Janus, the Group’s Code of Ethics, sets the key principles and behaviors applicable to all employees when performing their job, such as respect for others, confidentiality and avoiding conflicts of interest.
Since its creation, the Group has always refused to participate in partisan campaigns (no political campaigns), a stance that is quite rare in the communications sector. These rules apply to all Group employees and are a fundamental part of the Janus Code of Ethics (accessible on the CSR page of the Group’s website).
Publicis Groupe conducts business-to-business communications operations. The Group’s direct challenges are linked to systems made available to Group clients (for their brand name/trademark, products, services, etc.).
With regard to data protection, Group experts take part in different multiparty working groups at both the national and international levels to examine best practices, existing and future standards and the consequences of the latest and forthcoming regulatory developments. The shared goal is to improve the transparency of the new modes of communication and interaction with end users. The Group is indeed firmly committed to the ideas of trust; free will and free choice of citizen-consumers (see Section 4.3.2 below).
In terms of inter-professional activities, Publicis Groupe has for several years been a member of the Coalition for Better Ads, which brings together all key players in the ecosystem (companies and trade organizations) around the common goal of improving online advertising standards. While it is clear that this finances many digital activities, it also has to better meet the expectations of consumers. One of its important areas of focus concerns the non-intrusive nature of advertising and the technical standards to be respected, notably regarding data protection.
(Also, see CSR Reports since 2009 and commitments given for example, concerning OBA – Online Behavioral Advertising, or AOD – Audience on Demand).
The Global Data Privacy Office (GDPO) is overseen by the Chief Data Protection Officer, whose role is to check and improve the Privacy program, a private data protection program, on an ongoing basis, in a world that is subject to constant change. The founding principles of this program are monitored by a Privacy Steering Committee, combining functional and operational roles. The appointment of Privacy Leads as well as Data Privacy Stewards in individual countries makes it possible to comply with different regulations such as the General Data Protection Regulation (GDPR) or the new Californian framework (CCPA).
On an operational level, the Group’s agencies comply with data protection laws. With the support of the GDPO, the teams have to design their plan on the basis of the privacy by design principle, which requires close cooperation with project teams from an early stage, building in personal data protection and system security issues, via the review and assessment of technical solutions, liaising with the corresponding client-side teams, as well as cooperating with external partners. The GDPO works closely with the Global Security Office (GSO, see below). He or she is the first port of call for any internal (employee) or external (clients, suppliers, partners, etc.) or any stakeholder query regarding data protection matters (privacyofficer@publicisgroupe.com).
In 2019, the acquisition of Epsilon and the final stages of bringing the Company into compliance with the Californian regulation (CCPA) allowed for a new change of scale. Epsilon’s Privacy team was incorporated very rapidly, whilst ensuring business continuity and with the same level of responsiveness as the project teams.
Data usage is central to the communications systems put in place for all Group clients. While various aspects require specific expertise, every employee must have a good grasp of certain fundamental knowledge on this matter.
The GDPO is the guarantor of the application of and respect for procedures, the updating of internal training on these matters, and participation in global industry bodies. The GDPO is part of the Group’s Legal Department, reporting to the Secretary General (the Global Data Disclosure Policy can be found at www.publicisgroupe.com CSR section).
