Since its creation, the Groupe has always refused to participate in partisan campaigns (no political campaigns), a stance that is quite rare in the communications sector. This rule, which applies to 100% of the Groupe’s employees, is included in Janus (accessible on the Groupe’s website, CSR section). Janus, the Groupe’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.
Publicis Groupe conducts business-to-business communications operations. The Groupe’s direct challenges are linked to systems made available to Groupe clients (for their brand name/trademark, products, services, etc.).
With regard to data protection, Groupe 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 challenges 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 Groupe 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.
Regarding education Publicis Groupe has, for 10 years now, participated in “MediaSmart”, a European program (PubMalin in France, www.pubmalin.fr) designed to help primary school teachers teach 8-11 years old critical thinking skills relative to advertising, as part of a joint initiative with media representatives, teachers, consumer associations and regulatory authorities. The Groupe also participates in the MediaSmart Plus program aimed at high-school students and their teachers.
The GDPO (Global Data Privacy Office) is a team of experienced professionals, experts in Data protection issues, working under the supervision of the Chief Data Protection Officer, whose role is to constantly check and improve the Privacy program, a data protection program. The GDPO reports to the Secretary General. The Groupe’s policy is publicly available on the Groupe’s website, in the CSR section.
The GDPO manages the data protection compliance program, advises agencies in their projects for clients and assists them in their risk analysis. The GDPO represents the Groupe in various professional bodies or joint initiatives, such as the IAB EU’s Transparency & Consent Framework, and the IAB, US CCPA Framework. From an operational point of view, the GDPO draws on itsGlobal Data Privacy Operations Team (GDPOps), including Privacy Leads and Data Privacy Stewards in the various countries, in order to lead the compliance program. The GDPO and GDPOps teams work closely with the GSO, the Global Security Office (see below).
The data protection policy is based on the principle of Privacy-by-Design and must constantly ensure that the teams apply best practices and act in compliance with applicable laws, whether it is for example the European GDPR (General Data Protection Regulation) or the California Framework (CCPA). This very early stage approach facilitates cooperation with all teams from the earliest stages of a project, so that data protection is well integrated into systems and solutions, and in close contact with client-side teams. The following principles are applied: a) ensure that each applicant can exercise their rights; b) review data protection policies and procedures; c) carry out regular assessments during the operation of the project to identify any problems and intervene if necessary.
The field of data protection requires expertise, and Publicis Groupe also makes all employees accountable, considering that everyone should understand and apply the basic principles, and thus ensure their obligations in relation to their role in the project. Every year all employees are required to follow a refresher training on the fundamentals of the provisions of the laws relating to data protection and security.
Data protection issues are centralized and each employee can directly contact the GDPO and its teams: privacyofficer@publicisgroupe.com.
