2018 promises to be the year when consumers will finally take control of how brands communicate with them. Remember, data belongs to the individual; not a brand, a company or us, and it is right that they should decide how and when it is used.
I accept that my support for GDPR might seem a little unexpected, however, the result of a more positively disposed, more engaged and more receptive consumer is an outcome well worth paying for. Our business should never have been about volume. It was volume that decimated the direct mail market, it is volume that is destroying email’s performance and credibility, and it is volume that is driving much of the anger in Brussels around the e-privacy review. Our industry should always have been about results.
Ironically, the imminent arrival of GDPR has already changed the conversation. It is clear that there will be a lot less data around to use and most of the brands we are working with are now intent on protecting what they do have and are trying to enhance it. With this is mind, brands have had to take a more strategic and long-term view of both retention and acquisition.
This doesn’t mean that they won’t be trying to acquire new customers, but it is how they will do it that will change. A shortage of opted-in email data will present significant challenges to any brand’s digital acquisition strategy, and they will need to be looking at new ways to get themselves noticed.
Most brands already have some sort of programmatic strategy in a bid to present timely advertising to individuals across digital networks, but this too is set to present challenges. The right to erasure within GDPR will, I believe, signal the end of this wanton use of data. If consumers had any idea that this was how their data was being used, the vast majority would of course prevent it.
I think we will see a clear divide between the two arts of acquisition and retention. There is no doubt that if you are a frequent customer of ‘brand X’, you will simply tell them how you wish to be communicated with. Experience, of course, engenders trust and therefore regular contact with a brand allows consumers to relax and be less suspicious.
On the other hand, a consumer’s view of a brand they have never worked with or heard of is naturally going to be at the other end of the spectrum. We are already seeing, and I think that we will see a lot more of, an increase in advertising brand building activity combined with direct mail and this is becoming the point of the acquisition sword. It has surprised us all to see how non-abrasive a channel direct mail has become, particularly when compared to email, SMS, or telemarketing.
But there is another significant difference to direct mail. The availability of data, and the use of “legitimate interest” for processing will mean that the richness of data available on the channel will be second to none. I am not forecasting a return to the heady days of the mid-Nineties and Noughties, but I am forecasting a return to the days when our first thought was about ROI, and quality not volume.
Brands will focus on outcomes, not coverage. I expect the quality (and therefore cost) of direct mailpacks to grow as brands focus on conversion and strength of brand positioning. This shift in thought will in turn add to the overall credibility of the channel and make consumers more accepting of this comparatively unobtrusive medium.
To be clear, I’m not suggesting for a minute that digital paths to great outcomes won’t exist, they will, but they will be difficult to achieve and fraught with legislative danger. We are already seeing many brands transfer these skills to the performance marketing arena where great content and relevant data are encouraging consumers to request brand contact.
It is unthinkable to hear of organisations who haven’t done anything about GDPR. Remember GDPR will affect every single European company and there will be no excuses for non-compliance. Of course, quite a lot of the guidance is still yet to emerge from the Article 29 Working Party in Brussels, making final preparations impossible to implement. However, we are working with clients on a strategy to get them GDPR ready. In other words, prepared for whatever may come. The Information Commissioner’s Office has been pretty clear that any significant changes to its advice are unlikely and I believe that we can get ourselves 95% of the way there.
2018 is going to be pretty challenging for any organisation that has not had GDPR in its sights for some time. There are no quick fixes here. We have lived with an out of date and increasingly irrelevant legislative framework for too long and the UK needs an update, sharpish.
Even the Privacy & Electronic Communications Regulations, which are now well over a decade old, are being rewritten in the guise of the ePrivacy Regulation review and they have already committed that this will align with the GDPR’s (for the first time). This is due for implementation the year after GDPR. If you are in B2B, then you won’t get away with it either as both texts refer to natural (consumers) and legal (companies) persons and imply opt-in for B2B. Clearly some lobbying is going to be required around that.
So bring it on, we feel ready and I hope many of you do, too. The specifics of the regulation will be defined by the courts, as precedent is set on precedent, so all you can do is get as ready as ready can be.
By putting consumer wishes and choices at the centre or all our marketing activity, I believe that the next 24 months will be our finest.
Mark Roy is founder and chairman of REaD Group
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