If you are marketing online, consumer protection needs to be top of mind. Most marketers understand this fact and diligently comply with appropriate best practices and regulations. However, don't forget to use the same level of due diligence in reviewing their Internet lead providers.



Caution, you can be held accountable for their practices.

Here are important points of review to consider in vetting a new lead provider:

1. Ask if they use third-party affiliates or lead generation services? If so, what is their compliance and due diligence process?

Most lead providers and brokers will purchase some quantity of traffic or leads from third-party sources. If it was your marketing department you would be expected to perform consumer protection due diligence against your vendor network--make sure your lead provider is doing the same against their vendors.

2. Ask to review an example of their standard affiliate, buyer, and vendor agreements (as applicable)?

This is the quickest way for you or your legal team to evaluate any legal exposure to your lead providers providers vendor practices. It is also a great way for you, as their lead generation partner, to strengthen the relationship with collaboration.

3. Do they have a compliance education program for their marketing department and/or third-party lead generation sources?

This is really a simple effort. Their effort can be as easy as a blog or regular newsletter, but they need to be advising their lead sources and lead providers of consumer protection expectations. This deepens partnerships and strengthens the network's overall compliance.

4. Do they have a quality control process? Does it evaluate the validity and integrity of generated leads and marketing sources?

This is a big differentiator. Some lead providers have a proprietary process for quality reviewing leads. Some don't have the technical capability to do this quality review. In which case they should be using a service like TargusInfo or eBureau.

5. Ask to review sample landing pages, ad creative, telemarketing scripts, and privacy policies used during the lead generation process?

This will be a bit of a touchy request. Most lead providers or marketing agencies view these items as trade secrets. Assure them you do not need to see placement or the entire portfolio--just indicative samples. After all, you are outsourcing your marketing department to them--exert your rights of review.

Invariably you will be carrying some risk for their lead generation practices. So, unless they are going to contractually indemnify you against these risks--do some review of these items.

6. What is their policy for dealing with relationships and marketing sources that are found to be out of compliance with relevant consumer protection laws?

Of course, all of this is lip service unless they enforce their policies. You need to take the extra step and ask them what they do in the case of compliance breach.

Get Educated on Consumer Protection

If you have not already education yourself on consumer protection laws and regulations, it is time to do so. Learn not only what the laws are, but what consumers expect from their online inquiries. Here are some smart places to look for more information:

* FTC: Consumer Protection Information

* FTC: Online Marketing Guidelines

* IAB: Consumer Privacy Standards