My final major project for BA (Hons) Fashion and Textile Buying Management at University of Huddersfield. Coming from a years worth of research and a dissertation based on how technology is shaping the retail industry. A Best Practice guide for retailers to use to aid them in becoming more ethical in their practices of collection consumer data. Technology is advancing as such a fast pace, retailers need to keep up with changes and how customers feel about what is happening around them, after all "consumer is king" right? We need to start listening to what the people are saying and change our ways before it's too late!
Research from September 2014 - May 2015.
FMP - Consumer Data: Collection, Usage and Storage in Retail.
1. 1
COLLECTION, USEAGE AND STORAGE IN RETAIL.
CONSUMER DATA:
BEST PRACTICE
GUIDE.
‘Creating a more digitally
responsible retail
environment through
knowledge in data ethics.’
2. 2
SPECIAL THANKS to contributers of the
research prior to this guide being published,
including, but not conclusively Neil Bennett,
Andrew Busby, Fatface, UK retail consumers,
Jane Ritchie and Jo Conlon. Without the con-
tribution of others, the idea of creating this
guide would have never become a reality.
First Published 2015.
As part of a Fashion and Textile Buying
Management Major Project by Zoe Robinson
Visit weebly.com/dodatabetter for useful
material including:
• Web links to relevant Internet resources
to facilitate independent research.
• An online glossary to explain key terms
• Other services that are available from
Do Data Better
• The Author’s contact details
‘Creating a more digitally
responsible retail
environment through
knowledge in data ethics.’
THE PURPOSE OF THIS GUIDE IS TO PROVIDE THE OPPORTUNITY FOR
RETAILERS TO MANAGE CONSUMER DATA MORE ETHICALLY AND
SUSTAINABLY.
4. 4
INTRODUCTION
In the last decade there has been a surge in
new technologies that aid the collection of
data from consumers online and in-store, such
as mobile and location tracking, face scanning
and footfall cameras. These technologies have
been implemented into retail environments
across the world, giving retailers more access
to data about their customers such as age,
location, browsing history and even emotions
towards their store experience.
During the surge of technology innovations,
there has also been a rise in consumer
concern regarding the collection, storage and
usage of their data. The concern has come
from situations such as breaches with
databases being hacked and data sets
stolen, to retailers unnecessarily
collecting data from consumers without their
prior knowledge, which has questioned the
trust between consumers and retailers. This
guide aims to help retailers build that trust
bask up with their consumers, through better
ethical practises when concerning consumer
data. The guide demonstrates the best
practises, main concerns and issues, with
solutions to create a more digitally
responsible environment that will better
satisfy the consumer.
CONSUMER DATA
COLLECTION TECHNOLOGY
5. 5
It has been argued that simply complying with
the laws in data collection are not going to be
enough in the coming future, and creating a
digital code of conduct that shows more
transparency in the data supply chain is the
next step for retailers when aspiring to gain
consumer trust.
Creating a transparent data supply chain
where retailers inform consumers what data
they are collecting, why they are collecting it
and how it is going to benefit both the retailer
and consumer is a reasonable way to create
a strong trust bond with consumers, as it has
been disputed that retailers need to earn the
right to collect consumer data, rather than
take it without permission.
There are a number of factors that need to be
considered when collecting data from
consumers, these include:
• What technology is going to be used to
collect such data?
• How relevant is the data? What are the
benefits?
• Does the consumer know the data is
being collected?
• Do the Privacy/Data policies inform the
consumer well?
• Is the consumer going to be accepting
of this data being collected?
• Does it comply with data and privacy
laws?
• Have any ethical considerations been
made? Can consumers opt out?
These factors make up part of the best
practiCe guide, which a retailer must
consider when collecting consumer data to
become more ethical and digitally responsible.
‘There’s an unwritten contract
between retail brands and
consumers that cannot be
breached.’
- Andrew Busby, Zensar and Retail Week.
SO WHAT IS
THIS ABOUT?
WHY BECOME ETHICAL?
The data collected can be used to give the
customer a more personalised experience, as
location based text messages can be sent to
individuals, age-specific advertising can be
displayed based on face scanning and
notifications can be sent to customers if a
product they have been viewing online is in
the store they are visiting. These are only a
few examples of what technology can do to
enhance the in-store experience for the
consumer, though enhancing experience may
not be the main agenda for retailers. It has
been noted that data is power, and the more
data a retailer has the more influence they
could have on buying behaviours, which could
in turn increase sales and profit.
6. 6
KEY FACTORS
To simplify, five key issues that need to be
addressed have been proposed for retailers to
follow: Customers, Data Supply Chain, Laws
and Policies, Technology and Business
Benefits. Over the next few pages of this
booklet each of the issues will be
discussed with the steps that can be taken
to ensure a more ethical approach. Although
there are no spcific laws or requirements on
the matter of being ethical when handling
data, these guidelines will allow retailers to
create a more trustworthy environment, which
could in turn create competitive advantage.
From considerable research, it became clear
that the media has started to recognise the
trust issues between consumers and retailers.
Technology and innovation shows around the
world showcased the highest technical
equiptment to track customers and collect
data, but not only has there been a rise in new
technologies, there has been a rise in security
breaches when regarding the data collected.
As retailers collect more and more data about
their conusmers, there needs to be more
secure data warehousing and transparency
with the data supply chain. Consumers are
becoming more aware of the collection of
personal data and retailer’s need to start
changing their ways to build and keep the
trust of the consumer.
‘Customers are becoming more
knowledgeable than staff on
tech and data.’
- Claire Zuurbier, M&S.
WHAT YOU NEED TO KNOW
7. 7
Industry leaders have made statements that
the customer should be at the heart of every
decision, as ultimately, they are becoming
more knowledgeable in operations and are
“the masters of the
universe”.
- Alison Lancaster, McArthur Glen.
To ensure the journey of becoming more
ethical with data is smooth, it is important to
take every colleague on the same journey,
ensuring everyone knows what’s happening
and why it’s happening. This way each staff
member will be able to answer any queries
customers may have about their data. With
this in mind, it’s time to take a step back and
listen to what the consumer is saying,
because after all, without them, no retail
environment would survive. This leads on to
the first factor that retailers must consider
when collecting consumer data: the consumer.
FIVE KEY
CONSIDERATIONS
8. 8
CONSUMERS
The main concerns when it comes to consumers are acceptance and trust. As retailers are more
often than not quite unclear with what data they are collecting and how they are collecting it,
when consumers first become aware of the activity, they can be quite unaccepting of the idea.
After several surveys from Accenture, Which? and academic studies, it became clear what views
the consumer has, a summary of these can be seen below:
As shown, the percentage
of consumers wanting
change is high. If you
were to put yourself in
the shoes of your
customer, as Mark Steel from
Argos suggested, would you agree
with these statements? If any of
these are areas of concern for your
business or you simply would like to
know more then these next pages will
guide you through an ethical approach to
collecting consumer data.
9. 9
CONSUMERS
ISSUE SOLUTION
CONSUMERS WANT CONTROLOVER THEIR PERSONAL INFORMATION.
- GET PERMISSION TO COLLECT DATA FROM
CONSUMERS BEFORE TAKING IT.
- BUILD RELATIONSHIPS WITH CONSUMERS
BEFORE ASKING FOR THEIR DATA.
- ALLOW CONSUMERS TO ‘OPT-OUT’ OF DATA
COLLECTION, EITHER ONLINE OF IN-STORE.
- BE CLEAR WITH INTENTIONS TO SELL OR
PASS ON DATA TO THIRD PARTIES, AND ALLOW
CONSUMERS TO DECIDE WHETHER OR NOT TO
PARTICIPATE IN THIS.
CONSUMERS WANT
TRANSPARENCYWHEN IT COMES TO DATA COLLECTION.
- BE CLEAR WITH OPERATIONS, IF YOU ARE
COLLECTING DATA FROM CONSUMERS, LET
THEM KNOW!
- PLACE INFORMATION BOARDS IN STORE AND A
SECTION ONLINE THAT EXPLAINS WHAT DATA IS
BEING COLLECTED, HOW IT IS BEING COLLECTED
AND WHY.
CONSUMERS ARE UNCOMFORTABLE WITH
TRACKING, MOSTLY IF THIS IS
PERFORMED THROUGH CAMERAS THAT
CAPTURE IMAGES OF CONSUMERS.
- EXPLAIN TO CONSUMERS THE BENFITS OF THIS
KIND OF DATA CAPTURE. HOW IS THIS GOING TO
ENHANCE THEIR SHOPPING EXPERIENCE?
- ASK CONSUMERS IF THEY WANT A MORE
PERSONAL SHOPPING EXPERIENCE? IF THEY DO
EXPLAIN THE NEED TO UNDERSTAND EACH CON-
SUMER MORE IS THE REASON FOR THIS DATA
CAPTURE.
- ONLY COLLECT DATA THAT IS NECCESARY.
- WORK ON UTLISING THE DATA YOU ALREADY
HAVE BEFORE LOOKING FOR NEW METHODS OF
DATA COLLECTION SUCH AS LOCATION
TRACKING OR FACE SCANNING.
10. 10
“The digital universe is doubling
every two years and is expected to
grow to 40 trillion gigabytes (more
than 5,200 gigabytbes for every
man, woman and child in 2020).”
- Andrew Poppleton, Accenture (2014)
11. 11
DATA SUPPLY CHAIN
The main concern with the data collected is
the idea of a data supply chain, its
transparency and security. Technology is
becoming increasingly advanced and industry
leaders are now calling data the LIFEBLOOD of
their organisation. It’s not enough to just
collect data, factors such as collection,
storage, security and analysis must be
considered, and data must be thought of as a
supply chain to enable the information to flow
smoothly through all parts of the business.
- CREATE A DATA PLATFORM THAT STORES DATA
SECURELY AND WHERE ALL STAKEHOLDERS
CAN ACCESS, ANALYSE AND USE THE
INFORMATION.
- RECOGNISE SPECIAL PROTECTION OVER
CHILDREN’S DATA IF IT’S COLLECTED.
- RE-ASSURE CONSUMERS THEIR DATA IS SAFE
AND INCLUDE A DATA STORAGE SECURITY
SECTION IN YOUR PRIVACY POLICY. DON’T JUST
SAY THE DATA IS SECURE, EXPLAIN HOW.
To read more on data supply chains please
visit: http://www.accenture.com/microsite/
it-technology-trends-2014/Documents/Tech-
Vision/Downloads/Accenture_Technology_Vi-
sion_2014_Trend3.pdf
CONCERNS
CONSIDERATIONS
The aim is to ultimately create and end-to-end
view of the data that is collected, so every
member of the organisation can access,
analyse, understand and use the data with
ease. Not only does everyone need to be able
to use the data with ease, this process should
be communicated with the consumer,
allowing them access to information about
where their data is and what is happening to
it. This transparency will help create the trust
bond between consumers and retailers that
was previously mentioned in the guide.
Security is becoming the main topic for
discussion accross industry leaders. Building
in data safeguarding from the very beginning
of the data collection process is vital. This
level of security should be consulted with the
providers of the data collection platforms, as
this should be built into the software. The
privacy of consumer’s data should be
considered and built in to the concept from
the start, making sure data is not shared with
any parties more than neccesary
12. 12
LAWS AND POLICIES
PERSONAL DATA SHALL BE PROCESSED FAIRLY AND
LAWFULLY AND, IN PARTICULAR, SHALL NOT BE
PROCESSED UNLESS... THE DATA SUBJECT HAS GIVEN HIS
CONSENT TO THE PROCESSING”.
THE DATA PROTECTION ACT (DPA), 1998.
At present, the only relevant law is the Data
Protection Act 1998 (DPA), and policies such as
privacy, data and security all differ depending
on the business. As a retailer, it is your
responsibility to keep all policies up to date,
and make the consumer aware when these
policies change. You must comply with the
DPA from the moment data is obtained until it
is deleted or destroyed.
A guide to understanding the Data Protection Act can be found at https://ico.org.uk/media/for-organisa-
tions/documents/1607/the_guide_to_data_protection.pdf
- WRITE A PRIVACY NOTICE THAT
EXPLAINS TO THE CONSUMER HOW THE
INFORMATION IS USED. THIS SHOULD
INCLUDE...
YOUR IDENTITY AS A COMPANY, WHO
YOU ARE, WHERE YOU ARE BASED
AND IF YOU ARE NOT UK BASED,
YOUR UK REPRESENTITIVE.
WHY YOU ARE COLLECTING THE DATA
AND WHAT YOU INTEND TO USE THE
DATA FOR.
ANY EXTRA INFORMATION YOU NEED
TO GIVE CUSTOMERS TO ENEABLE
YOU TO PROCESS THE DATA FAIRLY.
Recently, there have been well documented
and publicised cases of data breaches, where
databases were hacked and millions of
customers data was taken. Unfortunately, this
is due to lack of security, but to better protect
yourself your policies and operations should
be written clearly to prevent devastating
lawsuits if a breach occurs. The clearer you
are, and the more information you state, this
will reduce the likelihood of your company
being penalised in the long term.
“
13. 13
- ONLY COLLECT DATA IF YOU HAVE A VALID
REASON. COMMUNICATE THIS REASON WITH
THE CONSUMER.
-DEFINE WHAT TYPE OF DATA YOU ARE
COLLECTING: GENERAL, PERSONAL AND
SENSITIVE ETC. INCLUDE THIS INFORMATION
IN YOUR DATA POLICY.
- CREATE A PRIVACY POLICY THAT
DISTINGUISHES WHETHER CONSUMERS DATA IS
ANNONYMOUS OR NOT.
The following considerations should be made to ensure a more ethical
approach, regarding the laws and policies around data collection. The
clearer and more accurately you write your policies, the easier it is for
customers to understand and less questions will be asked.
- BE CLEAR ON YOUR INTENTIONS.
- DEVELOP A DATA POLICY THAT FOCUSES
SOLELY ON INFORMING THE CONSUMER WHAT
DATA YOU ARE COLLECTING, WHY YOU ARE
COLLECTING IT AND HOW IT IS GOING TO
BENEFIT THE CUSTOMER.
- UPDATE THE POLICIES EVERY TIME A CHANGE
IS MADE, OR A NEW TECHNOLOGY IS INSTALLED
THAT COLLECTS DATA.
CONSIDERATIONS
THE FUTURE
In 2012, the Eurpoean Commission proposed
a regulation of the European Parliament and
of the council on the protection of individuals
with regard to the processing of personal data
and on the free movement of such data.
This means, the European Commission are
attempting to change the law with regards to
personal data and it’s protection. The
reform has not yet been passed but by 2017
there will have been a decision made on
whether or not the laws in the EU will change.
The main changes to the Data Protection law
will include giving indiviuals:
- THE RIGHT TO BE ASKED FOR CONSENT
- THE RIGHT TO BE FORGOTTEN
- THE RIGHT TO DATA PORTABILITY
The reform, if passed, will also mean changes
for retailers too:
- FINES OF 5% OF GLOBAL ANNUAL TURNOVER
IF PERSONAL DATA IS ABUSED
- THE DEFINITION OF PERSONAL DATA WILL
BROADEN, BRINING MUCH MORE DATA INTO
THE REGULATED PERIMITER
- MUST GIVE JUSTIFICATION TO THE CONSUMER
ON WHY YOU ARE PROCESSING THEIR DATA
- ORGANISATIONS SHOULD APPOINT A DATA
PROTECTION OFFICER
- IF YOU ARE COLLECTING CONSUMERS DATA
YOU WILL BE LIABLE FFOR THE SECURITY OF IT
AND IF THERE ARE RISK OF BREACHES TO THE
SECURITY THE CONSUMER MUST BE NOTIFIED
More changes may be made, the full reform
notice can be found at: http://eur-lex.europa.
eu/legal-content/EN/TXT/PDF/?uri=CELEX-
:52012PC0011&from=en
14. 14
TECHNOLOGY
One of the main contributors to the recent
worry around data ethics is the world of
technology and innovations. At the recent
technology shows in the UK, innovations such
as face scanning cameras that determine age,
devices that can pick up mobile signals within
a certain radius and mannequins that have
hidden cameras to track customers in store.
Though these technologies may be beneficial
to retailers to help gain more insight into who
the customer is and what their every move in
store is, the technology can be in most cases a
hefty investment.
Adapted from the University of Cambridge, the
key steps in choosing and investing in new
technology is shown below:
1. Identify the problem and
the technological solution.
2. Understand the
customers' needs.
3. Involve the customer in
the development.
These 3 key steps suggest that investment in
new technology should be highly customer
focussed, and that there must be some kind of
problem/gap in the retail environment for the
technology. The first point is also what many
industry leaders stated, technology should not
be implemented for the sake of
technology, there must be a clear problem
that will be solved by the technology. The data
a store already collects about their customer
should be fully utilised before investing in
new data collection methods.
Understanding customer needs and involving
the customer in the development of the
investment both suggest that because the
technology is used to benefit the customer,
the customer should have a say in the
decision. Involving the customer could be as
simple as a customer survey asking what
services they would like in store, to focus
groups to test out new technologies and
feedback on their views about technology
before it is fully implemented. Ultimately, this
leads back to the ‘customer is king’ statement,
and giving the customer more power by
being involved in the decisions. If customers
are not happy with any aspect of the technolo-
gy, these can be discussed and resolved be-
fore investment, contributing towards a more
ethical environment.
15. 15
BUSINESS BENEFITS
TRUST
The Data Protection reform that is being
considered by the European Commission may
pass in the next 12 months and a more thical
approach will be mandatory.
of consumers are more likely to accept
a retailer taking their data and trust them
with it if they are a loyal customer. The majority
of this guide has had a customer focus, but
ultimately, as retailers decisions must be made
that are going to benefit the business in one way
or another. Our obvious goal is to boost sales and
profit, and a more ethical approach to handling
consumer data will gain trust and in turn create
loyal customers and boost sales.
Data ethics are a contemporary issue
Becoming ethical and more digitally
responsible will provide a competitive edge
Changing ways now before it’s too late
could save money in the long term
FACTORS TO CONSIDER
16. 16
It has been discussed that there may be an
issue with slow ROI when it comes to
investing in new methods of data
collection, but it has been suggested there
is a HALO EFFECT when regarding customer
experience. The better
experience a customer receives the more
likely they are to return and tell others about
their experience, though customers giving you
access to their data will expect a better
service in return.
To maximise the return on investment it is
suggested that you should start with your
staff, train them in the subject and work up,
ensuring everyone is on the same page.
STAFF TRAINING
Many industry leaders have suggested that it
is important to focus on staff training and
ensuring everyone is on the same journey
together when becoming more tech and data
savvy. It’s vital that when investing in a new
data collection method that the
implementation is thorough and approached
with an ‘all or nothing’ attitude to ensure the
most successful outcome.
RESEARCH
INVEST
BUSINESS BENEFITS
RETURN ON INVESTMENT (ROI)
COST
Although there are many positive
benefits embarking on a journey to
becoming a more ethically,
digitally responsible retailer, there
are also some downsides, the main
being cost. The main costs that
will occur are...
Investing in technology to capture data
Maintenance of the technology
Training all staff on technology/data usage
Developing a secure platform to store data
17. 17
ROLE SPECIFICS
To ensure the company is working to a high standard of digital responsibility, there are
different responsibilities for each role within retail that need to be met, from implementing a
thorough data policy to basic knowledge on what is happening throughout the company
regarding data. This next section is going to outline the specifics for Head Office, Store
Managers and Sales Assistants, what they need to know and how they play a part in creating a
more digitally responsible and ethical workplace.
- CREATE A SOUND DATA POLICY AND
PRIVACY POLICY AND HAVE THEM EASILY
VISIBLE AND ACCESSIBLE TO CONSUMERS.
- FOLLOW THE POLICIES AND UPDATE THEM AS
THEY CHANGE.
- CREATE INFORMATION BOARDS FOR STORE
MANAGERS TO DISPLAY IN STORE.
- SEND DATA PROTECTION ONLINE TESTS TO
STORES FOR ALL STAFF TO COMPLETE.
- COMPLETE TESTS AND TRAINING ON DATA
PROTECTION AND PRIVACY.
- BE AVAILABLE FOR CUSTOMER QUIRIES ON
THEIR DATA AND THE TECHNOLOGY USED IN
STORE TO COLLECT DATA.
- DISPLAY INFORMATION BOARDS IN STORE SO
CUSTOMERS ARE AWARE OF WHAT DATA
COLLECTION IS TAKING PLACE IN STORE.
- CREATE A HUB FOR CUSTOMERS TO ASK
QUIRIES ABOUT THE DATA COLLECTION.
- INCLUDE THOROUGH TRAINING OF DATA
COLLECTION AND BEST PRACTISE IN EACH STAFF
MEMBERS TRAINING, AND HAVE
FOLLOW UP TESTS WHEN NEW DATA
CAPTURE TECHNOLOGIES ARE
IMPLEMENTED OR POLICIES CHANGE.
19. 19
CHECKLIST
This page has been created to ensure all aspects of the journey to becoming more ethical with
collecting consumer data in store have been covered. This checklist can be used by head office
to ensure full infiltration of ethical practise, once the list is checked, you should be well on the
way to becoming a more digitally responsible enterprise when handling consumer data.
Have you recently
implemented or thinking about
implementing data collecting
technology?
Have you updated your
privacy policy and created a
data policy?
Have you created in-store
notices to inform consumers
what data is being collected
and how?
Have you created an option for
consumers to opt out of the
data collection?
Have you developed a secure
platform to store the data on?
Have you made a clear case for
why you need to collect this
data?
Have you got permission from
customers to collect their
data?
Have you trained all staff on
data protection, why the data
is collected, how it’s collected
and what data is collected?
Have you tested the data
collection on staff before
making it live to customers?
Have you updated policies and
provacy notices when data
collection has changed or
technology has been updated?
20. 20
REFERENCES
Exhibitions:
Internet Retailing Expo 2015 - Birmingham
Retail Business Technology Expo 2015 - London, Olympia
Online Documents:
Accenture. (2015) Technology Vision 2015: A case for data ethics. Retrieved from:
http://www.accenture.com/us-en/outlook/Pages/outlook-journal-2015-case-data-ethics.aspx
Curtis, S. (2014, March 12). Europe backs stronger data protection rules. The Telegraph. Retrieved from: http://www.
telegraph.co.uk/technology/internet-security/10692265/Europe-backs-stronger-data-protection-rules.html
Data Protection Act 1998. (29) [online]. Norwich: The Stationary Office.
DMA. (2014). EU Data Protection Reform – What you need to know. Retrieved from http://www.dma.org.uk/article/eu-
data-protection-reform-what-you-need-to-know.
European Commission. (2012). Proposal for a regulation of the European Parliament and of the council
on the protection of individuals with regard to the processing of personal data and on the free movement of such
data (General Data Protection Regulation). Retrieved from:
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52012PC0011&from=en
ICO. (2015). The Guide to Data Protection. Retrieved from https://ico.org.uk/media/for-organisations/docu-
ments/1607/the_guide_to_data_protection.pdf.
Poppleton, A. (2014). Putting information into circulation. Retrieved from http://click-accenture.com/putting-infor-
mation-into-circulation/#.VVEdEIvBzzI.
University of Cambridge. (2009). Making the business case for new technologies. Retrieved from:
http://www.ifm.eng.cam.ac.uk/uploads/Resources/Briefings/v1n3_ifm_briefing.pdf
Which?. (2015). Are shops spying on you?. Retrieved from:
http://www.which.co.uk/news/2015/03/five-ways-shops-are-spying-on-you-398535/.
Online Images:
Image 1: Matthew Butler [butlertotheb]. (2012, 13 Nov). Isolated Crowd of People Walking Towards w/ Alpha [video
file] Retrieved from: https://www.youtube.com/watch?v=xVk49-cNmMs
Image 2: Wirth Creative. (n.d.). Crowd. [Photograph] Retrieved from: http://wirthcreative.com/archives/464
Image 3: Pixshark. (n.d.) Engaged with technology. [Phototgraph] Retrieved from: http://pixshark.com/future-tech-
nology.htm
Image 4: The Telegraph. (2014) Data security - SME Business Essentials. [Photograph] Retrieved from: http://www.
telegraph.co.uk/technology/internet-security/10692265/Europe-backs-stronger-data-protection-rules.html
Image 5: AMP Technologies (n.d.). mdconstrt. [Photograph] Retrieved from: http://amptechnow.com/wp-content/up-
loads/2013/06/mdconstrt.jpg?3adfee
Image 6: Wonderful Engineering. (n.d.). Technology Wallpaper. [Photograph]. Retrieved from: http://cdn.wonderfu-
lengineering.com/wp-content/uploads/2014/01/Technology-Wallpaper.jpg