“Turn left in 100 feet-”

“Make a U-Turn-“

“Recalculating…”

Sound familiar? We’ve all been there. As thralls to technology, we tend to put our faith in the ‘GPS machine’ when going somewhere, now low and behold you didn’t make it to Grandma’s house. Instead, you ended up at a truck stop in the middle of nowhere and the pump doesn’t take cards.

Similarly, you have probably put your trust into online technology as well – and ended up in the wrong place, and now it’s too late. They’ve got your information. The phone calls have started. You might even be wondering why you’re getting several calls from people that you never remember giving your information to in the first place.

Chances are, you’ve encountered what the industry is terming, “Black Hat SEO tactics” which utilizes different techniques designed to trick not only search engine crawlers but consumers too. This results in the visitation of sites that you think are what you want. In reality, someone has mimicked the site you wanted, collected your information on their contact form, turned around and sold your information to any number of businesses.  In that same way, as you would plug a location into your GPS to find a destination, you do a similar practice when you enter for a certain phrase or term in an online search engine.

You may be asking yourself: Why does Black Hat SEO exist? Is someone policing these sites? Why did this happen to me? Well, it all comes down to one simple, cliché fact: There’s money to be had.

Three main goals for Black Hat SEO:

  1. Drive traffic onto a specific webpage.
  2. Collect your information.
  3. Sell your information.

Utilizing these sneaky techniques allow these “Black Hatters” to drive you to the pages they want. Not the site you intended.  Oftentimes, their tactics are so covert, it makes them almost unrecognizable as anything except what they’re trying to portray and what you’re looking for.

How to Spot a ‘Black Hatter’ – Methods to Their Madness:

  • Hidden Text/Keywords/Links– This is when some web copy is made a text color that can’t be seen when viewing the webpage, as it blends into the background. These instances can cause you to click on hidden links as well.
  • Cloaking– A website owner creates certain information in their code which allows you to see it on a search engine, but does not actually display on the webpage you are visiting.
  • Social Network Spam– This is when web owners put multiple links on social media pages and posts.
  • Link/URL Buying– A website owner purchases links and industry branded URLs to syphon off more traffic from the original brand.

 

Can the Real Brand Please Stand Up?

All of these techniques make it difficult for the average prospective consumer to feel good about whom they’re sharing their information with, and which sites are legitimate. While Black Hat SEO techniques are not recommended and viewed negatively, some web admins will do the unthinkable and go the extra mile to include hidden techniques to gain more views and traffic on their webpage! The end resulting in the consumer being mislead, their private information sold many times over, and often the real brand losing credibility to their prospects. Having the man power to locate, research, find and nail these culprits aren’t typically within a brand’s personnel bandwidth. Therefore, the trend to combat them has been to contract with third parties who do this on their behalf, and on a continual basis. After all, new content is created every day.

Surfing the web can get pretty dicey nowadays. *In fact, since 2016, on average in education for every 12 websites found, at least 1 of them contains a violation under the Federal Trade Commission (FTC), Department of Education (ED) or Consumer Financial Protection Bureau (CFPB). That ratio is even higher within the finance industry where 1-in-4 sites contain a FTC, CFPB violation – all of which are deceptive to consumers and eat away at the integrity of legitimate brands.

If you have a site, you think warrants investigation, let us know by emailing: verify@integrishield.com.

*Information based on total client data.

Have you ever received a “free” lead in your inbox?  Depending on your personal experience, you may initially think it’s a free lead to let you sample what a particular lead generator can do for you. Or you may not even know how you actually got the lead.  What do you do?  Do you contact this prospect?  Your decision on how to handle the inquiry will determine how much the lead could cost you in the end.

There are a few variables to consider before deciding to contact a “free” lead.

  1. Do you know where the lead came from? Even if the lead source is listed, it’s important to know how it was generated to result in a consumer providing their information.  Did he or she know they were inquiring specifically for a product from your brand?  While you may not be able to track back the full path, at a minimum, check out the referring URL to ensure no bait and switch tactics were used.
  2. Did the consumer consent to contact, and in what forms? If you received a consumer’s contact information, it’s important that they consented to be contacted.  Because the lead is free, let’s make the assumption you did not provide authorized consent language. You must be able to answer…
    • What language was used?
    • Did they consent to be contacted by your business or only the lead generator?
    • Did the lead get to opt-in for TCPA consent specific to your business?

It’s important to have these answers because fines can add up quickly when it comes to consumer consent violations.

  1. Can you get access to the data collection of consent? You should also have access to opt-out data as it pertains to the consumer opting out on the lead generator side.  This is just as important as knowing if consent language and opt-in were available on the inquiry form.  Businesses are subject to fines and potential litigation for not observing opt-out requests.  This would also be helpful in opening up the option to email the consumer.  Email does not require prior consent, but once someone unsubscribes or opt-outs, a business can no longer email them unless he or she opts back in.  Without control of the consent language and the data being collected, emailing could be risky as well.

Businesses hold lead generators to higher standards today and justifiably so considering the regulatory environment.  Any source of a lead is subject to scrutiny and not knowing is not a defense.  Before you decide to contact that “free” lead, calculate the possible fines and don’t let it costs your brand money or its reputation.

[As published on LeadsCon.com]

On August 1, 2016, The FTC’s inflation increases for maximum civil penalty amounts go into effect. You can find the Federal Register Notice containing all of the statutes and amounts here. With penalties increasing, from $16,000 to $40,000 in some instances, it’s time again to look at your business objectively and determine what risks you are willing to take. Here are some areas, business owners and caretakers of brands need to evaluate for exposure.

Police Those Who Try to Exploit Your Brand
Your business is not responsible for what others do if you are not affiliated with them. Unfortunately, that’s not enough to keep us off the regulator radar these days. Whether you are the advertiser or the lead generator, understand the pitfalls that can occur when using third parties. Objectively ask yourself, do you know everything your affiliates or publishers are doing to market on your behalf? Take it a step further and question if you think they know everything their network is doing. No one is 100% error free online, all the time. The mere appearance of not “playing by the rules” could shine a spotlight on your business where infractions could be uncovered.

An unauthorized publisher can put you at risk for regulatory scrutiny or lead to an investigation. If a consumer can’t spot a fraudulent representation of your brand online, then regulators won’t be able to notice at first glance either. It’s critical right now to monitor and enforce standards for your brand’s presence on the Internet. Create a paper trail documenting your efforts to discover and remediate infractions.

Every business is unique, but here some things you can do internally:

  1. Keep an inventory in a database or even a spreadsheet of your proprietary and authorized third party URLs.
  2. Set up a monthly audit process to review all URLs for brand, regulatory, and consumer consent compliance.
  3. Review the user path to ensure nothing was misleading up to the form and consumer consent was collected in the correct places.
  4. Take screen shots with time/date of infractions.
  5. Email the screen shots along with a request for remediation to the third party.
  6. Store all emails back and forth concerning the remediation.
  7. Schedule a quarterly Internet audit looking for domains and URLs not authorized by your brand and follow the same paper trail and remediation process.

Be Proactive Against Those Who Seek and Exploit Violations
From consumer disclosures and consent language online to contact strategies and database maintenance, leave no stone unturned when it comes to ensuring compliance. There are opportunistic individuals who target certain industries and put themselves in a position to file a complaint or take legal action. You need to get ahead of them.

Look for and monitor all forms of disclosures, consent, privacy policies, terms and conditions, and any other industry specific data or content required. It’s a common mistake to only search for where it exists on the web. Yes, we want to make sure what we know and see is unaltered, but don’t forget to look for instances where these forms have been omitted—which is a tougher search.

Contact maintenance strategies need to be reviewed and followed. Reactive responses to violations will result in fines and suits. It may surprise you how easy it is for individuals to create the exact scenarios that equip them to file a civil suit against a business. Do Not Call (DNC) violations under section 5 of the FTC Act have increased to $40,000 per instance. If you weren’t following DNC best practices, it’s time.

Despite your efforts to maintain industry compliance on a daily basis you may feel exposed on many fronts. The regulatory scrutiny has found its way into many business operations and expense columns with seemingly no reprieve. To help mitigate risks everyone must take an active role and reduce exposure. Lead generation as an industry is strong. Remember, you are not only equipped to be successful while being compliant, but you are in a good position to write the narrative.

In the past year, for-profit schools in Minnesota have been coming under increased scrutiny. The state’s Office of Higher Education has created a new watchdog which sends out “secret shoppers” to monitor whether schools are misleading or dealing honestly with prospective students. Schools giving misleading information about job-placement rates or how much money graduates could earn in their field are just a couple of examples that would raise concerns with these shoppers.

The new state watchdog has started to compare notes with Minnesota State Attorney General’s Office.   This this office can suspend or shut down a school that gives students misleading information, including institutions that a court or government proceeding concludes they have engaged in fraud or misrepresentation.

Monitoring your staff can shield your institution from potential fines and penalties. Some areas to proactively monitor for compliance may include:

  • Scripts: Providing scripts for your representatives to follow enables them to touch on key benefits of your institution and direct the conversation toward enrollment.
  • Citing Statistics and Job Placement: When a prospect inquires about job placement or expected salaries, statistics provided must be accompanied by an official source such as the Bureau of Labor Statistics. Employment can never be promised.
  • Financial Aid: Not every student will qualify for financial aid. It is important to provide this clarification and transfer prospective students to a financial aid representative to receive further information.

Get more tips for analyzing and improving the performance of your admission staff, email Shawn Graybill or call 888-547-7110 today.

Minnesota Increases Scrutiny of For-Profit Colleges

Over the last couple of weeks, articles have surfaced shedding light on lead generating practices that are less than exemplary. Many in the for-profit sector are concerned and unsure how to move forward. With the recent scrutiny of the industry, it is important to make sure that you are doing your best to protect your organization. IntegriShield can offer helpful tips and information to keep your organization safe.

Watch for our webinar regarding fraudulent lead generation and how you can protect your organization coming in January.

In the higher education field, we all know that distance learning is the way of the future. Online learning has provided many people with the access to receive a quality education when, in the past, they have not had this opportunity. However, taking away the face-to-face aspect of education has allowed some individuals to abuse this opportunity. With the increase in the amount of people utilizing online learning, we also see a significant increase in the amount of financial aid fraud that is happening. Groups of people are starting financial aid fraud rings and making off with hundreds of thousands of dollars in Department of Education financial aid funds.

How do they do it?

These groups, which can consist of any number of individuals, submit multiple financial aid applications to schools. Typically, these schools are focused on online learning and have a low tuition cost. The individuals do the bare minimum in the courses they have elected to take to make sure they meet the participation requirements. Once they have received the excess of their financial aid funds, they disappear.

How can you detect this activity?

There are a couple different things you can look for:

  • Multiple FAFSA applications submitted using the same IP address.
  • Multiple FAFSA applications submitted using the same address, phone number, e-mail address etc.
  • Multiple FAFSA applications submitted from the same area with similar household situations (i.e. single parent households with one or more children).
  • Offenders typically pester the financial aid staff for information on when they will receive their funds. They can become aggressive and will threaten to report the person or the school to their congressman or the Department of Education.

How do you handle these situations?

  • Delay the financial aid process for these individuals as much as possible. Select for verification or require participation in online orientations or other lengthy processes.
  • If possible, set up a team of a few people from different departments to specifically identify and handle such cases.
  • Delay the posting of financial aid funds on suspicious students.
  • Report any suspicious activity to the Office of the Inspector General.

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"The quality service that IntegriShield provides gives me peace of mind regarding compliance. They work as an extension of my department to identify and resolve any misrepresentation found and serve as a resource to me regarding specific compliance questions. I highly recommend them for institutions who need a partner not a vendor." - Mary Wetzel, Central Penn College

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