It’s not just cookies: Rebuild marketing and privacy for a new playing field



  • As privacy concerns become more and more pronounced, marketers face the end of easy, consistent access to consumer data.
  • But it’s possible to acquire the data your company needs while still respecting privacy.
  • Success will have three ingredients: A new data strategy, a new approach to trust and value, and a newly innovative technology toolkit.


A tectonic shift has begun — one that could open the door for companies to reinvent their marketing and data strategy, and potentially their whole approach to the consumer experience. To seize the new opportunities, companies will have to act swiftly.

For years, companies could rely on consistent access to consumer data gathered by third parties on the ad-supported internet. Now, key tools for obtaining this data are about to go away. Among other shifts, Google is phasing out third-party cookies and Apple has altered the rules for its identifiers for advertisers (IDFAs).

Privacy regulations and regulatory enforcement are also tightening. With ever more companies gathering and using ever more data, the risk to brands from data breaches or other privacy violations is rising. New privacy regulations reinforce the new norm. Consumers are either required to explicitly opt in to share their data or they have ways to opt out of their data being sold and opt out of receiving ads that target them. Consumers also have new expectations, not just for privacy and control, but for what value they may demand in exchange for their data.

Bar chart titled
How prepared for the changes are players in the digital ad ecosystem?
Percentage of respondents who are very or somewhat prepared for the loss of third-party cookies and identifiers. Source: IAB, State of Data 2021.

Across the business world and digital marketing ecosystem, some companies are already reacting with aggressive new data strategies. Others report a lack of preparation. Cloud and other technology providers are offering new tools and partnership possibilities. This fast-changing scenario may appear daunting, but it shouldn’t. It means that new opportunities are arising.

All companies — whether brands or advertisers — have new ways to know, reach and please their customers, new tactics for offering value and creating trust (both B2B and B2C), and a new technology toolbox for understanding consumers without infringing on their privacy.

To seize the new opportunities, companies will have to act swiftly. They can then craft a unified strategy that’s fit for a new, more privacy-conscious world.

Yet there are two main ways you could miss these opportunities while potentially assuming new regulatory and business risks. The first danger is not acting right now: New solutions are advancing quickly. Even first movers are not yet too far ahead and have yet to fully assess both the marketing performance and the privacy implications of their plans.

The second danger is if different executives — such as the CMO, chief privacy officer, chief data officer, CTO, chief trust officer and ethics and compliance officer — act independently. If different functions or lines of business look to different solutions and work off different technology and operational strategies, they can fail to unify around consumer needs. (To illustrate how unwieldy an uncoordinated approach could become, consider that the marketing technology landscape alone has over 8,000 solutions).

The new rules for understanding and reaching new and existing audiences

The rules for accessing consumer data have changed due to major shifts in digital platform policies, privacy regulations and enforcement, and consumer expectations.

Digital platforms are changing their data policies. Google parent Alphabet, as part of a declared effort to “fundamentally enhance privacy,” will phase out third-party cookies on its Chrome browser by early 2022. Third-party cookies, which track consumers from one website to another, have been a prime source of data for use in marketing, consumer experience initiatives and product innovation. Google will soon launch alternatives, but it won’t offer or use identifiers that track individuals across the internet. In line with Tim Cook’s affirmation that privacy and climate change are the top issues of the century, Apple has announced that its latest operating system requires apps to display a pop-up, through which consumers must choose to have their data tracked — including by Apple’s IDFA. Apple’s App Store also now requires that apps publish privacy “nutrition labels” with details about how the apps use consumer data. Without care, these labels could put companies at risk of regulatory actions — including from the Federal Trade Commission (FTC) — for deceptive and unfair trade practices.

Privacy regulations are growing in both number and strictness, with Europe’s GDPR, California’s CCPA and CPRA, and Virginia’s new Consumer Data Protection Act merely the tip of the iceberg. By the end of 2021, an estimated 82% of the world’s population will have data protected by basic security requirements, according to PwC’s Ready Assess database (which includes over 2,500 data privacy and security laws and regulations). ESG investor ratings are also attracting ever more attention, increasing the scrutiny of data security and privacy practices.

Consumers have long said that they want more privacy — even if they often haven’t found it yet. In a PwC survey, 76% called sharing personal information with companies a “necessary evil.” The COVID-19 crisis has accelerated privacy awareness with so much of life moving online. The result is that even as consumers demand ever more personalized digital experiences and products, they’re also seeking better privacy options. Business customers, too, are increasingly wary about sharing the data upon which their own business may depend.,

These changes may put many digital marketers in a bind, but they could also be the impetus for positive changes. Marketers face demands to be more customized and trackable so they can deliver demonstrably better ROI even as consumers are rapidly changing their purchasing paths. To meet these new demands, marketers will need identity and attribution models that can follow consumers in these new paths, paths that are often non-linear and fragmented: crossing multiple touchpoints, controlled by multiple companies, over multiple days and with repeating cycles.

It’s still possible for brands and digital marketers to acquire the necessary data while protecting privacy and enhancing consumer satisfaction. The path begins with seizing three opportunities.


Seize these opportunities: know, earn and innovate

Success in this new world will have three ingredients: a new data strategy, a new approach to trust and value, and a newly innovative technology toolkit. The foundation for all three will be sizing and understanding the impact of the changes on your business. How much do your topline and bottomline depend on data whose flow and availability may be disrupted? Your marketing, consumer experience initiatives and product innovation may all require data whose access could be threatened. Once you’ve assessed your precise risks and needs, you can advance on the new opportunities.

1. Know the consumer better

Without third-party cookies, IDFAs and similar tools, many companies have to create a new data strategy. Yet even with cookies, most companies have failed to fully access and monetize all the data that they could. To take just one example, many haven’t integrated all the customer information they already hold to create individual customer data profiles. The opportunity now is to create a new strategy that also creates new value — a resilient data pipeline, laser-focused on giving the business exactly what it needs.

Begin by mapping out what data you’re accessing now, where you’re sourcing it, how those sources of data may be disrupted and what that data is worth. You may choose to stop collecting some data if you discover it isn’t worth much. For the data you do want, your map should reveal the exact contingencies — whether technological, regulatory, contractual or due to internal data silos — that you need to overcome to gather and use it.

You may find new ways of collecting data that are more complete and cost-effective than third-party cookies ever were. You should be able to develop a data strategy better suited to customer purchasing paths that no longer line up with linear advertising models.

You’ll benefit from this new strategy whether you primarily gather data directly or acquire it from third parties — and it should help you assess whether or not you should build or accelerate a first-party data strategy. Some companies with strong consumer relationships may even find a new opportunity to aggregate and sell their first-party data to new partners. But a first-party data strategy isn’t right for every company. For many, new partnerships will prove a better answer.

Your “single-pane” view of your data, whether first or third party, can help you continue to unlock its value as the privacy environment keeps evolving. It can help you develop a data trust strategy that not only helps you monetize data but also helps you minimize its risks.

2. Earn their data — and their trust

The customer value exchange for digital marketing has changed, as a new report from the Interactive Advertising Bureau (IAB) makes clear. Consumers are no longer satisfied with the traditional exchange of free content in return for accepting ad delivery.

B2B companies face a related, perhaps even greater, challenge. Business customers can be highly cautious about sharing data. Still, like individual consumers, they increasingly expect both effortless, seamless digital experiences and customized services and products — which you can provide if you have their data.

To raise the odds that both B2B and B2C customers will choose to share their data, consider a new kind of value exchange. You (or the third parties that gather data for you) will have to explicitly offer something of commensurate value in return. This value will usually not just be privacy itself, though it will probably include transparency and power. No one likes to be tricked into anything, including sharing their data. This value will more often be about ease and convenience, a superior digital experience, premium content, or free or discounted products and services.

Whatever your data sources, how you manage your customers’ digital identities can define your brand. You should therefore consider your options carefully. The correct privacy stance and privacy customer experience will not only give you access to the data you need, it will also strengthen customer loyalty and intimacy.

Highly sophisticated data valuation models are emerging. These models can help CFOs understand how much of their revenue depends on data sourced directly and through third parties. That will help determine the appropriate value for that data. These models can also help risk managers better understand, quantify and mitigate the related risks, which should also help guide how aggressively you pursue certain data sets.

3. Innovate with a new toolkit — and new partnerships

As third-party cookies and IDFAs begin to fade, innovations are multiplying — many of which the cloud enables because, for cloud providers, the new opportunities are immense. Many are developing powerful tools and capabilities. Through a marketing cloud, your company may now be able to better measure attribution and performance for marketing across channels. It may be able to receive more focused and relevant data on every stage of a customer’s digital journey. A shift to the cloud can also accelerate innovation and growth throughout a company.

On and off the cloud, new partnerships are emerging. Many consumer packaged goods companies, for example, partner with retailers who help track business outcomes for marketing. Several telecom companies, some with direct relationships with hundreds of millions of customers, offer identity solutions.

Other partnerships are coming together within and across industries so partners can build unified customer IDs from data aggregated from their various sources. Fast-growing digital platforms — whether for streaming content, video conferences, doctors’ appointments or online learning — also offer options for understanding customers and marketing to them.

These partnerships are evolving new rules and standards for data. At present there’s little alignment — even around defining such fundamental measures as age brackets for demographics across ad formats, geographic targeting and baseline attribution models. You might want to consider engagement to shape those and other standards to meet your needs. The IAB Tech Lab and the Partnership for Responsible Addressable Media (PRAM) are two alliances worth a look.

Whether in the cloud or not, with partners or on your own, tech innovations for identity and attribution are accelerating. Here are a few options to consider.

  • Identity graphs. You may be able to piece together a consumer’s or customer’s different interactions with your company across multiple touch points into a single, coherent identity graph — a rich profile. If you can’t follow your consumers or customers across all their touch points through your access to first-party data, a cloud provider or data connectivity platform might be able to connect third-party data for you, even without cookies and IDFAs.
  • The new anonymity. New techniques enable partners to share certain aspects of consumer and customer data with each other while hiding other aspects and preserving individual anonymity. Confidential computing, for example, encrypts data not only when it’s at rest or in transit but also when it’s in use. Differential privacy is another example. It’s a technique to share information about group behavior while protecting information about individuals.
  • Data clean rooms. Data clean rooms help advertisers and marketers match up first-party data with aggregated, anonymized consumer data (including from credit card companies) to help track the effectiveness of their advertising and marketing. Several digital platforms offer data clean rooms. Some large companies may wish to build their own to get a view across multiple platforms.
  • Targeting by segments. You or a cloud provider may be able to cluster individuals with similar interests, giving you the ability to customize both marketing and products while the individuals remain anonymous. If you choose to share your own data with a cloud provider to help target segments, be sure to negotiate a partnership that protects the data rights of both you and your consumers or customers. Clear governance and shared responsibility models for compliance with all privacy laws and regulations, including cross-border data transfer considerations, will need to be negotiated too.
  • AI for synthesis. Artificial intelligence (AI) and natural language processing (NLP) tools can help you better understand and predict consumer and customer journeys from disparate data points — both anonymized and not. AI may be used to help predict what individuals are likely to do, even if you cannot track them directly.

These options are just some of the many that are emerging. Digital media is still in a phase of experimentation and innovation. Yet even without dominant models, you can’t afford to wait. We believe all companies should begin evaluating existing and emerging tools — and do it in a unified fashion.


Start here: Come together to assess, map, solve and monitor

The challenge is too big for any one function or line of business to solve. It will also be wasteful if different lines of business reach agreements with different technology vendors or partners when a single customers’ or consumer’s data crosses many business lines.

Your path toward seizing the new opportunities begins by bringing together executives from marketing, sales, privacy, finance, IT and the business. This multi-stakeholder team should consider these questions to shape their agenda and create a unified response.

Discussion agenda

Business impact

  • What data (first or third party) from consumers or business customers do we rely on?
  • How are we using this data — including for marketing, experience and innovation?
  • What is the revenue or profit associated with these uses?
  • How will our current data sources be disrupted, whether by industry or regulatory changes?

Data and privacy strategy

  • How can we replace data sources if needed?
  • What new plans do we have for using data — and what new data will be required?
  • What do consumers or business customers want in order to trust us with their data?
  • What is our current privacy stance?
  • To what extent (if any) should we develop or accelerate a first-party data strategy?

The new digital marketing ecosystem

  • Which partners can deliver identity models that keep consumer and customer data secure and uphold privacy?
  • What tools are available to increase transparency and reduce waste in digital marketing?
  • Which partners can deliver the best business outcomes in attribution models?
  • Should we consider acquiring strategic vendors or partners?
  • How can we keep up with and evaluate new MarTech and AdTech solutions?

Taking advantage of the cloud

  • How can a secure cloud provide more programmatic protection of your data?
  • What role can cloud providers play in filling gaps in audience identification?
  • How can organizations use geo-based clouds to accelerate compliance with regional regulatory requirements?
  • What new partnerships may evolve as cloud providers move further into the service and insights space?
How can we help you build trust in this era of disruption?

How can we help you build trust in this era of disruption?

Cybersecurity and Privacy solutions

Learn more

Jay Cline

US Privacy Leader, Principal, Minneapolis, PwC US


Andrea Fishman

Transformation Partner, Chicago, PwC US


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