LOOK INTO PROGRAMS THAT ARE SPECIALIZED FOR THE PROPERTY MANAGEMENT INDUSTRY.
AUDIENCE CATEGORIZATION TOOLS CUSTOM AND MIRROR AUDIENCE TOOLS These audience targeting tools are used for advertising purposes. They let a user narrow down the viewership of advertisements by specific categories, like gender, age, location, etc. A common method of targeting certain audiences is through the use of manual drop- down menus or pre-determined filters. These programs are similar to Audience Categorization tools. The distinct difference is that instead of the program targeting its audience based on predetermined filters, the advertiser uploads a custom data set and uses characteristics to target specific consumers.
Mirror audience tools are used to find consumers who are similar to the consumers on a customized list, which can be helpful for finding new users in an audience not found in an original data set.
The way ads are filtered based on these audience targeting tools can often be discriminatory under the Fair Housing Act, as they may limit the information certain protected class groups have access to.
Custom data pools can include illegal bias when they are limited by protected characteristics.
RISK
RISK
If you’ve been using programs with tools like these, rectifying a possible violation can be tricky. The best course of action is to review these custom data sets. Are they recommended by your advertising program, or are they created by your property management company? In either case, the data sets that are input should be reviewed to ensure that protected categories are excluded. Promptly review and edit any active advertisement campaigns if you have found media that could be found to be discriminatory. When revisiting, consider running separate ad processes. For example, you can still utilize an advertising program to run campaigns, but don’t rely on the provided data sets or let the program automatically implement AI suggestions. Another option is to look into programs that are specialized for the property management industry and are aware of the different parameters HUD has set. This can further help to avoid potential discrimination liability.
How can you be proactive? The first step is to analyze the data that your advertising program is collecting. If certain filters being used directly or indirectly include protected categories, such as gender, parental status, or country of origin, then you risk a violation. Ensure such filters are removed from your advertising process as soon as possible and implement policies to ensure such filters are not used in the future. You can also consider researching and utilizing a different program. Revisiting these programs is a vital part of staying fair housing compliant, which includes conducting regular, manual audits of any ads the program produces. If you have active advertisements, regular monitoring is highly recommended to ensure that specific filters aren’t accidentally in effect.
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