The way consent to market is acquired in the call centre or online may be at odds with your data strategy. David Reed finds how to get a better mix.
Heard about the ISP which set a target of cross-selling a product to one in four of its customers via email, only to discover it had just a 25 per cent opt-in rate? Or the call centre in which agents opted-out customers from the “junk mail” programme as part of the service?
Both of these examples were provided by independent consultant Nigel Grimes, former head of insight at RBS Insurance, at this year’s Data Summit. They emphasise how important consent to market rates are to business goals and how easily unco-ordinated business processes can undermine company strategy.
That company which lacks the necessary permissions to talk to its own customers could easily be your own. “It is an area that has been neglected and a challenge that data and insight teams have to face up to,” says Grimes. “How many companies have consent rate KPIs? It isn’t on the Balanced Scorecard, so who owns it – marketing, IT, compliance?”
In the worst case he had seen, 100 per cent of customers had opted out of further marketing contact. “Most CEOs would be shocked by their consent to market rates,” adds Grimes.
The problem arises as a result of the gaps between different business processes. On one side, marketing is seeking the maximum level of contact and the most liberal consent statements possible. On the other, compliance departments may write a privacy notice which fully protects the business, but only requires a single tick to end all further cross-selling by the organisation.
Enitrely independently of these functions, the moment of data capture is often designed or enacted by people who are not only lacking in data protection knowledge, but may not even be aware of the corporate data stategy. Leave the design of a Web form to a website designer, for example, and you could find that new customers come with an automatic opt-out. It is often when a new business strategy is ntroduced that a data audit reveals these problems. But all is not necessarily lost. “Air Miles put 540,000 customers back into the database by looking at the data and changing consents in a compliant way,” says Grimes.
With multiple collection points, including third-party partners, different opt-in and opt-out statements and variations had been used. Carefully examining the wording and the way consents had been coded revealed that half a million collectors could legally be added back, with the addition of tens of millions of pounds-worth of business over a five-year period.
Simple coding errors or conflicting meta-data definitions for consent variables should not be overlooked as a common cause for this problem. Unless there is a clear and co-ordinated approach, data that should be enabling business practices could get changed into something that is disabling them.
“I have seen customers saying yes to being marketed to in the call centre then, because of the way fields have been set differently as data passes from one system to another, it ends up on the customer database as a no,” says Karen Sadler, found of Sadler Consulting. She has worked for a range of insurance, telecoms, FMCG and other companies in the specific area of data protection for marketers.
“I have seen instances where very high volumes of customers don’t know that they were opted-out, but the business has been working with this legacy of people who’ve objected. There is an opportunity for the business to resolicit those customers,” she says.
Particularly where a call centre sits at the heart of the operation and customers have frequent reasons to make contact, introducing a well-presented data protection ask into the conversation can have a significant effect on consent to market rates. In a market where acquiriing new customers is very challenging, getting contact rights back for existing customers provides a major boost.
Where Sadler identifies a particular problem is in the ellision between preferences and permission, especially in the online world. “I have worked with one financial services company that offers customers all the options and preferences about how they would like to be contacted. That is admirable, but is getting into channel preferences, rather than consent. There are hierarchies that need to be respected,” she says.
The expansion of options during online registration or transactions has been one of the key suppressors of consent rates. Faced with an extensive list of choices, from group-level down to product-level opt-out, opt-ins for email and phone or opt-outs for mail, customers may either give up or just pick at random.
Very high volumes of customers don’t know that they were opted-out
Building consent across a file needs to be undertaken in a steady, consistent and bottom-up way. There is no point winning the key consent, only to undermine it later on. Sadler points to one high street and online brand which asks customers twice during the transaction process. “So what if they say yes the first time and no the second?” she wonders.
The concept of permissions as a key strategic asset is a very recent idea. It tends to emerge when the business undertakes some type of transformation that involves data – perhaps the acquisition and merger of a new business or the creation of a single customer view to drive greater cross- and up-selling.
Once the value of consent to market has been recognised – and worked out in hard financial terms – then it becomes one of those things you can’t help noticing everywhere. If it is a piece of data that is owned by a specific function or person, then it is more likely to get applied in a consistent and meaningful way.
Richard Harris, vice-president of acquisition at American Express Card Services Europe, says: “Penetration of marketable email addresses is a valuable metric to have and one we measure in our customer base. It is reported on the dashboard on a monthly basis with other ‘drive to Web’ metrics, like paperless statements.”
Across new customer acquisition it is relatively easy to make opt-in worthwhile for customers and to achieve a high consent rate, he says. Part of the reason why customers sign up for an American Express card is precisely to find out about services and offers for members. “On our application form we collect email addresses both via online and direct mail and get a high opt-in rate,” says Harris.
The business makes it easy for members to opt-out at any time should they wish to do so, alongside the statutory unsubscribe option in email newsletters. Harris says that there has been a particular focus in the call centre on acquiring email addresses and opt-ins in order to build the consent to market rate.
The online application process has also been carefully scrutinised. “There is a higher likelihood of getting someone to opt-in to email marketing is we acquire them online. We also make sure it is not an opt-out from marketing across the board – I have come across people who have a once-for-all option,” he says.
“But there are difficult areas because of legacy platforms and customer books the business has acquired in the past,” notes Harris. “And we don’t assume that, just because we were given permission in the past, we can just email them. Often we don’t have a current email address.”
Neither consents nor contact data are static. As people move, so do their personal details, but equally, so can their feelings about whether a company should contact them or not. In the past, marketers have feared that making it too easy to opt-out will lead to a major loss of permission. In reality, the act of providing the option can often be enough to reassure a customer and keep them onside.
Coming up with permission statements that are compliant, consistent and easy to execute is a challenging task, however. Ask two data protection lawyers what the right wording should be and you will probably get three different opinions. What works online is also very different from what can be used in the call centre.
“A very common thing we come across online is for registration pages to be written with an opt-in – even though that is only required in a very small number of cases,” says Rosemary Smith, director of data protection consultancy Opt-4. “That can happen by mistake and because nobody is really paying attention to the data capture.”
If web designers can get this wrong, so too can customer services representatives. “It is very hard during a call to phrase something as an opt-out, rather than an opt-in. It is easy to say, ‘would you like us to send you information about our products?’. That is an opt-in. It is less easy to say, ‘please say if you would prefer not to hear from us’. That is an opt-out,” says Smith.
Laws and guidance around permissioning are complicated, especially the fact that you do not need opt-in for emails promoting similar products or services of which somebody is a customer. You do to cross-sell another company’s product via a standalone email. But you can include limited cross-sell messages in emails about the main product.
“A common situation we see is where there are differences of opinion within the organisation where one part believes that is has got a specific relationship with the customer and has opted them in at a very high level – possibly even over-the-top. At the other end of the business, they may have been careful not to over-option but a failure to opt-in will override a negative option,” she notes.
Political issues like this can get in the way of unifiying the permission process (and creating a single customer view with clear contact flags). Steve Lomax, managing director of Experian Cheetahmail, also points out that, “the more complex the channel structure and the more service based the brand, the more of a potential issue this is.”
If a customer uses a service often and is therefore in frequent contact, perhaps via the web as well as the call centre, then the opportunity to change permissions arises more regularly. That is what can give rise to inconsistent flags and settings, especially if the message about giving permission is not clear and compelling.
That is why Lomax argues in favour of a low level option linked to a preference centre. “Customers can then set specific communications preferences and may go up or down, rather than just given them only one option,” he says.
Equally, a permission is not always that valuable. Bhavesh Patel, senior data planning manager at Haygarth warns: “We have seen examples of people coming in from a competition and opting-in just because they want to enter. They are not really interested in hearing about the brand.”
Permission is a valuable thing that needs to be nurtured. It can also differ according to circumstance. Only by mixing strategic goals with tactical actions will the business sustain the right combination of consent and contact.