Governance – where to draw the line?

Back in the days of the wild, wild, west, gun fighters and bank robbers ran amok. Gentle folk were afraid for the lives and street brawls were commonplace. Okay, it was exciting, but reputable companies – I mean folks – stayed in the big cities and left the frontier towns to the lawless.

Aw shucks, it’s another metaphor.

The good thing about all those gunslingers and rot gut whiskey drinkers was they opened up opportunities. It was their all round recklessness that pushed the boundaries. But before these new opportunities could be truly capitalised on, somebody had to impose order.

Enter the sheriff…

The sheriff slung the drunks in jail and ran the gunslingers out of town. Sheriffs were also pretty handy with guns themselves. Not a few gunslingers were hired by towns to police their streets and gun down the ‘bad guys’. In fact, apart from the presence of the sheriff’s 5-pointed star, very little differentiated the law man from the lawless.

So, when you’re policing the streets, where do you draw the line? Okay, we’re ditching the metaphor now.

In terms of rolling out the concept of digital governance to wider audiences, I’ve chosen legislation and regulation as my entry point*. This is because, in lawful societies, the risk of legal penalty is a sufficient deterrent (particularly if you’re a big company with a lot to lose). It’s also something that attracts the attention of the board room, which, sorry, content per se does not

*I started to group together some of the more pertanent rules and regs in my previous post

But when you seriously consider what could impact on the correct governance and risk mitigation of digital content, you begin widening your scope – quite considerably.

For example, culture secretary, Jeremy Hunt, plans to publish a Green Paper setting out the scope of a new communications act by the end of this year. If you think this is just about hacking and tabloids, think again – and read the below…

Hunt gave a few clues as to areas on which he may focus, but appeared to indicate that one may be regulation of programming content on the internet.

Under the current EU Audiovisual Media Services Directive, “TV like” services, such as the BBC iPlayer, are subject to regulation. However, the level of regulation is less than that imposed upon traditional TV channels.

“Whether we are watching a broadcast live or through catchup TV services, via a TV or a computer, it is the content that matters, rather than the delivery mechanism,” said Hunt. “So should it be the case that the method of delivery has a significant impact on the method of regulation? Or should we be looking at a more platform-neutral approach?”


There’s data protection and eprivacy and the implications of the European Data Protection Framework (EDPF) Review (don’t ask me, I’m new here) and the Digital Economies Act; some might say the latter was rushed legislation aimed at pirate downloaders and which now seems to be languishing somewhere in Brussels. PRS for Music, which brings together the two royalty collection societies MCPS and PRS, is also looking at the whole area internet piracy and controlling copyright online.


  • The EUs general concerns and overall remit around data protection and how personal data is used.
  • The ongoing digital implications for copyright and its infringement including ideas floated by the Hargreaves Review.
  • The impact of changes to internet protocols.

Then there’s the whole area of cyber security , the Government’s plans for a cyber security strategy, the implications of the Home Affairs Committee inquiry following last year’s riots, a warning from head of GCHQ’s about a ‘disturbing’ level of cyber attacks, as well as high-profile security breaches involving big names such as PlayStation and Google.

It’s not that organisations and governments are not increasingly on their toes when it comes to critical issues such as hacking and data protection. As early as its 2008-2009 report, the UK’s Intelligence and Security Committee raised concerns about the potential threat posed by cuber crime, not only to the UK government,  but also ‘critical national infrastructure and commercial companies’.

We therefore welcome the fact that this threat has been recognised and that cyber security is now listed as a Tier One national security risk. The new funding that has been made available, as part of the SDSR (Strategic Defence and Security Review), to fund cyber security work is a significant step forward.

Source: 2010–2011 Annual Report, Intelligence and Security Committee

All fine and dandy. But its the next bit of their latest report which attracts my interest…

Whilst the priority and funding are to be welcomed, structural issues continue to cause us concern. We have noted 18 units with particular responsibilities in this field across the three Agencies, two law enforcement bodies and five government departments. Between them they cover policy, management, intelligence operations, protective advice, detection and analysis, with some focused on crime, some on hostile activity from overseas, some on Counter-Terrorism and others covering all three. This risks duplication and confusion and cannot be cost-effective. We therefore recommend that work be done to rationalise the existing structures.

Source: 2010–2011 Annual Report, Intelligence and Security Committee

Some 18 different agencies all getting their head around cyber security. Cooks? Broth? Anybody?

I think there is a real danger that as the digital wild west becomes the tamed west that we could end up in a situation where the streets are populated by too many sherif’s, firing off their six guns for offences no more horrendous than jaywalking. I’ve read the phrase ‘governing the internet’ more than once and frankly it worries me. Didn’t Canute try something similar?

But it’s not all bad news…

After the gun  and the guns for hire, and the early day sheriffs who relied on their quick draw, there came judiciary and laws than formalised the processes for identifying bad from good and exacting appropriate penalties. That’s where I think we now need to go with digital governance.

Those of us involved in content, its creation and implementation are ideally placed to step into and exert our  influence in this area. I used the word ‘influence’ rather than, say, ‘control’, after careful thought. Think traffic police rather than Big Brother. It’s all about enabling the flow of communication while mitigating the risk of pile ups.

We already act as the linchpin for a whole range of disciplines. The image below was created by Richard Ingram and is one of many of his stunning visualisations that go towards explaining our turnkey positioning.

• We already have, and continuing to improve, a range of tools and methodologies that allow us to guide clients in project choice, rationale, implications and implementation.

• This is alongside the deploying of the actual content itself across an increasing array of channels and delivery mechanisms.

• To this array of tools and services we ‘simply’ need to  add governance tools and methodologies, such as a suitable content risk matrix that will allow us to identify the more important issues that clients need to address – and mitigate.

I’m going to show you what that content risk matrix might look like in my next blog.


Why content strategy is no miracle cure

Penicillin, central heating, Spanx… could be termed ‘miracle cures’ (okay, so some antibiotics don’t work as well these days, but I’m wrestling with analogies here – cut me some slack). What I mean is that once they’re applied their impact is almost instantaneous and evident. I live in a world which is warmer and where I suffer less strep throat thanks to two of my analogies.

If you want to know more about Spanx, consider why actresses strutting their stuff down the Oscar red carpet never wobble or bulge. Ever.

But content strategy isn’t Spanx. For a start, it isn’t one thing. It is a lot of expertise housed within the brain of a person demonstrating content strategising abilities and which includes “established disciplines – such as communications and editorial planning, marketing, content and author development, with new disciplines such as digital workflow planning and management, auditing and behavioural insight, social media and traffic analysis”.

The preceding bit is within inverted commas because I’m quoting from the content strategy course that CDA runs through emarketeers and where the emphasis is very much on skills development. » Web content strategy training course: Maintain control of content planning for online projects

We can also define CS as a range of solutions, supported by tools and methodologies. CS is Spanx, personal trainers, Botox, dieting, cosmetic surgery, gatric bands, cunningly cut designer gowns,  make up artistry… plus other stuff that Hollywood celebrities will go to the grave without revealing. Miracle cure it isn’t. It takes time. It’s painstaking. It’s more than just contouring underwear.

image shows website in corset going down red carpet while onlooker says "If you set aside the discovery work, data analysis, UX, taxonomy and brand work, the training, the TOV, style guidance, and the content management approach, this website’s transformation has been nothing short of miraculous "

Yet there is an assumption from clients that content strategy might cure content ills in an out of the box way. Just slip the website, say, into its figure-defining support and it can strut its online stuff down the red carpet, ready to pick up an Oscar or two from an adoring user base.

If anything, CS has more in common with a good personal trainer who will figure out why your content is unfit. A good personal trainer will devise diet plans (what goes in) and excercise regimens (outputs). He or she will get to the bottom (so to speak) of your bagel dependency and adapt your programme as you get more fit – or fail to. It is an ongoing and evolving process. The bulk of the work is going on inside.

Okay, where I am headed with all this…

Well, part of me is questioning whether we are in danger of defining CS as Spanx sometimes? Are we guilty of allowing clients to think they can buy (and we can price) this stuff in a box? Do we name it too often as if it were a single thing? Do we appear to promise it as a miracle cure rather than a fitness programme? Take two pairs of Spanx and see me in the morning?

When I run the web content strategy training course I am constantly considering how movers and shakers within orgnisations conduct themselves and get thesmelves and their proposals taken seriously. A Finance Director wouldn’t define is skill set as finance directing. So, if I’m not a content strategist – what am I? Answers on a postcard please…

part of web page from emarkteers site which promotes the courseWeb content strategy training course

There are places left on the July 18 content strategy course in London. » If you’d like to book a place you can do so here

Why the Spanx analogy Anne?

I was at an awards evening in London a little while ago and was in conversation with two fellow content strategists, when the miraculousness of Spanx and ordering them online was revealed to me, forever linking CS and Spanx in my head. You know who you are…




Why does less cost more?

The lab rats and I have been pondering the quality v. quantity question recently. A lot of what we deal with as content strategists seems to rest on a (client?) perception that content is relatively low cost and readily available. Everybody can write, right? (And lots of people can pick up a camera to create moving or still images – which are also content, let us not forget.) The big money is in the code and the technology, the build and the maintenance, even the search and findability aspects of a project.

Sometimes I just drive out into the countryside, find a lonely hillside and howl “WRONG!!!” at the moon. Other times I sit in the office and ponder what we’re really dealing with here in terms of perception / mindset… It’s an interesting ponder.

The congility and Publishing expo logos And as I’m going to be speaking around this subject a little at next week’s Congility @ Publishing Expo in London on March 2 I’ve been pondering more than uusual.
» The lab rats go to Congility @ Publishing Expo

Scarcity and monetary value have long been linked. It’s one of the reasons why I don’t have a platinum bathtub or a 2 carat solitaire diamond ring. But underpinning the scarcity-value proposition is a far more fundamental one – supply and demand…

As soon as demand exceeds supply in the monetary model the price starts to rise. Financial markets are founded (and occasionally founder) on this principle. So there’s an automatic hardwire in our brain that takes us from less to less costs more.

Bloody publishing battles

This has created some bloody battles that started happening long before the internet was a glint in the eye of  Tim Berners-Lee. For example, traditional newspaper publishers have been fighting price and circulation wars for years (I speak as a former journalist and editor). Newspapers compounded things by introducing the more costs less approach, battling for readers by slashing prices and offering newspapers composed of myriad sections, a glossy magazine and a free DVD if you’re lucky.

And then the internet came along and there was even more more. We filled this virtual world with websites, emails, text messages, blogs, social media hubs and all this  information composed of bits and bytes that can now be squeezed onto flash drives, themselves as cheap as chips. The entire Library of Congress could be digitised and secreted in a gnat’s armpit.

cartoon showing two stick figures looking a jewller's window. the window is full of laters of the alphabet and words. one man is saying to the other: I remember when you could buy a whole alphabet and still have enough left over to get a fish and chip supperSo, where does that leave us? Is more always going to be cheap? Does it deserve to be anything else?

Okay, so those were rhetorical questions. What we have to do is get behind the content and feel the value.

Content is a means to an end. Content brings us information, which if configured right, allows us to extrapolate value as knowledge – usefulness, if you will.

We may have lost the ability to value to content intuitively because all we can see is how much of it there is, but we can reconnect with it’s unlying value as a carrier of knowledge.

More is priceless

As a content strategist I know that, far from more containing less value it has given us something priceless. More content has allowed us to experient and ring the changes with content in a way that was not possible when all content was offline and there was less of it (or it took longer to create and was more unweildy once created).

We can flex it and change it, measure it and track it – then change it some more. We can move people seamlessly through journeys that connect across on’ and offline nodes of information (a while since you heard the old ‘node’ term huh?).

We can also think long and hard about how we monetise these journeys. I hate the term ‘paywall’. It’s not the concept I hate, it’s just the idea of a pay wall. It sounds too much like  pain barrier to me. And there’s all sorts of stuff that we’ve yet to grasp effectively. The use of moving images and interactivity, the use of the visual (eg QR codes), hyperlinking and microlinking. Maybe more will never cost as much as it should but we can certainly get better at attaching the right value it.

publishing expo March 1 and 2, Earls Court, LondonYou can find out more about where these thoughts are leading me and the rats in the lab if you come to Congility @ Publishing Expo, Wednesday, March 2, Earls Court 2, London. » Read an outline of my presentation

Online marketing comms – rules tighten. Let the seller beware

From March 1, any communication on your website that sets out to tell users about goods, services, opportunities, freebies… but where the primary or ultimate  aim is to sell something, will be regulated by the Advertising Standards Authority (ASA).

The ASA is the UK’s independent advertising watchdog, responsible for controlling marketing communications in all media in the UK. (They work with statutory partners such as Trading Standards, the Office of Fair Trading and the communications regulator Ofcom.)

The March 1 changes cover the marketing communications of all organisations operating from the UK on their own websites and in other non-paid for space online under their control eg Facebook.

The ASA talks about copy a great deal in its guidance but their remit could easily extend to any type of content, for example a home page video or a viral campaign on YouTube.


The ASA’s extended remit may come as a surprise to a lot of organisations (the ASA’s own cross-media advertising campaign was only launched at the weekend). As always the big question is who’ll get their knuckles slapped first, for what and how hard?

The ASA’s punitive powers already include obliging broadcasters to comply with ASA rulings but  it’s also brought in some new sanctions from March 1 including “an enhanced” name and shame policy. And paid-for search advertising that links to non-compliant marketing communications may be removed with the agreement of the search engines.

It’s also important to keep in mind that marketing content that falls under the scope of the ASA’s remit may not necessarily include a price or seek an immediate financial transaction. Let the seller beware.

The change falls under the scope of UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (the Committee of Advertising Practice / CAP) Code.

CAP decided to extend the digital remit of the ASA in response to formal recommendations from a cross-section of UK industry, including the Internet Advertising Bureau. Nick Stringer, director of regulatory affairs for the IAB stresses that self-regulation must maintain pace with today’s fast-moving digital environment and changing consumer behaviour. “The ASA’s extended digital media remit aims to protect internet users and enhance their trust, as well as industry and political confidence, in the medium.”

What’s covered:

  • advertisers’ own marketing messages on their own websites, regardless of sector, type of businesses or size of organisation
  • marketing communications in other non-paid-for space under the advertiser’s control, such as social networking sites like Facebook and Twitter.

What’s not covered:

  • classified private advertisements
  • press releases and other public relations material
  • editorial content
  • political advertisements
  • corporate reports and investor relations.

User generated content?

ASA points out that generated content (UGC) that has been adopted and incorporated within an organisation’s own marketing communications could be covered. This will be considered on a case by case basis.

For example: “ASA is likely to take a very different view of a consumer’s positive comment that has been posted, by the website owner, in a prominent way on the front page of its website, than if that same comment appeared within the context of a consumer message board moderated for harmful and offensive language or images only”.

How to make sure you comply

CAP is offering guidance and courses. The IAB has also including some useful FAQs on its website. From a content strategy (CS) perspective the key thing is to make sure that all your content is fit for purpose and doesn’t fall shy of any regulation.

While the March 1 changes are the latest, many websites fall short of what’s required elsewhere – for example Part 3 of the Disability Discrimination Act which covers access and came into force back in 2004. Ringing any bells? It means your website must be accessible to blind and disabled users and this should be influencing everything from colour choices to meta data.

Content audits and the use of copydecks are just two of the CS tools where regulatory or legislative requirements could be captured and verified. Even without the weight of law, large organisations need to be running tight ships – eg who wrote it, when, who signed it off? Clearly defined and maintained internal content creation processes are a must. And let’s not forget content training that not only improves content creation skills but raises general organisational awareness of why all content, on’ and offline is so important.

Apart from anything else, if you can demonstrate you did your best to comply with this law or that regulation, the punitive response maybe be less harsh than in organisations where content is chaos rather than king.

Useful links

» More about the CAP guidance
» IAB Extending the digital media remit of the Advertising Standards Authority FAQs PDF