Repermissioning for GDPR

Transcription

1 Repermissioning for GDPR

2 Permission-based marketing is getting tougher. The GDPR and eprivacy reform mean that marketers need to review existing permission processes to make them more transparent and easier to use. While that is difficult enough in itself, a bigger problem is the existing data we all have. The draft ICO guidance offers some help, saying that: You are not required to automatically refresh permission in preparation for the GDPR. But it s important to check your processes and records in detail to be sure existing permissions meet the GDPR standard. Where existing permissions don t meet the GDPR s high standards or are poorly documented, you will need to seek fresh GDPR-compliant permission, or identify a different lawful basis for your processing, or stop the processing and delete the data. Repermissioning for GDPR 2

3 How to re-permission your list If you ve identified that your existing data and mailing lists don t meet the GDPR standards what can you do? Looking at the ICO commentary around the Flybe and Honda cases, ICO Head of Enforcement, Steve Eckersley said: Businesses must understand they can t break one law to get ready for another. While the ICO is clear around what you shouldn t do, there is very little guidance on what you can do or how to go about this sort of campaign. The following isn t legal advice. Before running re-engagement, re-permission or any other campaign to upgrade permission to GDPR standards, you should accept that there is risk involved. You should always make sure you understand your data and your legal basis for marketing to these recipients. If you are in any doubt you should seek legal advice or contact the ICO s free helpline. That being said, there are things that we can all do to make repermissioning campaigns safer and more successful. Repermissioning for GDPR 3

4 Things you should do Instead of sending an asking people to opt-in or confirm consent, a softer approach would be an campaign asking customers to verify their contact details and preferences. As part of the forms which allow your customers to verify and update their details, allow them to update their marketing and communication preferences too. Use language appropriate for your target audience. The Manchester United Stay United repermissioning campaign was an excellent example of a compelling message, explaining to fans exactly what they get from . Don t expect a single to get everyone to opt-in. Create a repermissioning campaign over a series of weeks, or even longer. Give both yes AND no choices in your s. This is essential if sending more than one If you only give one option (to opt-in or opt-out) you don t know who missed the message and you don t know who to re-target. In a longer repermissioning campaign, use messaging which increases in jeopardy. Keep language neutral to start, escalating to the final which explains that they ll be removed from the list. Use all channels Don t just use . When people log into websites, place orders, call into a high-street branch or phone you, and when sending information in the post, use all these opportunities to try and get your customers to verify and update their details. And, once you ve refreshed your lists you should keep your marketing permissions and preferences up to date. Throughout the year you can use campaigns and website signposting to show your customers how they can modify their content preferences. Repermissioning for GDPR 4

5 Things you shouldn t do Don t send re-permission to anyone who has opted-out of marketing or where you have no evidence of your legal basis for marketing. Don t coerce or force your customers. It may still be possible to incentivise your repermissioning campaign to some extent there is often a benefit to signing-up to receive s. However in order to make sure permission is freely-given, marketers can t make consent a condition of a service, can t unduly incentivise and must be careful not to cross the line and unfairly penalise those who refuse. If you use an incentive in your campaign, don t make the call to action all about an incentive. The call to action should still be about the permission. Don t bundle permission for marketing with other terms and conditions. Don t send large volume re-permission s in one go. Batch them up and test your responses, working through your list from newest to oldest.? Things you should consider Testing. The consequences of a poorly run re-permission campaign are that you may end up losing valuable subscriber and customer data from your lists. Test subject lines, imagery and layout. And test variants of your re-permission messaging. Send to most recent data first. Batching data into segments based on age will allow you to send to the most recent, most active, most valuable data first. Working backwards through your list you can identify when response rates start dropping or when risks start increasing. And that s where you stop! Preference centres. Give your customers and subscribers more choice in the content rather than a single binary choice. Provide multi-channel alternatives. If they don t want to receive s they may be interested in following you on social media. Repermissioning for GDPR 5

6 Would you like to hear more? Watch our on demand webinar! Click here to view the webinar Want to ask a question? Get in touch! tellmemore@communicatorcorp.com +44 (0) Communicator, Thomson House, Groat Market, Newcastle, NE1 1ED, United Kingdom