Jo Young joins UniFida

UniFida has appointed Jo Young as Client Director to join its growing team. Jo is a leading data consultant with extensive marketing analysis experience across multiple disciplines including digital, database, research, econometrics and pricing.

Speaking about the appointment, Julian Berry, Founder at UniFida said: “We’re very excited to have Jo on board. She will be working with existing and new clients, helping them to access deeper customer insights and deliver customer experiences that drive sales and maximise marketing returns, using our CDP and marketing attribution solutions. She will also help further develop innovations such as our CO2 counter for marketing.”

Jo YoungPreviously Jo launched an award-winning econometrics division and, in her former role as Director of Innovation at R-cubed, she led ground-breaking projects to combine first-party marketing attribution with econometrics for leading-edge media measurement and optimisation.

Jo has worked at some of the UK’s leading data consultancies, pushing the boundaries of what is possible with data, analysis and technology with companies such as Lakeland, John Lewis, AXA, TUI, Cancer Research, Unibet, P&G, Arriva, American Express and O2.

Google Analytics is illegal according to the Austrian DPA, but UniFida has an alternative

Austrian DSB: Use of Google Analytics violates “Schrems II” decision by CJEU

In a ground-breaking decision, the Austrian Data Protection Authority (“Datenschutzbehörde” or “DSB”) has decided on a model case by NOYB that the continuous use of Google Analytics violates European data protection regulation, GDPR.

This is the first decision on the 101 model complaints filed by NOYB, the European Center for Digital Rights, in the wake of the so-called “Schrems II” decision. In 2020, the Court of Justice of the European Union (CJEU) decided that the use of US providers violates the GDPR, as US surveillance laws require US providers like Google or Facebook to provide personal details to US authorities.

Similar decisions are expected in other EU member states, as regulators have cooperated on these cases in an EDPB “task force”. It seems the Austrian DSB decision is the first to be issued.

Max Schrems, honorary chair of said: “Instead of actually adapting services to be GDPR compliant, US companies have tried to simply add some text to their privacy policies and ignore the Court of Justice. Many EU companies have followed the lead instead of switching to legal options.”

SCCs and “TOMs” not enough

While Google made submissions claiming that it had implemented “Technical and Organizational Measures” (“TOMs”) – which included ideas like having fences around data centres, reviewing requests or having baseline encryption – the DSB rejected these measures when it came to US surveillance (see page 38 and 39 of the decision).

“With regard to the contractual and organizational measures outlined, it is not apparent, to what extent [the measures] are effective in the sense of the above considerations. Insofar as the technical measures are concerned, it is also not recognizable (…) to what extent [the measure] would actually prevent or limit access by U.S. intelligence agencies considering U.S. law.”

Max Schrems said: “This is a very detailed and sound decision. The bottom line is: companies can’t use US cloud services in Europe anymore. It has now been 1.5 years since the Court of Justice confirmed this a second time, so it is more than time that the law is also enforced.”

Decision relevant for almost all EU websites

Google Analytics is the most common statistics program. While there are many alternatives that are hosted in Europe or can be self-hosted, many websites rely on Google and thereby forward their user data to the US multinational. The fact that data protection authorities may now gradually declare US services illegal puts additional pressure on EU companies and US providers to move towards safe and legal options, such as hosting outside of the US. A similar decision on EU-US transfers was reached by the European Data Protection Supervisor (EDPS) a week earlier.

In the long run, there seem to be two options: either the US adapts baseline protections for foreigners to support their tech industry, or US providers will have to host foreign data outside of the United States.

Max Schrems added: “In the long run we either need proper protections in the US, or we will end up with separate products for the US and the EU. I would personally prefer better protections in the US, but this is up to the US legislator – not to anyone in Europe.”

Google LLC does not fall under Transfer Rules?

The DSB has rejected claims against Google LLC as a data recipient, holding that the rules on data transfers only apply to EU entities and not the US recipients. However, the DSB said that it will investigate Google LLC further in relation to potential violations of Article 5, 28 and 29 GDPR, as it seems questionable if Google was allowed to provide personal data to the US government without an explicit order by the EU data exporter. The DSB will issue a separate decision on this matter.

Max Schrems said: “For us, it is crucial that the US providers cannot just shift the problem to EU customers. We have therefore filed the case against the US recipient too. The DSB has partly rejected this approach. We will review if we appeal this element of the decision.”

The decision is not dealing with a potential penalty, as this is seen as a “public” enforcement procedure where the complainant is not heard. There is no information if a penalty was issued or if the DSB is planning to also issue a penalty. The GDPR foresees penalties of up to € 20 million or 4% of the global turnover in such cases.

Max Schrems added: “We would assume that there is also a penalty for the EU data exporter, but we only received a partial decision so far that does not deal with this question.”

NOYB has published a deeper legal analysis on

UniFida does not use Google Analytics and instead uses Matomo to download data from clients’ first party websites. The Matomo data processing is all undertaken in Europe and so does not violate the GDPR. See

Cutting marketing budgets

Wielding the axe on marketing budgets – how can you cut creatively?

In today’s challenging times, many organisations are looking to reduce their marketing budgets while minimising the overall impact on sales.

Of the £20 billion+ spent per annum on marketing in the UK, the challenge is to identify which parts of a marketing budget are actually wasted. If you Google ‘How to cut my marketing budget’ you will find yourself flooded with generic advice, but no specific guidance on how or where to wield the axe.

So, you need to be creative. Here are some specific questions you need to ask when assessing your marketing budget allocation:

1. Which customer segments should we focus our marketing budget on?

This question should always be asked at the start of a budget reduction exercise – and the answer may not be what you expected. For instance, at UniFida we recently discovered that for an insurance client of ours their least affluent customers were providing the highest longer-term value per sale.

As well as investigating specific market segments, you should look at splitting your investigation between the impact of marketing to recruit new customers compared with spend on existing customers. Both will respond in very different ways to similar campaigns.

2. Should you start your investigations at a channel or a campaign level first?

The problem with starting at a campaign level is that you are very quickly swimming in the weeds. You may find that there are literally hundreds of campaigns when you look across all your channels and by axing individual ones you are ignoring what their cumulative effect is, as well a potentially stopping, say, the worst ten emails, when in fact they perform better that some of your AdWords campaigns.

We suggest you start at the channel level and aim to get to the same marginal ROMI (Return on Marketing Investment) for each one. If you can achieve this then you will have a perfect channel level budget distribution. The marginal ROMI can be described as the return from making a small increase or decrease in the spend for any channel.

To measure marginal channel level ROMI you will need some quite specific tools, a description of which comes later.

3. Having fixed your channel level budget allocation, how do you progress with campaign pruning?

An initial risk is that some campaigns do not need to be axed – they may just need better targeting, or revised content. Clearly these problems need to be dealt with before any cuts are undertaken.

Then, turning to the individual campaigns, you must regard each one as part of an overall marketing ecosystem that, working in combination, encourages customers to undertake customer journeys that may or may not end in a sale.

steps in customer journey diagram

So, you will need to judge the effectiveness of the campaign in terms of how much it contributes overall towards the journeys that lead to a sale, but you may also be interested in the role it plays in initiating, holding, or closing sales.

To achieve both of these you need to know where events created by the campaign crop up in your customers’ journeys and what impact they have. As an example, a social media campaign may be very good at getting new customers to visit your website, but it may need some PPC support to get them to actually purchase.

What specialist tools do you need to achieve all this?

All this will only become achievable when you start examining your marketing effectiveness at the granular level, i.e. each step in a customer journey. A step may be receiving a catalogue, opening an email or a visit to your website from a referrer.

In combination, and ignoring indirect channels like press or TV for a moment, these steps in your customers’ journeys are what marketing delivers. On average there are around three steps preceding each sale, but some journeys will consist of one step, or others twenty.


The right tools for the job

With this in mind, you need a tool that gives a value to each step based on its contribution towards a sale and allows you to aggregate these steps up to all those created by a campaign, and then up again to all campaigns that take place in a channel. (Interestingly there are many questions around timing in this as well because campaigns can have long tails).

This requires technology to link online and offline customer journey steps and then give to each step a weighting based on the contribution it makes to the overall journey.

Alternatively, if you are looking at indirect channels like press and TV, then you need to introduce an entirely different technique, ’econometrics’, which will also determine the value they contribute towards your overall sales. Econometrics works in a very different way by examining the impact of changes in the spend in any channel over time on the overall level of sales.

How UniFida can help

UniFida provides a one-stop shop for delivering the tools and services for both of these approaches – customer journey attribution for direct channels’ ROMI and econometrics for indirect channels. We can also help with a proof of concept to demonstrate just how effective these approaches are.

For more information email [email protected] or call + 44 203 9606472.

UniFida logo

UniFida is the trading name of Marketing Planning Services Ltd, a London based technology and data science company set up in 2014. Our overall aim is to help organisations build more customer value at less marketing cost.

Our technology focus has been to develop UniFida. Data science business comes both from existing users of UniFida, and from clients looking to us to solve their more complex data related marketing questions.

Marketing is changing at an explosive speed. Our ambition is to help our clients stay empowered and ahead in this challenging environment.