Navigating Compliance And Risks header

Navigating Compliance And Risks In Affiliate Networks At LeadScale

Written by Nicholas Ng on November 6, 2023

Over my recent years at LeadScale, one of my many “hats” has been to lead the Supplier onboarding process concerning Publishers. It is fair to say that I have seen all shapes and sizes of companies and have noticed risks and trends in how specific Publishers and networks work.     

The primary goal of the Compliance onboarding process is to understand how a Publisher/Network works. It also aims to evaluate any risks associated with how their processes align with any applicable legal and regulatory frameworks in which they run.  

Our assessment helps us accurately assess “the bigger picture” of what working with a Publisher will look like. It also provides insight into the inferred risks that LeadScale and its clients may encounter. This occurs if they enter into a relationship with that Publisher. 

As our company motto outlines, we help our clients decide on which relationships to invest in and which ones to let go.   

One of the most noticeable trends I have seen is that of Affiliate Networks.    

As a preface, not all Affiliate Networks are problematic. This blog is just a note on some of the issues a company may face while working with a Network that doesn’t prioritise its output quality.    

Inadequate Due Diligence

My primary concern with Affiliate networks relates to the processes they follow when onboarding and auditing suppliers of lead data.   

From my perspective, it seems that many Networks run a stand-offish approach focused primarily on the quantities of Publishers they can onboard rather than on focusing on a handful of quality Publishers. 

I have noticed that an average Affiliate network onboarding process will ensure that a Publisher agrees to a contract. This contract outlines the marketing channels they will use, which GEOS they will use, and if they have updated their privacy policy. This will be followed by a few terms and conditions obliging a Publisher to ensure that their data processing will comply with its legal and regulatory obligations.   

This approach seems to be a pre-emptive “risk diversion” rather than an actual risk assessment. Potential information security and privacy risks for the Network are offset via contractual obligations and air-tight, appropriately worded indemnities. Still, little attention is paid to evaluating a Publisher’s compliance with its legal obligations under Data Protection Laws. There’s also little understanding of how its processes align with industry standards and limited visibility of how the company implements proper safeguards to protect Personal Data. 

If Supplier relationships are managed effectively, a Network will be able to understand the quality of its Publishers and address any risks to itself and its clients.  


As an Affiliate Network undertakes LeadScale’s supplier onboarding process from the perspective of a Network owner, LeadScale would only be able to understand the functions of the entity managing the Network. Often, little would be known of the Publishers themselves until much later.  

The Publisher is in control of the management of the core components of an Advertising campaign (the channels used for the collection of data, the control of advertising materials used on capture points, the method of collecting data, the control and presentation of consent statements, and display of privacy policies).  

Ineffective onboarding processes can obstruct an Advertiser’s perspective of the privacy concerns associated with working with a specific Publisher. They can also create a false impression of security. 

If you want to know more about LeadScale onboarding process, feel free to email me or add me on LinkedIn.

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