From a commercial point of view, failing to cleanse data thoroughly with suppression files is bad business sense. Using suppression files cuts the cost of mailings, increases response rates, minimises waste and protects the brand’s reputation. From a wider perspective, using suppression files is crucial to preserving the commercial freedom that industry self-regulation provides.
To understand why, it’s first necessary to look at the three basic parts of the governing framework that determines what you, as direct marketing practitioners, can and can’t do. Think of it a three-layered structure, with “caveat emptor” forming the base; regulation on the top; and self-regulation in the middle.
The notion of “caveat emptor” sets out the fundamental rights of consumers and of their expectations of responsibility for their own self protection. Regulation and self-regulation together must protect those rights.
Regulation and self-regulation are two very different beasts: regulation comprises laws drafted by Government policymakers and enforced by Government-appointed regulators with legal sanctions at their disposal; self-regulation consists in best-practice guidelines developed and administered by industry trade bodies and practitioners.
Largely speaking, the Government favours keeping regulation to a minimum and letting self-regulation keep industries in check. This is for a number of reasons, such as the fact that self-regulation does the job at a low financial cost; it’s constructed by industry experts; and it’s far more likely to be accepted by industry because of the risk of unintended outcomes from regulation.
The DMA keeps the direct marketing industry in check through its role in maintaining its self-regulatory framework. Self-regulation isn’t enshrined in law, so breaking it doesn’t incur legal penalties. However, it’s vital that Government remains confident that the industry is responsible enough not to require the imposition of heavy-handed regulation.
Through its work in developing self-regulation and providing guidance to companies on how to work within its boundaries, the DMA helps to demonstrate to Government that regulation is unnecessary, and thereby staves off legislative threats to the commercial freedoms of the industry.
Advocacy of the use of suppression files is a key aspect of the DMA Code of Practice. In addition to their statutory requirements, all DMA members are required to abide by the DMA Code, which specifies at a minimum that they must screen their data against MPS, and should screen for bereavements and gone-aways. But there is no reason why this should not also be adopted as an industry-wide minimum. Making it so will support the DMA in its mission to ensure that the self-regulatory framework the industry currently enjoys continues to prevail.
By Mike Lordan, chief of operations, Direct Marketing Association, and member of the Suppression Providers Alliance