The morning post accessing mailmark and tray savings - 25 june
1. Data protection 2013
Friday 8 February
#dmadata
Supported by
The morning post: accessing
Mailmark and tray savings
Wednesday 25 June 2014, Kings Place
#dmapost
Supported by
3. 10.00am Registration
10.30am Introduction
Mike Lordan, Director of external affairs, DMA
10.35am Mailmark
Charles Neilson, Head of business development – Consumer & network access, Royal Mail
11.00am DSA perspective
Jennifer Rufus, Head of product development, TNT Post UK
11.10am Mailing house perspective
Peter Stockton, Mail solutions director, Communisis
11.20am Questions
Charles Neilson, Royal Mail
Jennifer Rufus, TNT Post UK
Peter Stockton, Communisis
11.35am Refreshment Break
Agenda
Supported by
7. Mail is alive and well
Royal Mail Mailmark®
We’re all here today because each have a vested
interest in the future of mail
8. Mail is alive and well
People pay attention to their post
People still prefer to receive paper bank statements (44% of
British residents say their financial records would be incomplete without them)
14% of people in the UK have never used the internet
17% of households do not have internet access
- Insight Exchange, 2011
- ONS, 2013
Royal Mail Mailmark®
9. Mail plays a distinct role
Royal Mail Mailmark®
Bills or statements
Loyalty rewards
Confirmation or follow up messages
Issues or complaints
Information from companies not used before
Other products and services
Welcome packs
Reminders
Brochures and catalogues
News and updates
Promotions and offers
Preference for Mail vs Email (absolute: % prefer mail vs % prefer email)
Source: Quadrangle 2013: S4Q2A/B, How do you prefer to hear from new companies / companies you have used before, for...? Base: Total, n=1000
10. Mail means higher emotional engagement
Royal Mail Mailmark®
Source: RM Neuro-Insight, August 2013
11. Mail needs to prove itself
Mail is a premium product
It’s a tangible product
Other mediums have metrics
Mail needs to stay relevant in the 21st century
Royal Mail Mailmark®
12. What our customers want from mail
Our customers want insightful reporting
They want to see where their mail is in the supply chain
They want to know more accurately when it’s going to
land
They want to know if there are any problems
They want to have oversight of the whole process
And of course they want all of that with the best value
Royal Mail bulk mail product
Royal Mail Mailmark®
13. Investment in mail innovation
So Royal Mail have invested
to make mail smarter…
Royal Mail Mailmark®
14. Investment in mail innovation
We have already upgraded our reporting systems and
invested in Letters Automation
And now are investing a further £70M to make mail
work smarter for our customers
Mailing Houses, customers and our industry colleagues
have also worked to support the capability
So together we can promote mail a modern and integral
part of the media mix
We can introduce the future of mail...
Royal Mail Mailmark®
15. I am here...
Barcode
A new barcode standard for
machine readable
Business, Advertising and
Publishing Mail
Technology
Sorting machines that read
the new barcode and
collect mail data.
Reporting
A Mail Analytics platform that
reports on volume, compliance,
day of arrival and overall
performance of consignments.
Royal Mail Mailmark®
Royal Mail Mailmark®
16. What happens to mail?
Sending
Customer Outward
Mail Centre
Outward Sort
Track Event
Royal Mail
network
performance
Royal Mail
delivery
performance
Predicted
delivery
performance
Delivery Batch
Track Event
Walk Sequence
Track Event
Inward
Mail Centre
Delivery
Sequencing
Delivery
Sorted Mail
Wholesale
& Retail
eManifests
Dashboard
Unsorted
Mail &
Meter
Royal Mail Mailmark®
Royal Mail Mailmark®
17. Mailmark™ gives you confidence
Consignment level tracking
Supply chain visibility
Transparency of Royal Mail performance
Audit trail
Predicted delivery day
Item level error reporting
Best value product
Royal Mail Mailmark®
22. Reporting gives us insight
These insights help us operationally
Big benefits for our customers too … you can
use the new insight to improve mail and data
quality
Royal Mail Mailmark®
Reporting – what have we learned?
23. Read rate of items more than
97%
Predicted delivery consistently
high and exceeding service
performance targets
Across Wholesale, 1c, 2c, E =
More than 98%
Royal Mail Mailmark®
Reporting – headline figures
24. We have been able to identify which customer mail items
fail to meet specification
We let the customer know, so they can look into any
problems with the production of their mail
Some issues already identified and resolved include:
→ Incorrect barcode type
→ Out of date look-up files – consistently missorting
→ Bad address data – accidentally mailing
internationally
→ Barcode zone infringement – pre-MailmarkTM this
would have been a tap out reversion
Royal Mail Mailmark®
Reporting – how we’ve helped customers
26. Royal Mail Mailmark®
Before MailmarkTM…
We based all of our checks on sampling
We sampled a small percentage of a mailing
And on the basis of that sample, we made an
assessment on the mailing’s compliance with the
product specification
If the sample showed errors we’d then revert all or
part of the mailing…
27. Royal Mail Mailmark®
We are moving to a new world
Where we no longer rely on manual sampling
Where our checks take place ‘in-process’ via
automation
Where we can pinpoint individual items that have
errors such as the wrong format or class
And where we make an adjustment or charge only for
the element of the mailing that is wrong
28. Royal Mail Mailmark®
The MailmarkTM option is for highly machinable mail
MailmarkTM option retains the current 90% Postcode &
DPS accuracy requirement for Business, Advertising and
Publishing mail
Customers will only be charged for proportion in error
below this threshold - e.g. a 89% postcode inaccuracy
would mean a 1% charge
The 90% threshold will be reviewed for March 2015
And … if the chargeable amount is < £10 per eManifest -
we won’t make a charge
29. Royal Mail Mailmark®
With the MailmarkTM Adjustments Framework
We will tell you when
something is wrong
We will help you get it
right next time
Any charges will be clear
and proportional
29
31. Benefits to customers:
Improving the quality of mail across the board
Supply chain visibility
Benefits of Analytics
A collaborative market approach:
Using MailmarkTM technology to improve data quality and
improve processing
Using MailmarkTM technology to support mail volumes
Committed to working with you to build on Analytics over
time
Royal Mail Mailmark®
MailmarkTM technology – in summary
32. We believe that by working together we can bring
90% of bulk mail volume onto Mailmark™ by
2016
Providing benefits to both the industry and all of
our customers
All the while improving mail quality and relevance
Royal Mail Mailmark®
MailmarkTM technology – vision for the future
33. Package of measures to encourage customer adoption:
Continued collaboration on reporting
Two additional bespoke report writers approved
Input from customers, SMP, WAG, DMA and others
Review of Mech Specification Option availability
CBC/OCR retained until at least 2016
Pricing differential between Mailmark and CBC
Prices announced at April 2015 Tariff
Plan migration early to be ready to benefit
Royal Mail Mailmark®
MailmarkTM technology – vision for the future
34. Contact your Access Operator, Mailing Agent or
Royal Mail Account Manager to review the
benefits of Mailmark™ for your business
Contact me! I’m always happy to talk to our
customers
charles.neilson@royalmail.com
www.royalmail.com/mailmark
Royal Mail Mailmark®
How do you get involved?
38. Where are we now ?
• Live with both presorted and unsorted from March 2014
• Current volumes processed and Handed over to Royal Mail is 1, 138, 691
items to date
• Working in a collaborative way with RM Mailmark team to develop and
improve offering as we move forward
• 99.85% successful read rate of mail handed over to Royal Mail so far…
39. What has been good….
• Positive approach between both Royal Mail and TNT Post
• Ability to influence change as we have been an early adoptor from the
beginning and the only DSA operator to be live with both unsorted and
presorted mail
• Seems to be more and more engagement from customers and mailing
houses but not a lot of doing….
• Spec should make it easier for customers to achieve lowest level pricing
• Our analysis so far shows that the surcharges will not impact us in the
same way as current reversions policy
40. Potential Challenges still….
Customer Take on process
- Unclear but we are working to address this
- Inertia from DSA customers to interact directly with Royal Mail Retail team could be
stifling the progress to take up Mailmark
Surcharges
- Unclear as to what this really means for customers, the data in the portal still has
glitches
- Could open up a lot of queries as reporting is against the emanifest and DSA
customers are billed against bag manifest so the 2 could never match!
- Internal challenges for reconciling against the Royal Mail bill for Mailmark
Pricing Differential
- A lot of customers/mailing houses waiting until price differential kicks in
- We do not want everyone to wait until next April to take this up as both TNT Post and
Royal Mail could struggle to support
- Need to encourage mailing houses to start developing now to be live before next April to
take full advantage of price change
43. Mailmark – Our View
Mailmark is the exciting future of Mail – put simply Mailmark will
enable intelligent mail and that can only be good news for us all
Mailmark uses a smarter barcode which Royal Mails sortation
equipment reads to track individual mail packs
It has required investment in terms of software development, but
with the large amounts of Transactional mail our sites handle it was
considered to be an investment for the future
It is clear that technology has been an enabler for many industries
and it is good to see so much innovation in the postal market,
particularly in the area of Barcodes.
It’s a good news story that we have fully embraced
44. Mailmark – Our Journey
The choice of Barcode needs careful consideration with clients for
both mail piece look and the customer data requirements.
Producing various examples supports this decision
Presentation of mail – two different streams, taking longer in terms
of production time
Upload of E-manifest – more time consuming and onerous for us to
ensure any batches are correct on the E-manifest prior to upload
We’ve had a few teething issues, which through working with Royal
Mail have been speedily resolved, we have to continue to manage
the Clients expectations
We managed an exercise where a Proof of Concept document was
provided to our client demonstrating its success
45. Mailmark – The positives
Predicted delivery date – Improves customer processes e.g. it
enables clients to staff call centres etc. more effectively
Mailmark will potentially be the ‘Best Value’ Machineable product
going forward
For the first time our customers can get accurate reporting on what
is happening to their mail. Its not just what it reads but also what it
doesn’t that’s interesting
Future upgrades will enhance the product even further in particular
in the areas of returned mail and confirmation of delivery
It has been important to us that Royal Mail have understood our
processes which has enabled us to work together to achieve a single
solution
46. Mailmark Future
In our experience it has been successful project so far,
creating transparency throughout the process. This
has shown to be a true partnership with Royal Mail and
the end client.
Our advice would be ‘Embrace this New
Technology’ to promote better mail for
all our customers!
49. 11.55am Letters in trays
David Dale, Head of product design, Royal Mail
12.10pm DSA perspective
Dean Ryan, Head of implementation, TNT Post UK
12.20pm Mailing house perspective
Alistair Ezzy, Sales director, GI Solutions Group
12.30pm Forecasting
Danijel Karadza, Network access account director, Royal Mail
12.40pm Questions
David Dale, Royal Mail
Dean Ryan, TNT Post UK
Alistair Ezzy, GI Solutions Group
Danijel Karadza, Royal Mail
Alex Walsh, DMA
12.55pm TNT delivery network
Andrew Goddard, Commercial director, TNT Post UK
1.15pm Data protection legislation changes – implications for mailing houses
Janine Paterson, Solicitor, DMA
1.25pm MPS
John Mitchison, Head of preference services, DMA
1.30pm Conclusion and thanks
Mike Lordan, Director of external affairs, DMA
1.30pm Lunch and networking
Agenda
Supported by
51. Could you save money by posting
mail in trays?
David Dale Head of Product Design
52. • Before 31st March
Sorted mailings could use bags/bundles or trays
Royal Mail Wholesale gave a tray discount
No discount for Royal Mail Retail customers
• From 31st March
Sorted mailings can use bags/bundles or trays
Royal Mail (Retail and Wholesale) give tray discounts
Discounts increased
52
What’s changed?
53. • Customers wrap and strappex bundles of mail, and tie up
bags - in line with Royal Mail’s specifications for bags
• Royal Mail cuts open all the plastic wrapping and the
strappex and bag ties, and places the mail into trays
53
Why offer a discount?
54. Advantages of trays
Royal Mail opens bags and bundles for all sorted mailings* to transfer the mail
to trays
Mail in trays is typically in better condition as it travels through the mail pipeline
On average this mail is sorted more readily and has fewer quality issues
Barcoded mail has better read rates
• Bags must be tied
• Mail must be bundled
• Bags give less protection
• Trays do not need ties
• No need to bundles
• Trays protect mail
• Lower prices
54
s There are presentation requirements – see the rest of this presentation and the Containerisation section of
our User Guide.
* Excluding Parcels, A3 Parcels and Large Letters over 10mm in thickness.
55. Savings on Letters
0.2pPer item
Excludes VAT
Effective 31st March 2014
55
£2Per thousand items
40pPer bag or tray,
based on 200
items per container
56. Savings on Large Letters
0.3pPer item
Excludes VAT
Effective 31st March 2014
56
£3Per thousand items
15pPer bag or tray,
based on 50 items
per container
57. …has not changed
•No changes to the rules about tray labels, weights etc
•Specifications for bags/bundles and trays are unchanged
•More details at www.royalmail.com/traysavings
57
The technical stuff
58. What could possibly go wrong?
58
• Care is needed when changing over to use trays
requires advance planning eg tray labels are different
• Tray Supplies
operating smoothly since 31st March; trays ordered as per bags
•Logistics and storage can be affected
‘…concerned about the internal logistics challenges and workload of
using trays over bags (cages, consumables) etc…’
‘…limitation was under the roof storage of trays, floor space
around production lines…’
• Exceptions (some items not permitted in trays)
parcels, items over 10mm etc – check the details at
www.royalmail.com/traysavings
59. What happens next?
59
• Royal Mail’s aim is to convert all the mail that can
reasonably be trayed (currently c40% for Retail)
• There will always be exceptions
• Customer take up and technical issues will be reviewed
autumn 2014
• Longer term aim to improve our standard trays (reduce
weight and improve ‘nestability’)
• Tray savings £value will be reviewed as part of general
price changes, along with other discounts
60. For more information
60
• Ask your mailing house
• Ask your usual Royal Mail contact
• www.royalmail.com/traysavings has contact details for
ordering trays, and technical information about tray fills
63. When does it work?
• Presentation in trays can and does work in certain
circumstances
• Low sort transactional mailings
• Some Low sort high volume 1 piece Large Letter mailings
• Regionalised large volume High sort mailings
• If minimum tray fills can be achieved
• 175 Letters
• 50 Large Letters
64. When does it not work?
• There are circumstances when it does not work
from a TNT Post perspective
• High Sort mailings
• Low volume mailings
• Large Letter mailings
• Mailings where minimum tray fill cannot be achieved
65. Operational Impact
Moving all Low sort mail to trays
• TNT Post already handover mail in trays
• Circa 20% of all Low sort mail
• All of our consolidated Mail
• Moving air around network is costly
• Ave tray fill Letters - 14% lower
• Increased pressure on consumables
• Ave Items per York – Bags – 5357
• Ave Items per York – Trays – 4683 – 13% lower
• Extra 66,000 Yorks per year
• Increased magnums required – circa 15,000
• Storage space – Trays take up more space than bags
• More Trays & Yorks = more Processing, Consumable and
transport costs
66. Commercial Impact
• Increased costs to process all Letter 70 =13%
• Additional cost of consumables
• Increase in transport costs
• More Vehicles
• More Routes
• Current discounts offered do not reflect cost to
Carriers to process
• Current discount of 0.2p not sufficient to cover cost of change
67. Way Forward
• TNT Post are generally supportive of presentation in Trays
• Need to continue to work with MH’s and RM to find best
solutions
• Use of different consumables – pallets for example.
• Consolidation of mailings
• Large Letter mailings to be assessed and negotiated on an
Individual basis – Volume & Weight dependant
• Discounts must reflect real cost of processing in trays
70. Why tray?
• Provides clients with postage saving (0.2p letters, 0.3p large
letters)
• Items are received at Royal Mail in a clean and undamaged
manner
• Reduces manual handling
• Reduces labour
72. Operational Difficulties
• Increased storage
• Less items per container
• Pallets cannot be stacked as efficiently
• Increased pallet movement
• Increase in logistics/collections
• Difficult to accurately calculate tray fill with physical constraints
• Operational differences between suppliers
• No clear identifier on originator of consumables so monitoring consumable levels for
each provider is difficult
• Tray supply through DSA challenging
75. Operator Differences
• TNT minimum tray fill 175 – will reduce with agreement
• TNT require all trayed work to be 8 way segged
76. Operator Differences
UK Mail require client to have a tray arrangement in place
Mailing profiles and average and minimum tray fills are
applied to the arrangement
Surcharges apply where minimums are not met (this is
averaged over the mailing) approx. costs 9p per tray
77. Environmental Impact
Shrink Wrap
Increased transport - consumables in & collection out
Sustainability of pallets Vs longevity of magnums/cages
79. Importance of Forecasting in Delivering
Excellent Customer Service and Network
Efficiencies
Dan Karadza
Network Access Account Director
DMA Postal Event
25th June 2014
80. Agenda
• Forecasting matters
• Forecasting requirement
• Latest developments
• What you can do to get involved and improve forecasting
81. Accurate forecasting really matters
• Absolutely critical in enabling Royal Mail Operations to
resource effectively so that it can process and deliver your
and your customer’s mail successfully and to the expected
service standard
• Accurate forecasting leads to a more cost efficient
operation which enables Royal Mail to maintain low
postage prices
• Accurate forecasting enables a more cost efficient
operation along the end to end pipeline
82. What is new in forecasting?
• Firstly, there has always been a contractual requirement to provide an
accurate forecast and this has not changed.
• During the Autumn 2012 consultation on the future terms of access, customers
acknowledged a need for accurate forecasting and asked for more time to
improve internal processes to support provision of improved accuracy
• The requirement is :
• Provide a 7 day rolling forecast on each working day by Inward Mail
Centre with an estimated breakdown between machinable and manual
items
• Provide a 24 hour forecast by 10am of the items you expect to hand over
on the following working day at each Inward Mail Centre with a breakdown
between machinable and manual items
• Royal Mail has always had the option to not accept or hold mail that is in any
excess volumes above forecast tolerance
• Royal Mail has always had the right to surcharge in cases where actual
volumes handed over are below the forecast tolerance (1000 letters or large
letters or 15% of the number notified in the forecast)
• What has changed is that the surcharge has simply been defined
83. What is new in forecasting?
• In February 2013, we issued guidance on when the
surcharges would apply:
• if the forecast is out of tolerance but there is no
operational impact at Mail Centre level on a given day
then no surcharge would be raised. If there is an
impact, the contractual terms would apply
• However, even if there was an operational impact, we
would not raise a surcharge if a customer is involved in
a programme of improvement with a deployment date
within a reasonable timescale
• No surcharges were applied in 13/14 in order to provide
sufficient time to customers to improve forecasting
accuracy and deploy their plans
84. The industry has worked together to improve
forecasting
• Royal Mail has worked individually with many of its customers over the past 12
months
• As well as working with individual Access customers, Royal Mail also set up the
Forecasting Working Group with industry representatives from WAG, MPAG
and DMA to:
• share good practice
• develop ideas as a industry
• agree how we move forward together
• This combined activity has resulted in notable forecasting improvements and a
brand new trial
• The 4pm reforecasting approach is beginning to show improvements
• Gradual learning process has led to mutual understanding and consistent
improvements
• The industry is investing to improve forecasting accuracy
85. Manual large letters are the real pain point of
poor forecasting
• From the 1st May 2014, we will apply surcharges in line with the
Contract if forecasts are inaccurate but only in the following situation:
• there is an inaccuracy of manual Large Letter items of >15% per
Mail Centre and,
• the Mail Centre confirms the impact of underforecast
• The surcharge, is £26 per Mail Centre per format. The surcharge will
only be applied if both of the above occur.
• No surcharges have been raised yet:
• We are putting a process in place to confirm operational impact to
customers via the daily client report
• We continue to work with the Forecasting Working Group to keep
everyone informed
86. Forecasting is getting better and we look
forward to further progress
• Understand your own accuracy and forecasting processes
• Talk to us or your industry representatives if you want to join the
forecasting trial
• Work with your customers and suppliers to raise awareness and make
improvements
• Further meetings of the Forecasting Working Group are planned in
September
• Forecasting is on the monthly operational agenda with all our
customers
• If 4pm forecasting trial continues to improve, Royal Mail hopes to
release the data for operational use
• Senior Royal Mail Operations Directors also part of the Forecasting
Working Group
• mutual acknowledgment of forecasting challenges in the market as well as how
critical forecasting is to Royal Mail Operations
• pragmatic approach on surcharging
87. Summary
• Achieving accurate forecasting has industry wide benefits:
• delivers our customers’ promise
• helps to maintain low postage prices
• creates certainty by reducing incidents which could lead
to increased cost or performance below expectations
which
• helps to keep our customers using mail
88. Questions
David Dale, Royal Mail
Dean Ryan, TNT Post UK
Alistair Ezzy, GI Solutions Group
Danijel Karadza, Royal Mail
Alex Walsh, DMA
#dmapost
Supported by
91. Content
• Overview – Journey so far
• Our People
• A mailing house view
• E2E versus DSA – Key Differences
• What is our specification
• Indicia
• Software
• Barcodes
• E2E Benefits
92. Our Journey So Far
April 2012
November 2013
February 2014
March 2014
South West & Central London
Greater Manchester
North West London
Liverpool
545k Households
11 Delivery Units
1000 Posties
667k Households
12 Delivery Units
700 Posties
399k Households
5 Delivery Units
400 Posties
370k Households
6 Delivery Units
500 Posties
93. Our Journey so far
Over 2500+ new jobs created throughout UK
We deliver mail to over 2 million UK households
34 Delivery Units in London, Manchester &
Liverpool
TNT Posties delivered in excess of 100m items
95. Our people
A short E2E Postie video showing various posties from different
backgrounds, what they did before TNT Post and how TNT Post has
changed their working/personal life.
http://www.tntpost.co.uk/tnt-posties
96. A Mailing House View
E2E v DSA
• Deliveries for E2E made by TNT Posties
• E2E provides tracking to the end delivery point
• Delivery SLA 2-3 days
• E2E Indicia is required instead of DSA indicia.
• Manifest required for end delivery point tracking – auto generated by
TNT sort software.
• 2D Barcode required within envelope window for end delivery point
tracking
97. The changes that need to take place...
New E2E Indicia
Production of .SEC file
2D Tracking barcode
A Mailing House View
What is our Specification
98. A Mailing House View
Indicia
• TNT would prefer all E2E Mail to be collected with a
compliant E2E Indicia on.
• E2E Indicia to be applied
99. A Mailing House View
SEC File - Software
• TNT Sort Software creates the SEC File
• E2E batching.
• 2D Barcode Population
• Software Update Notifications
100. A Mailing House View
Barcodes
• TNT Post are flexible on which 2D Barcodes are used, if we are able
to read test samples then we are happy to approve.
• Maximum of 90 characters in the 2D Barcode of which the first 45
characters are reserved for Royal Mail use.
• TNT Post do not define where our 20 characters including #
characters are placed within the remaining 45 spare characters..
101. Overlay of overall benefits
to the industry
Data Print Enveloping Despatch
Receipt Depot
Sort to
Delivery Unit
DU Sort and
Delivery
Management
Information
102. E2E Benefits
1. Tracking from despatch to doorstep delivery
2. Lower cost alternative to DSA for customers
3. Additional discounts for mailing houses meeting the
E2E specification
4. Transparency of performance
5. Real competition in final mile delivery
104. EU data protection reform
timeline
• Jan 2012 -first draft Data Protection Regulation ("DPR")
• December 2012-amendments suggested by the
Rapporteur of EC Committee on Civil Liberties, Justice and
Home Affairs ("LIBE Report")
• February – May 2013 – Reported that 4000 amendments
tabled
• May 2013- partial "compromise" draft from Justice and
Home Affairs Ministers ( "CD" )
• October 2013 -LIBE voted on amendments
• October 2013 – Heads of Government meeting
• December 2013 – Inconclusive Justice and Home Affairs
Ministers meeting
104
105. EU data protection reform
timeline
• Jan 2014 Civil servants working group meetings
continue
• Mar 2014 Inconclusive Justice and Home Affairs
Ministers meeting
• Mar 2014 MEPs adopted LIBE report
• May 2014 European Parliament elections
• June 2014 Next Justice and Home Affairs Ministers
Meeting
• Nov 2014 New European Justice Commissioner and
other Commissioners take office
• Dec 2014 Justice and Home Affairs Ministers agree
position
• 2015 Regulation is passed in Brussels
• 2017 Implemented into UK law
106. 3 areas of concern
• Explicit consent required
• An end to profiling?
• Data processors jointly responsible for data
107. Consent
Consent: Current Position Consent: Proposed Position
- Freely given, specific,
informed indication of the
data subject’s wishes
- Explicit consent required
for sensitive personal data
only
-Freely given, specific, informed and
explicit indication of data subject’s
wishes
-Given either by a statement or a
clear affirmative action
- Data controller / data subject
relationship to be taken into
account
- Burden of proof on controller to
demonstrate consent
108. Explicit consent
• Move from opt-out to opt-in – need explicit consent to
send any message, exception existing customers
• Need review language used at point of data collection to
ensure that consent is explicit /opt-in
• Think about how you will deal with existing databases –
may be unusable
109. Profiling – a thing of the past?
• No collection of data without explicit consent
• No targeted marketing at specific consumer profiles –
less targeted and more generic communication?
• Currently held demographic personal data will have to be
erased
110. Compliance: Data Processor obligations
• Mailing houses, will be subject to these obligations,
especially in respect of data security
• Review amount of data being processed, erasure policies
and data retention policies – documentation to demonstrate
compliance
• Review staff training in data protection.
• Appointment of a data protection officer?
• Risk- based approach to compliance and data protection
impact assessments
110
111. Key lobbying messages
• Data is essential for economic growth
• UK has leading role in EU digital economy
• SMEs particularly affected
• Transparent and responsible use of data is a vital business
practice
• In industry’s interests to handle data with care
• Self-regulation has valid role to play
• Regulation will not stop bad players
112. Key lobbying messages
• The proposed regulation is bad for consumers
• Would damage users’ online experience
• Danger of tick-box culture & unrealistic expectations
• Need a proportionate data regime that recognises that not
all data is the same
• Personal data, sensitive data,
anonymous/pseudonymous data
• Different levels of protection required
