad policies fully go into effect?

Facebook’s ad policy changes were enforced in late August and applied to all new and edited ads created via Ads Manager. Any ads that were active prior to this date were unaffected. However, by early 2020 Facebook plans to retroactively apply ad policy restrictions to all campaigns that may fall under the HEC Special Ad Category.

How does this affect Kasasa checking Facebook campaigns?

Facebook’s ad policy changes did not affect any Kasasa checking Facebook campaigns that were active prior to the enforcement date. However, any campaigns that were created after August 26 were flagged as HEC ads and therefore disapproved. Although Kasasa is not currently running credit or loan ads, the Facebook algorithm has falsely flagged Kasasa checking ads both because they are part of the banking industry and because the landing page is linked to a financial institution’s website that can potentially have both loans and credit.

Under these guidelines, Kasasa’s Facebook campaigns would be subject to the HEC targeting restrictions. Although we do not exclude ad audiences by interests or personal attributes, it does affect campaigns in the following manners: 

• Location: Currently campaigns are primarily targeted by ZIP codes. Without the ability to hone in on ZIP codes, campaigns will have to target certain geographic points with a minimum 15-mile radius.
• Age: Kasasa’s ad campaigns currently target 24-65+. The audience age will be expanded to include 18-24 year olds as well.
• Lookalike audiences: Kasasa targets lookalike audiences based on page behavior. While this option will no longer be available, Special Ad Audiences may be created from this and other source audiences with limited attributes — excluding attributes that may be deemed discriminatory.

Although Facebook’s ad policy changes constitute a significant change to the ads platform, there are several targeting methods that Kasasa utilizes that will remain unaffected. Kasasa will continue to have the ability to retarget audiences based on online behaviors and will also have the ability to upload and target customer lists.

Can Kenshoo help?

Kasasa uses Kenshoo, a digital advertising technology platform, to run and optimize campaigns on our clients’ behalf. Kenshoo currently has the ability to save ad set targeting via Personas. This allows traits to be assigned to created Personas including target age, geography, and interests. While these Personas are built within the Kenshoo platform and appear to bypass Facebook restrictions, ultimately they are used to create ads that must be imported into Facebook and are subject to the same ad policies and review process. Ultimately, Kenshoo is unable to help with HEC targeting restrictions and must adhere to Facebook’s advertising policies.

Where do Kasasa’s campaigns currently stand?

Although Facebook’s algorithm has yielded false HEC positives, Facebook anticipates that the algorithm will eventually begin to distinguish and more accurately categorize ads. Until that time, we have the ability to bypass these automated reviews and submit ads to Facebook’s Business Integrity Team for a manual review. We have exported and submitted all current and scheduled ads to Facebook’s Fox Manual Review Process where an actual person reviews each individual ad. This not only allows us to bypass HEC targeting restrictions that do not apply to our current marketing strategies but allows us to address pending ad policy enforcements that will be applied in early 2020.

With this added dependency, we expect SLAs (service-level agreements) to be extended for all future campaigns, as they will have to be submitted to Facebook for manual review. Additionally, it is important to recognize that as Kasasa rolls out new products, they may be susceptible to HEC ad policy restrictions and campaigns will have to be created with these targeting restrictions in mind.

If you have any questions, please contact your Client Success Manager.