Richy Glassberg: Vodafone Spain was just fined a record $9.72M (€8.15 million) for its vendor’s conduct! What happened? How does a major company like Vodafone get this wrong and pay for its vendor’s screw-up?
Wayne Matus: How? Because you are your ad vendor’s keeper! Vodafone Spain’s failure to monitor advertising by its vendor is what resulted in the record-breaking fine. Vodafone was found to have failed to continuously monitor the processing of its vendors, and lacked organizational and technical means to do so.
Richy: I guess I understand the large fine since they even sent messages to people on the Robinson list, which is their equivalent of our “Do Not Call.” Do you think we will continue to see fines of this nature?
Wayne: This isn’t going away. The law under the CCPA and Virginia is similar to this GDPR provision, If you can’t demonstrate that you did proper due diligence, you could be in for a wake-up call. Vendor compliance in advertising must be a major priority for every business.
Richy: At least 14 other states have introduced, or at least talked about, similar regulations. How can businesses keep up if they have 10,000 vendors, let alone 10?
Wayne: The way forward is standardized vendor management. You need to know what your partners are doing. A simple note saying “we are compliant” is not good enough. I wrote a piece with Kroll’s Rich Vestuto for Law.com on this very topic. An agreed-upon assessment with precise language written to the laws, and proper internal support from executive stakeholders is imperative. Otherwise, organizations are putting themselves at a huge risk.
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