By Jon Cano-Lopez
So, it is 184 days – or six months if you prefer – since The General Data Protection Regulation – aka GDPR – became enforceable.
In the run up to the enforcement date – and in the months following – there has continued to be a huge amount of uncertainty and misinformation around GDPR and in some cases some down-right panic mongering. The avalanche of re-permissioning messages in the weeks preceding May 25th was testament to a prevalence of some database damaging advice.
One data protection lawyer we know likened it to watching lemmings throwing themselves off a cliff!
However, despite the hysteria and here-say the threatened “GDPR data apocalypse” has not materialised. And as we reflect on 2018 and the period since “GDPR day” here are some reasons to be cheerful…
Embracing the spirit of GDPR
REaD Group have been consistent in our view that GDPR is a good thing for consumers – and for business.
And six months on, our view has not changed. In fact, we are even more confident that embracing the principles of the GDPR will only enhance direct marketing – increasing transparency and trust and leading to more positive, long term and profitable relationships between consumers and brands.
The Regulations are not about catching out businesses (who are doing the right thing!). They are about the enforcement of practices that should be in place anyway. Keeping your customers and their rights, privacy and preferences at the heart of your business and being transparent in how you are processing personal data will not only help to protect you from the risk of fines but also enhance your brand reputation, value and relationships. Ultimately, if you are doing things right, it will be reflected in your bottom line.
The Data Economy is thriving
And although the reference to data being the “new oil” has been somewhat over-used, there is truth in the concept. Projections from European Data Market Study for the growth of data economy are extremely positive, with the value of the data economy in Europe projected to be worth €739 billion by 2020.
The rise of the CDO!
Gartner have predicted that through 2019, 90% of large organizations will have hired a CDO.
Another indicator of the growing importance of data is the rise of the Chief Data Officer (CDO) – elevating data strategy to Board level. The appointment of a CDO in many organisations – and across diverse industries – indicates a growing recognition of data as a driver of value and competitive advantage. Data driven decisioning is increasingly becoming a business imperative.
Results from the latest IPA Bellwether Report also provide cause for cautious optimism, with total marketing budgets revised higher during the third quarter of 2018, extending the current period of growth to six years.
After an initial period of post-GDPR caution and inertia, there has been some signs of resurgence for direct marketing, with many businesses successfully utilising third party data and direct mail for acquisition marketing campaigns under the Legitimate Interest basis.
The industry view is also optimistic. In independently conducted research, over 78% of direct brands asked have projected equivalent or an increase in spend on data driven marketing.
Third party data – use it responsibly and reap the rewards
Well, we have been saying this for some time, but to borrow from the recently published DMA advice: Using third party data under the GDPR.
“There is nothing in the GDPR that prohibits the use of third-party data provided that it is undertaken in the right way, with the appropriate safe guards.”
The message is clear – and provides much needed clarity for marketers. The direct marketing industry should have the confidence and conviction to continue to use responsibly sourced and permissioned third party data to optimise the quality and value of their data and data strategy.
Plus, new ways of utilising open source data have provided more opportunities to target direct marketing to addresses – using postcode level data to send partiality addressed mail.
GDPR data quality obligations – don’t bury your head in the sand!
There is a growing realisation that the data quality obligations introduced by GDPR cannot be ignored. Article 5.1 (d) is clear – reasonable and demonstrable efforts must be made to keep all personal data held and processed by a business clean and up to date -or deleted.
Our independent survey indicated those who utilise data quality services appreciate “not having to worry about the accuracy of contact lists when launching marketing campaigns”.
And data quality is now being seen as a ‘must do’ to ensure compliance with GDPR, minimise wasted communications and limit potential reputational damage.
Rapid innovation in technology is also impacting positively on data driven marketing – with developments in DaaS, AI and machine learning delivering even greater opportunities for data optimisation, enrichment and real-time interaction.
Key take aways from the last six months? Businesses and marketers should see GDPR as an opportunity to be more responsible and accountable, to get their data and data strategy in order – get it right and the future is bright!
We were absolutely delighted to be acknowledged as Rising Star 2018 at the Apteco Partner of the Year Awards last night.
Winning this Award is the culmination of more than two years of innovation and endeavor at REaD Group and reflects a true team effort.
Having been one of the industries leading data providers for more than 25 years, adding to our service offering to help clients to maximise the effectiveness of data and how it is used, was a natural next step in the evolution of the business.
As a result we made the strategic decision to increase our capability and client base. We recruited a talented solutions team, invested in our technical stack, defined a series of key objectives and focused our efforts in achieving them.
This Award is the culmination of more than two years of strategic endeavour at REaD Group and reflects the true team effort.
REaD Group Chairman and Founder, Mark Roy is extremely proud of the achievement, commenting : “The real triumph is in how far we have come in the last two years. The solutions reflected by this award, that are delivering so much value to our clients, are a fantastic achievement for REaD Group – well done team!”
To be recognised as their fastest growing partner by Apteco is a credit to everyone involved and firmly establishes REaD Group as a trusted partner for the delivery of complex engagement solutions.
Much credit and congratulations to everyone involved!
by Jon Cano-Lopez, CEO at REaD Group
In response to the DMA Advice: Using third party data under the GDPR
After almost six month since the enforcement date for the GDPR, we welcome the publication of this much needed advice from the DMA.
The clarity it provides on the use of third party data should dispel some of the hysteria and business damaging inertia caused by the ambiguous messages and conflicting advice that has abounded before and since the GDPR became enforceable in May this year.
The advice reflects a strong consensus of view from the DMA and a panel of highly experienced data industry practitioners and subject matter experts which provides further weight and reassurance to the content.
At REaD Group we have been very clear and consistent in our views on the value of the responsible use of third party data and this advice paper reinforces what we have been saying all along.
Ultimately, a responsible and common sense attitude to marketing is what is required. If processed with respect to consumers’ interests and privacy and according to the obligations of the GDPR (appropriate LIAs etc), third party data delivers huge benefits to – and in the interests of – consumers and society.
Recent campaigns using our GDPR ready database have delivered extremely positive levels of engagement and ROI for our clients. Consumers are responsive to direct marketing IF the campaigns are targeted, relevant, timely and non intrusive.
Using the right third party data – in the right way – does work!
The direct marketing industry should have the confidence and conviction to continue to use responsibly sourced and permissioned third party data to optimise the quality and value of their data and data strategy. As the DMA reiterates: there is nothing in the GDPR that prohibits the use of third party data provided that it is undertaken in the right way, with the appropriate safeguards.
My key take-away from this advice? Time for marketers to get off the fence and get marketing!
Read the full DMA advice document here
LONDON 1 March 2018
Announced at a Gala Reception at OXO Tower last night, Jon joins an impressive list of people acknowledged to have the influence, profile, experience and knowledge to drive the data-driven marketing industry.
I am delighted and flattered to be selected for the DataIQ 100. It is an honour to be recognised and to be associated with such an impressive list of data and analytics professionals – particularly at such an exciting time for the data industry.
Jon has worked in the data industry all his career, with an impressive CV spanning more than 25 years – including leading some of the UK’s largest data companies – Claritas, Altwood Systems, Acxiom, Ai Data Intelligence, Communisis and currently and now, as CEO of REaD Group – Jon has built a reputation for driving innovation and success in data communications.
He joined REaD Group in 2014, as part of the company’s exponential growth and is responsible for the strategic direction and continued success of the business – including adding some top brands to its A-list client base.
At the heart of this strategy is his belief that data sits at the heart of everything and understanding and interpreting that data is key to any brands success
In addition to building on REaD Group’s position as market leader in data cleaning and quality, he has been instrumental in developing the company’s service offerings – including an enviable insight capability and winning contracts for the delivery of Single Customer View solutions reflecting a real benchmark for REaD Group.
An advocate of utilising technology to drive innovation and deliver optimum results for clients – Jon is the driving force behind the implementation of Data as a Service (DaaS) at REaD Group. As well as raising the bar for data quality and provision in the industry, the implementation of the GDPR throws up significant complexities for data processors and DaaS provides an elegant and equitable solution to that challenge.
Jon has been an authoritative contributor to the direct marketing throughout his career holding positions on DMA’s Data Council, various working parties and the Institute of Direct Marketing Data Council. A genuine industry influencer, he is sought after as a media commentator and trusted advisor on data marketing, privacy, compliance and the GDPR.
Congratulation to Jon for this much deserved recognition!
The full 2018 DataIQ 100 can be found here
The lack of clarity in the run up to GDPR has been shocking. This statement provides much needed clarity on how to remain on the right side of the legal minefield and make the most of the opportunity that GDPR really presents.
REaD Group have been involved from the very earliest stages of GDPR. We have been at the forefront of negotiation, lobbying and discussion for the last six years. Consequently, our knowledge of the regulation itself, the intended meaning and what it means for the Direct Marketing industry is unrivalled.
REaD Group is unequivocally supportive of the GDPR. All the decisions we have made surrounding the permissions required to use third party data for direct marketing activity under GDPR have been externally validated by Bristows LLP, widely regarded as this country’s leading data protection lawyers.
REaD Group have been working towards becoming a GDPR ready business for the last three years. We have made significant changes to our own data collection methods and how we obtain, retain and maintain our data and data solutions. Our contributor due diligence processes we believe are unparalleled and unique in the scrutiny of GDPR requirements and we have enhanced our internal IT solutions.
It is important to remember the purpose of GDPR is simple; to give consumers greater control and transparency over the use of their data. Most importantly, GDPR will change marketing communications for the better – more open, more honest and more transparent and in turn that will deliver a more positively disposed, aware and trusting consumer, which has to be good for us all.
REaD Group has enhanced its safeguarding processes to ensure every piece of personal data made available to you has been collected in a GDPR ready manner. This inevitably means there will be changes to our products as we ensure that all data has been lawfully processed in line with GDPR. No data is accepted into our data estate until our due diligence and auditing processes have been satisfactorily concluded. This includes adherence to a number of significant and mandatory GDPR rules established by our GDPR Steering Group.
In the recent weeks and months there have been conflicting opinions surrounding the level of consent required for data to be available for third party direct marketing post May 2018.
The issue of consent has created an enormous amount of confusion. What is it? How is it obtained? What channels does it apply to? Or indeed, do I need it at all? Consent of course, is only one of six legal grounds to process personal data under GDPR, yet it has occupied a disproportionate amount of the airtime serving only to confuse further.
At REaD we prefer to ask – Do we have permission? In other words, do we have grounds from one of the six processing purposes? In most cases with our data assets permission means the processing of data collected either with consent or as a legitimate interest. Both of these grounds for processing are equally valid and our products will be selectable on either or both.
This means if you are planning a postal marketing campaign, you won’t need consent. You can rely on using legitimate interests, if you can show how your use of the consumer data is proportionate, has a minimal privacy impact and the consumer is unlikely to be surprised or object. To be clear, within GDPR itself, Direct Marketing is specifically singled out as a legitimate purpose.
Being GDPR ready is about balancing risk. When you decide to use REaD Group data, we advise you to conduct the necessary balancing exercise between your interests in direct marketing and the rights of the consumers. REaD Group will have conducted this exercise ourselves under our obligations as data controller. We also advise you to ensure that consumers know exactly how you intend to use their data. Our experience tells us that the more open and honest you are the better it is received by consumers.
Of course, our in-house experts will be more than happy to talk you through this note as well as your specific concerns or campaign ideas. We have done the vast majority of the work for you in building a GDPR ready data asset so we can all market ourselves confidently and securely.
Want to talk GDPR? Contact our team today.
By Mark Roy, Chairman and Founder of REaD Group
So, at last a bit of welcome news from the ICO. In black and white in new guidance for the charity sector. Consent is NOT required if you are using direct mail and relying on Legitimate Interest. Considering the amount of utter nonsense being spouted by SO many ‘overnight experts’ this is an extraordinarily timely piece of clear-cut advice from the ICO to marketers.
That said, it was rather curiously tucked away in the FAQ’s of the advice specifically designed for the charity sector. That very same sector that has spent the last 24 months, since the Etherington review, paralysed with fear of potential repercussions of using data incorrectly. Ironic really, when the mainstay of British fundraising had always been direct mail, that it is now that very same channel that will no doubt bring about the resurgence in charitable marketing.
ICO: You won’t need consent for postal marketing …If you don’t need consent under PECR you can rely on legitimate interests for marketing activities if you can show how you use people’s data is proportionate, has a minimal privacy impact, and people would not be surprised or likely to object.
Of course this doesn’t just apply to charities, it applies to any organisation that has a legitimate interest to process data, no matter what sector. It is very important to realise that when, late in the day, the EU added those 18 words to clause 47 of GDPR – namely “The processing of personal data for Direct marketing purposes may be regarded as carried out for legitimate purposes” – they meant Direct Mail!
Today, direct mail is regarded very differently from a decade ago.
70% of respondents said that mail makes them feel more valued (up from 57% in 2013). Source: Royal Mail Market Reach: The Value of mail in uncertain times, August 2017
It turns out that compared to email, SMS or voice calls it is perceptibly a comparative saint. It is remarkably unobtrusive and has the tactility to create real connections with the recipient and relay real brand value.
The ICO should be applauded for this much needed definitive advice, much more of the same is required… please! Hopefully then, and I suspect only then, will we see an end to the ridiculous scaremongering and be able to get on with running our businesses whilst continuing to protect the consumer interest.
There has never been a better time to plan your next Direct Mail campaign. We might know a thing or two about that…get in touch to explore the huge opportunity this clarity presents.