to optimize cross-channel marketingwithout hurting your brand and reputation

Top 10 ways

GOALS

Learn to get proper consent through various data acquisition efforts

Understand compliance with U.S. and Int’l laws

Integrate personal and non-personal data while respecting privacy

Avoid brand and deliverability hazards

Avoid arrested development…# 1

with purposeful collection

Optimize consent for each channel

…they’re still walled gardens

# 2

CROSS-CHANNEL CONSENT CONTINUUM

Collection is part of a TRANSACTION, but no disclosure of marketing intent or opt-in request

EMAIL ‘AUTO-CONSENT’ IS NOT PERMISSION

?Legal in US but is a poor privacy practice and increases

deliverability risk

Mitigate with welcome emails.

UPDATED TCPA OPT-IN RULES

OCT 16: Prior “express written consent”.

Agreement must be overt, specific to marketing SMS, and independent of any other agreement.

Cannot send more than 1 Opt-Out Confirmation text

Is the above compliant??

BY THE GRACE OF THE WIRELESS CARRIERS

Include industry-mandated essential terms and disclosures

cost disclosure how to opt-

out

link to T&Cscontac

t details

BE AWARE OF SOCIAL NETWORK TOS

Make permission statements clear Provide links to your privacy policy discussing social data use Mind restrictions about using data off the platform

Consent optimized for the US…

may not be adequate in Int’l markets

# 3

CASL

EC Dir

CAN-SPAM

ePrivacy Directive

INTERNATIONAL CONSENT CONTINUUM

GET UNAMBIGUOUS ‘INFORMED CONSENT’

for CASL IS COMING

# 4Don’t wait. Prepare now...

Requirements

Consent Purpose-based Express Consent (Opt In) Implied Consent can expire!

Content Mailing address + Tel, Email or URL How to opt-out

Unsubscribe “Readily performed” processing

Coverage

(Non-accidental) access from a computer system in Canada

Broad definition of “commercial message” Email, SMS, IM, MMS, video, and software in scope

CASL DESIGNED TO BE MORE RESTRICTIVE

Regulations still incomplete and CASL not expected to come into force until late 2013 or early 2014.

CASL’S REGULATOR SAYS ‘NO’ TO “TOGGLING”

Don’t feed Point-of-Sale# 5

USE TOOLS TO MITIGATE SPAMTRAPS

Use kiosks/iPad instead of teller requests Ask to check spelling Correct known domain typos Ask to opt-in within eReceipt or send COI

Old email data is still a delivery risk

# 6

…even if it was initially COI’d

SEGMENT DATA BY TENURE (AND COUNTRY)

Adjust acquisition practices to help identify recipient’s country jurisdiction, segment accordingly

Behaviorally verify users inactive for over 8 months and re-confirm users inactive for over 18 months.

Continually scan for signs of life# 7

…across all your frontiers

USE CAMPAIGN ANALYTICS

Monitor performance and delivery metrics

Look for email Clicks. Opens can be false positives!

Who are your social media fans?

Can you re-target offline buyers?

Disclose tracking and data integration efforts…

# 8

and get consent where you can

ALLOW USERS TO OPT-OUT OF OBA

Visit aboutads.info

DON’T FORGET ENHANCED DISCLOSURES IN THE EU

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Readily accessible privacy policies are a must# 9

…on-deck and off

# 4PRIVACY POLICY SHOULD TOUCH ALL CHANNELS

Web, mobile, and app privacy policies should be easy to read!

Put it all together to help you

# 10

bridge channels

1. Constrain collection of data to only specific purposes.

2. Ask for unambiguous consent up-front. Mind industry-specific guidelines.

3. Record ‘overt acts of permission’ whenever possible. It is always possible.

4. Audit your database and practices to gauge Int’l risk. (UK ICO, CASL)

5. Preempt spamtrap risks online and at Point-of-Sale.

6. Put in place tailored data hygiene controls to cull bad data.

7. Scan for signs of life across all touch points to re-target and re-engage.

8. Put what you should and more into your privacy policy. .

9. Make your web/app privacy policy easy to access, read and understand.

10. Bridge across marketing channels using your primary medium.

10 WAYS TO NOT TO BREAK YOUR BRAND

THANK YOU!

Alex Krylov:Privacy & Compliance Analyst Lead, CIPP

Experian Global Compliance | Marketing Services.

For more information, please visit http://www.experian.com/blogs/marketing-forward/.

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