At the beginning of March the Information Commissioner’s Office (ICO) published its draft consent guidance for the General Data Protection Regulation (GDPR) which could have far-reaching consequences for UK businesses.
Without the ‘right’ consent in place many businesses may struggle to legitimately send marketing campaigns to their customers and may be required to re-permission their entire customer database. There has been much discussion about the significant impact these changes will have on a business’s ability to engage with their customers and generate revenue from their marketing campaigns. But the change also creates an additional unintended consequence when it comes to data suppression.
Smaller campaign volumes result in a reduction in the amount of returned mail. Many businesses, especially in the banking sector, rely on deceased and gone away notifications from these returns to keep their data up to date and accurate. Without this source of data, they will need to find alternative ways – such as using external suppression files – to keep their databases accurate and compliant.
GDPR is a legal requirement. Failure to comply with the Regulation’s requirements carries the risk of severe financial penalties. The Regulation states that personal information must be kept up-to-date and accurate. Any inaccuracies must be corrected or erased as quickly as possible and personal information should not be kept for longer than the purpose for which it was originally acquired. Deceased data that no longer serves any purpose should therefore be suppressed (if there is no purpose for keeping those deceased records on file). Failure to do so is a clear technical breach of the Regulation.
What’s more, a new requirement of GDPR is breach notification: the ability to notify individuals in the event that data has been lost or stolen. Notification needs to take place without undue delay and only those living persons at risk should be identified. If a business has not suppressed or flagged the deceased in its customer database, it will clearly not be able to meet this requirement. Suppressing in the wake of a data breach is the wrong time to take action.
Failure to put the right processes in place to ensure data remains accurate and up to date could represent a technical breach of the Regulation and incur a financial penalty to the tune of 2 per cent of global group turnover, or €10 million. It is therefore crucial that businesses – particularly those that still rely heavily on returned mail to keep their databases up to date – include suppression within their wider data review as they prepare for May 2018.
If you regularly screen your data using a deceased suppression file you would expect to have clean and accurate data. However, you may be surprised to discover you could still have significant numbers of deceased customers in your database, leaving you at risk of non-compliance.
Unfortunately, it’s a common problem. Misconceptions about suppression files mean many data managers are completely unaware that solutions they have been using for years are failing to suppress all their deceased data. What’s more, because they believe they’re working the problem often goes undiscovered for many years.
Over time this results in large numbers of undetected deceased records and inaccurate non-compliant data. With GDPR being implemented since May 2016 the consequences could be serious and far reaching. So how can companies make sure their strategy doesn’t fall short of the standards required?
Here, we dispel some common misconceptions and offer guidance on what every data manager needs to know about deceased suppression.
You don’t need to evaluate your deceased suppression strategy
Firstly, keeping personal data accurate and up-to-date, and deleting or rectifying inaccurate data, is a compliance requirement, not a nice to have. A lack of awareness of how your suppression strategy is performing is unlikely to be accepted as an adequate excuse for holding inaccurate data. For more information on the rules and standards set out by GDPR download the ICO’s overview.
Secondly, the suppression market has evolved, products have changed. If you’ve been using the same file for several years it may contain very different data today, then when it was first licensed. And that may mean it’s no longer effectively removing your deceased customer data.
We recommend you evaluate your strategy at least once every three years. It’s a simple process and provides assurance that your solution is still fit for purpose and remains compliant.
If you use a bureau to manage your data suppression most will be happy to audit your data free of charge, and share the results so any ‘gaps’ in strategy can be addressed.
KEY TAKE-OUT: Evaluate your suppression strategy at least once every three years to ensure it’s working effectively and your data remains compliant. When using a bureau, make sure you understand any suppression strategy decisions they make on your behalf and the reasons for making them. Question them if you don’t understand as it’s your responsibility to explain your data suppression strategy under GDPR.
If you are using a deceased suppression file your customer data is compliant
Whilst this may be true, the only way to be certain is to evaluate all the suppression files in the market and implement a solution that is accurately removing all your deceased data. There are two important questions to ask:
- Is your solution removing all your deceased data?
Are you certain that the solution you are using is the ‘right’ one for your data? It’s important to understand how each of the market suppression files performs before deciding. Relying on a single suppression file rarely identifies all known deceased.
- Can you trust that the data is accurate and reliable?
Does the suppression data have a strong provenance? You need to understand how the data is sourced and verified: How many sources and types of data have been used to create the file? How have they been collected? Is the data derived or volunteered? How has the data been verified? Verification is critical; if an individual is identified as deceased across several independent data sources it corroborates accuracy. Volunteered data is rarely as accurate as data captured as the result of a transaction (a policy being cashed-in or cancelled for example).
KEY TAKE-OUT: Evaluate to ensure your solution is removing all your deceased customer records. Always check how the suppression data has been sourced and verified. Data that reaches the market quickly has a commercial advantage – the process of verification takes time – so always check the suppression data you license has undergone stringent checks.
All deceased suppression files are the same
Although it’s true that all the suppression files on the market have a level of overlap, they contain different data sources that have been collected and verified in different ways. Each file will contain ‘unique data’ that will never be found on any other file. And if those unique customers happen to be in your database, but not in your suppression file, your customer data will remain inaccurate.
One of the UK’s largest insurers recently evaluated all the leading market deceased suppression files and found their database contained over 89,000 deceased customers. This worryingly large number had gone undetected by all the suppression files they previously relied upon to keep their data clean.
Also, don’t be fooled into thinking that the overall size of a deceased suppression file is all that matters. It’s important to audit how many deceased records each file identifies on your own customer data and how recent those deceased records are. Biggest isn’t always better.
KEY TAKE-OUT: The overall size of a deceased suppression file isn’t all that matters. Unique data is an important factor to consider when choosing a suppression file; those deceased customers may be sitting in your database.
You only need one deceased suppression file
This is a rather bold marketing claim and one that we don’t feel is justified. Even though our deceased suppression file contains at least 30% unique data when compared to the other two market leading files, saying you only need to rely on one file alone is certainly not a claim that we would make. The only way to be sure you have the right file(s) is to evaluate all the options and choose the combination that performs best for your business.
KEY TAKE-OUT: Always evaluate suppression files to choose the optimal blend of files, you won’t achieve adequate coverage and protection with just one file.
With the introduction of GDPR in May 2016, there’s never been a more important time to make suppression a priority. With so many common misconceptions about data suppression leading to inadequate solution choices, it’s imperative that data managers evaluate all the available options and base their file selection on fact. It’s the only way to be sure that the solutions they chose deliver reliable and accurate results and help them to achieve compliance with GDPR
A gang has been identified and two men jailed after being found guilty of committing identity fraud. The victim, Minh To of Stockport, Greater Manchester was targeted by criminals who transferred the deeds of his £500,000 five-bedroom home and attempted to auction his property.
The fraudsters targeted Mr To’s mail and stole utility bills. They then forged his signature and transferred the deeds of his home falsifying the documentation required to auction his property. Mr To was alerted to the deception by his daughter who saw his home on Rightmove for sale just three days before the auction was due to commence.
This case further highlights the risks of fraudsters intercepting mail and using it to commit identity fraud; one of the fastest growing crimes which is estimated to cost the UK approximately £5.4 billion per year.*
Criminals often target mail as it can contain lots of personal information. The most obvious of these being financial details such as bank statements and credit and debit cards. Unfortunately, consumers are often less aware of the risk of other mail, much of which still contains a wealth of information that fraudsters can put to good use.
How to avoid being the victim of identify fraud
The safest way to avoid being targeted is to ensure that all mail is safe. If a consumer moves home, they should change their address with all organisations that send them mail as soon as possible to ensure it doesn’t end up in the wrong hands. Unfortunately, we know that this doesn’t happen in practice and many people simply forget to tell everyone. In fact, research shows that when asked to rank the organisations that people would tell when they were moving house respondents categorised just five types as ‘essential to inform’.
Typically, the top tier was advised of a new address within three weeks of a move. Important organisations were told within two months and non-essential organisations (including many heavy direct markers such as retail, charity, and entertainment) were not told at all.
We always advise our clients sending mail to screen their data against goneaway and deceased suppressions to help to minimise the impact of mail not reaching the intended recipient. It’s not enough to rely on consumers updating their personal details. With ‘potential opportunities for fraud’ to add to the long list of reasons to screen data, it’s easy to see why it’s a no brainer for any responsible marketer.
* Source – Annual Fraud Indicator 2016, PKF & Experian.
If you knock at the front door of one of your customers you will know when they answer whether they are the person you are trying to reach, but how do you ascertain whether your direct mail communications are reaching the right person when you can’t visit each and every home you are contacting?
Thousands of people move home (in some cases leaving the country altogether) every year and this figure is increasing, but the lowest priority these people have is updating their contact details with every company they have ever done business with; updating address details with banks, credit card companies, utility suppliers, mobile phone providers, loyalty cards, pension providers, solicitors etc. can be a mammoth task alongside the general hassle of moving house. Perceived as an unimportant activity for a mover, it is unsurprising that customers fail to inform companies about a change of address.
The incoming tenant often has to deal with months of unwanted post addressed to people that have long since moved away, and many people throw this away instead of returning it to the original sender. Although a lot of direct mail is returned each year as a result of house moves and people wishing to unsubscribe from future mailings, there is a huge amount of direct mail that disappears into landfill, never reaching the intended recipient nor making its way back to the sender for removal. Further to this, many companies never action these returns, or take so long doing so that sending continues, despite having the information that some people have moved or do not wish to receive any further communications. This inaction on the part of the originating company can lead to negative perceptions of the business and its practices.
Research by The Software Bureau indicates that each piece of returned mail costs the originating company £4, yet many companies continue to print and send mail to these obsolete addresses, quickly amassing a huge bill that could be avoided through undertaking regular database cleansing. Estimates put a figure of 40% of returned mail being due to unsubscription requests, and 60% being due to goneaways. Printing and sending communications to addresses that are no longer related to a genuine customer is a waste of money and resources; funds and time that could be more efficiently assigned to attaining a cleaner and more reliable database.
One reason businesses do not remove goneaways from their databases is to avoid incurring the associated costs, but this is a short-sighted view as the costs of continuing to mail people who are not there will far outweigh that of keeping the database clean. Using a cleansing file like Re-mover means your database will be up to date to within one month of all house moves at any given time – that is much quicker than relying on new tenants to return the odd bit of unwanted post. If a direct mail campaign involves sending several iterations or reminders about a service, there is every chance that time and money has been invested in contacting a customer who has moved. If the new tenant then eventually returns all the unwanted mail you could be looking at a cost of £40 per record over a period of a few months – this adds up fast and cuts into the available marketing budget as well as skewing ROI figures.
Companies that regularly use Re-mover and other suppression files will see a much better return on investment from their campaigns, a lower overall campaign cost (due to reduced print and postage costs) and a much better reputation for not sending unwanted or irrelevant postal communications.