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One of the things I’ve seen while working with dozens of clients and hundreds of people on NHB+ is that many of them underestimate the power of the Facebook algorithm.
To fully harness it, we need to give good data back to Facebook.
And these new restrictions prevent us from not only giving good data back to Facebook - they can prevent us from giving back ANY data.
These new restrictions could be the death sentence for many businesses…
…unless we know how to respond to them so that we can still get good data back into the Facebook algorithm.
That’s why the call we did last week in NHB+ was all about how to adjust to these new restrictions on Meta.
And since this is such a timely issue affecting so many people, I wanted to give you guys a sneak peek into the golden nuggets dropped every day in NHB+.
There’s so much confusion about this issue. Every single day I’m getting multiple people hitting me up asking about this and wanting to know what to do. So here’s what I’ve said to them (this is what I taught on the NHB+ coaching call last week) and here’s what you need to know…
What’s going on:
Facebook has started placing advertisers into categories like health and wellness, financial service, personal hardship, nationality, politics, race, and others.
Advertisers in these categories may face data restrictions, such as being unable to send lower funnel events to Facebook. So no ability to send purchases, initiate checkouts, leads, or scheduled calls. The health and wellness category seems to be the one hit the most and hit the hardest so far.
To check your categorization, head on over to Events Manager > Data Sources > Then select your pixel > Settings… then scroll down and click on “Manage” under “Manage data source categories.”
To see what events, if any, you have blocked, right under “Manage data source categories” scroll down and click on “Review” under “Manage event blocking.” Then you’ll see a tab for your blocked events.
If you get categorized or face restrictions, you will likely get emailed from Facebook too.
My thoughts on why this is happening:
The FTC has already started bringing cases against health and wellness companies for sharing sensitive data. Things like creating custom audiences with an email list or even just sharing pixel data with Facebook was interpreted as sharing sensitive data. This was seen as a violation of HIPAA rules.
The logic is… if you had a site selling info on managing diabetes, then anyone who would buy that would have diabetes. So, the logic goes, just by sharing that purchase event with Facebook you have passed along sensitive information about that person’s health status.
That’s why Facebook is moving to prevent you from sending those events.
My personal theory is that the FTC went to Facebook and Google and told them to get this mess figured out and to get it figured out quickly. (Or maybe involved it was the FDA or the HHS… there are multiple organizations in HIPAA).
So the word came from the higher-ups at Facebook that this restriction had to happen - and now the engineers and implementers have to put it into place.
That’s my theory because this entire thing feels RUSHED and very chaotic.
We were only notified of this massive change in November. It just came out of the blue. And the communication was so poor - no one knew definitively what was going on. Meta reps were trying to figure it out, advertisers were trying to figure it out, and there were rumors flying around left and right.
There has been very little official communication from Meta, and all that we have is incredibly vague. All we hear officially from Meta is “this might happen” or “this could happen” or “maybe this might almost halfway kinda happen at some point but we will tell you nothing definitively.”
And after weeks of not knowing what would really happen, the restrictions have started.
But even now, this has been implemented very inconsistently by Facebook.
Some health advertisers aren’t categorized. Others are categorized but they don’t have restrictions. Others are categorized but only have light restrictions, and then others have heavier restrictions.
Because everything is so chaotic right now, I don’t trust anything I hear about what’s coming in the future. Not that people aren’t genuine - but I don’t think anyone knows what’s going to happen, not even Meta employees and reps.
Is this a problem?
For some categories, it’s not an issue. I have clients right now who are classified as “Religion” and they just had to make sure they used Core Setup. I can post more about Core Setup later, but basically it’s not a big deal. It’s just a minor hiccup that you need to learn to get around. (In short, just be careful of how you’re creating custom audiences and custom conversions… but more on that in a later post.)
But for some advertisers (particularly health and wellness), Meta has stricter restrictions - and that’s a big deal.
If you can’t send the purchase event (or add to cart, initiate checkout, schedule, lead, complete registration, etc.), that’s significant.
It’s like that data doesn’t exist in Facebook. You won’t be able to see it in Ads Manager. You won’t be able to effectively optimize for purchases, because Facebook effectively sees no purchases coming in.
That’s a big deal.
That’s a really big deal.
However…hopefully the fix isn’t too horrible.
How NOT to fix this
Let me make this clear - this isn’t a problem with the tech you use to send these events.
So the solution is NOT Conversions API or feeding in offline events or some other tool to get the standard purchase event into Facebook.
You can send it all day - but Facebook will refuse to accept it. It’s like Facebook just ignore it.
They don’t want to accept this data because that makes them responsible.
Second - the solution is NOT some third party tracking tool like Wicked Reports or Hyros or Triple Whale or Google Analytics.
Those may help YOU see the data that’s missing in Ads Manager, but it won’t help FACEBOOK see the data that’s missing. So the algorithm won’t be able to effectively optimize (not even close). And that’s a massive problem.
Third - I would not advise doing anything like creating new accounts or new pixels in order to circumvent these restrictions.
I don’t know what will happen - but Meta is not taking this lightly. So you may be setting yourself up for a HUGE world of hurt if you try to do something like that.
What is the solution?
So there are three main solutions that I’ve seen passed around and have advised people to try.
- Use Instant Forms (aka Lead Forms). Because these pass data on-platform, some people have been able to use these when passing the standard lead event from a landing page was impossible. (Just don’t ask questions about personal information like health.)
One media buyer took my advice and started using Instant Forms to get leads when he was restricted - and it saved his results and saved the relationship he had with the client. - Use retargeting strategies - such as a top of funnel video views campaign, with engaged viewers being retargeted to your lead gen or sales page.
This is probably the least attractive option and would really only work if you had a somewhat high ticket product. - The most common solution - and the one I’ve seen work the best - is to use custom events.
Remember, we are restricted from sending STANDARD purchase events to Facebook.
But you can still fire a custom event when someone purchases.
Just give your custom event a generic name that doesn’t indicate any health info (like “Event1” and not “BoughtDiabetesBook”).
If Facebook is receiving this custom event, they can go to the FTC or FDA or HHS and perhaps have a plausible case that it is not health-related sensitive information.
And that’s all they care about. They don’t care that someone purchases on your site - they just want to protect themselves legally.
I do have media buyer colleagues who have been advised that custom events are considered circumventing policies, but I have heard from others that it is not.
(Like I said earlier - it’s chaotic and I don’t believe anything I hear from anyone.)
I personally believe custom events won’t be an issue based on the little documentation I’ve seen from Facebook - and based on the common sense that Facebook just wants to protect themselves legally.
Making sure custom events work:
There’s a big problem with a custom event though.
When you use a standard purchase event, Facebook can easily optimize for it - because it understands what a purchase means.
Even if you had a brand new account with a brand new purchase-optimized campaign, Facebook would still understand to go after buyers.
It knew what that standard event meant.
But with a custom event, Facebook has to get enough data to understand who is triggering that custom event.
If you just fire up a campaign optimizing for a custom event right off the bat, Facebook may be really confused about who to show the ad to.
It may take a good deal of spend to get a good deal of data before Facebook can properly optimize.
But there are some ways to fix that: - If you’re not restricted now, set up custom events immediately and begin getting data on those custom events while you still run your standard purchase-optimized campaigns.
- If you’ve already lost the ability to optimize for purchase, you can still launch a campaign that is telling Facebook to optimize for purchases.
You won’t get any purchase data sent to Facebook from this campaign, but you may be able to get a trickle of current buyers to train your custom event.
You may try duplicating that and duplicating that as long as you are actually getting real purchases - and this will train your custom event. - If you can do anything to get buyers by other means like email traffic, organic, other platforms - then that will help train your custom event on what a buyer is.
- There are ways you can work with a developer (likeFahir Mehovic) to take a buyer list and fire the custom event for buyers. (This is more sophisticated than just uploading a buyer list to Facebook.)
For reasons I won’t get into right now, I would try to select buyers who are as recent as possible - last 7 days would be ideal if that’s enough data.
(There are way more advanced ways to do this too that we can discuss later - like having multiple custom events for different recency time frames.) - You could even get a list of people in a certain market. For instance, there are tools that can give you a file of people who were searching yesterday for phrases like “how do I manage my diabetes.”
Then you could fire a custom event on these people the same way you would in option 4 above.
(There are many downsides to this, though.)
Note: I’m not a data compliance expert, so I’m unsure if #4 is white hat or gray hat. And I would imagine #5 is likely black hat. So I’m not going to advise you to use those - I only mention them for the purposes of education and helping you brainstorm better, more compliant solutions.
Where will this go in the future?
I’m not too worried about this long term.
First, I think Facebook wants to figure out ways to take your money. So they’ll figure out ways to protect themselves while still giving you results.
They’ll figure it out eventually, but for now there’s a period of chaos and adjustment.
It’s just like iOS14. It was hard at the time - I can remember talking with fellow media buyers and we were worried our careers were over.
We had to do goofy things like verifying domains and setting up our events in AEM (Who remembers that?). But now things have mostly adjusted as well as they can.
Second, I think the change in leadership in the US will affect things.
Zuckerberg seems to have gotten close to Trump. We’ve also seen the US mention heavy investments into tech and AI
So I think that may influence the way the FTC, FDA, and HHS handle these issues.
(Of course, State Attorneys General can still enforce HIPAA issues - so anything can still happen.)
Final words
Weeks ago, I was sharing these changes with a health client and catching him up on all the latest happenings.
His response was great.
These changes could be an opportunity. If we’re affected, our competitors will be too.
The cream rises to the top.