List Buying Guide: Be a Good Data Steward

Strong data security and privacy practices are good for your company, the industry and the customer

August 2006 By Hallie Mummert

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Another best practice is not to acquire more data than you need, especially sensitive data like social security numbers or credit card numbers. Why deal with the liability attached to this kind of data unless you have to, Mastria remarks. If you do use personally identifiable data for marketing purposes, make sure you have training procedures on security/privacy in place for anyone in your company who might come into contact with this information.



Data Usage

When it comes to data usage, an important step every marketer should be taking is to honor consumer requests to stop receiving postal mail, e-mail, phone calls and faxes; suppression also should be granted to those who do not want their data shared with outside parties under any circumstances. In addition to being regulated by a mix of federal and state laws—such as the Can Spam Act, for one—the deployment of an in-house suppression file is a condition of membership in the Direct Marketing Association (DMA).

A corollary to the subject of sourcing involves intelligent use of information on prospects and customers in your marketing efforts. One of the data issues of particular concern to Mastria is the existence of records on marketers’ files that either can’t be attributed to a source or that came from the Web but the original source driving the online response—e.g., direct mail, television—cannot be traced. In these instances, there is a danger to treating these respondents as part of the overall housefile, he explains, since you don’t know enough about them to develop a relevant contact strategy. In addition, your list rental clients won’t have much to go on for their marketing efforts, either. Implementing a sound matchback process is critical to identifying these unknowns in your promotions process so you can better determine how to engage them in the larger direct marketing process, Mastria states. Otherwise, he emphasizes, the industry is going to continue to see declining response rates due to ineffective marketing communications.

Data Transfer

Obviously, all parties in the data supply chain need to exert considerable effort to stay in line with state and federal legislation when sharing information. But what about industry self-regulation?

Harte-Hanks’ Pierce finds the list industry a changed business today. In the past, list rentals or exchanges might have taken place via a verbal agreement between companies that had a high trust level. Now, more contracts are used—and they’re reviewed by firms’ privacy and/or legal departments before being signed by employees who are responsible for their companies’ data policies, she says.

This diligence also is being applied to the inspection of mail pieces, telemarketing scripts and other direct marketing creative that marketers intend to send to the lists being requested for rental. Pierce notes the entire contents of such campaigns are being scrutinized to ensure all information is legal and appropriate for the audience. Even data compilers are asking for this information from their rental clients, she adds.

While this increasing adherence to rental clearance and data security best practices is heartening, Pierce hopes to see the list industry be more consistent as a group in following these processes and DMA guidelines. “We realize that if we don’t step up to the plate, we will face more legislation that might not be in the best interests of the consumer.”



Beyond Compliance

To better serve the public, experts agree that marketers must spend more time contemplating how data is used in the marketing process and what impact their decisions have on the world at large. “As marketers and custodians of data, we need to take the onus that data security is fundamental not only to our businesses but to the trust of the end customer,” says Mastria.

Companies that are leading the way in data best practices set their own high standards and then do business only with companies that offer similar levels of security and privacy protection, Isaacson notes. To develop these standards, companies can bring in an outside data security auditing firm to scrutinize their procedures, he explains, or at the very least, they should have a security professional—on-staff or outsourced—review their relationships and contracts.

And don’t forget the tools developed by the DMA. Mastria, who served for several years as the association’s vice president of media and public relations, mentions a few guides and checklists that can help member companies get a handle on this topic:
* Do the Right Thing—takes the DMA’s member guidelines on regulatory issues and translates them into commonsense advice.
* Privacy Checklist—provides a comprehensive approach to data collection, usage and transfer.
* DMA Guidance: Screening Offers Before List Rental—also available to non-members, this advisory was developed with input from the Federal Trade Commission.



Considering that more than a few data security bills are up for congressional review, what can direct marketers do to anticipate the future? Isaacson, who two months ago was named co-chair of the DMA’s new Data Stewardship Council, sums up the issue: “If you follow your own data privacy people’s view of best practices for data stewardship and DMA guidelines, then you should be adhering to a standard that should govern all your business operations—whether or not there’s a pending law. Most laws don’t look at best practices, they look at common practices. If you’re looking at best practices, then you should be in a good position.”

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