Data and direct marketing are inextricably linked. Put simply, you can have no contact of any kind without using your consumer’s correct personal information. Data quality must, therefore, be your priority at every level. But it is most critical for you regard to the legal imperatives and from the perspective of achieving optimum ROI.

 

Sourcing data

Cold data

  • ‘Warm’ versus ‘cold’ data

Data is often referred to as being:

  • ‘warm’ – when contact of some sort has been established by the brand on whose behalf your call is being made, or
  • ‘cold’ – when there has been no previous contact with the brand
  • Expect to need cold data

While intuition suggests that warm data is preferable to cold data, the reality is that your campaign will probably require cold data at some stage.

  • Cold data can be effective

Cold data can be as effective as warm data, when selected intelligently and appropriately.

  • Source cold data

If you are looking to contact consumers who are not already your customers, there are many sources of data available.

 

Data ownership

The following conditions are typical, but always check the precise terms of your own list rental agreement for variations.

  • One-off data usage

In most cases, data acquired for direct marketing purposes is purchased as list rental for one-off use.

The ‘use’ is generally defined as being a live, answered call with the correct consumer.

Once the consumer has declined to participate further as the call unfolds, their number is deemed to have been used and may not be called again.

  • Call-back permitted

The consumer may request to be called back at a more convenient time, in which case a further call may be permissible.

  • Limit number of attempts

Setting a limit on the number of times a number should be called where there is no answer or answer-machine disposition.

  • Positive response

A positive response, and one which entitles you to have ownership of that record, will depend on the terms of your list rental agreement.

This could be where your consumer has shown sufficient interest in your product or service to indicate that they have taken preliminary steps towards the conclusion of a contract, i.e. purchasing such product or service.

This would NOT normally include you simply claiming the consent of the consumer to be re-contacted at a later date, unless otherwise agreed by your data supplier.

 

Data owners

Telemarketers with knowledge and experience of the data market may choose to approach data owners directly.

 

List brokers

Those who are unfamiliar with the data market are at no disadvantage. There are many list broking experts who will advise, guide and acquire data on your behalf and at no additional cost.

  • Use DMA member brokers

To ensure a high level of both legal compliance and efficacy of the data, you should only use data owners or data brokers who are members of the DMA.

  • Do thorough due diligence

Whenever you buy or rent data, you are responsible for its compliance – so always ensure you conduct full due diligence on any data you source.

See the Buying, selling and renting data section of the Data guide for full details.

 

Origin

  • Check how data was collected

With the increase in TPS registrations in recent years, third-party data with telephone numbers is scarce. It is, therefore, incumbent upon you, as the telemarketer, to question the source of your data and the method by which it was collected and verified.

It is also worth considering under what circumstance the data was acquired, even if the data was collected in accordance with UK data protection legislation (i.e. offering an opt-out).

  • Check recency of data

Accuracy is also absolutely critical when considering choice of data.

You must ensure that data is accurate and up to date in order to ensure compliance with the DPA.

Best practice requires that you check on the provenance of the data and recency of the contact in order to ensure you reach your intended customer.

 

Handling data

Legal compliance

  • Use data legally

As well as gaining the assurance that the source data has been collected in accordance with the DPA and the PECR, it is imperative that you use the data with the same adherence to relevant legislation.

  • Screen cold data data against TPS and check accuracy

Screening cold data against TPS is a legal requirement, but it is also a legal requirement to ensure that data is accurate and up to date under the DPA.

  • Screen against other suppression files

Screen files against proprietary suppression files, where appropriate (i.e. mortality, gone-aways and homemover files), as well as internal suppression files.

  • Maintain DNC list

As a legal requirement, you must maintain and consistently update in-house do-not-call (DNC) lists and ensure that this information is always shared between any retained agencies and/or outsourced call centres. Often call lists are collated from a number of sources, and it is important to remember that these must always be run against your in-house DNC list.

Your in-house DNC list must always be updated to include any ‘do-not-call’ requests made to the agency or call centre(s).

  • Make data source available

Track the data chain as far back as possible so that you can correctly provide the source of the data if your consumer asks.

This is essential, even if it proves a challenge in the event of different sources of data being used for the same campaign.

  • Honour suppression requests promptly

Act upon suppression or subject access requests from consumers promptly – and certainly within a maximum of 40 days of the written subject access request.

  • Only use freshly-screened data

Before you can use data for telemarketing purposes, your must have updated or refreshed it (at the very least by

screening against suppression files) within the previous six months; and screened it against the TPS no more than 28 days prior to use (see below).

 

TPS

  • Screen before supplying

Data purchased through a third-party supplier, who is a DMA member, must have been screened against the TPS no more than 28 days prior to supply.

  • Screen before use

You must ensure that data has been screened against the TPS no more than 28 days prior to unsolicited calls being made.

  • Legitimate market research exception

The only exemption to this is for data which is to be used for legitimate market research.

  • Opted-in data exemption

Your proprietary lists (i.e. lists of consumers with whom you have an established relationship) may be used without cleaning against the TPS, providing your consumer has supplied their number directly to you (i.e. you have not sourced it) and you have gained their opt-in permission to use their number for direct marketing purposes.

 

TPS Assured

  • Accreditation of TPS compliance

TPS Assured is an annual audit and certification service that assesses whether your organisation complies with

PECR, Ofcom guidance and TPS Assured’s guidance on outbound telemarketing best practice.

If you’re a UK-based organisation that uses outbound telemarketing to contact UK consumers, you can apply for TPS Assured certification.

  • TPS Assured helps your business

Achieving TPS Assured accreditation helps your business with three key benefits:

  • Stay on the right side of the law

TPS Assured brings all the rules governing telemarketing together in one place to make it easier for you to comply and follow best practice.

You’ll also receive expert advice, guidance and immediate updates about any changes to the laws, rules or regulations that could affect the telemarketing industry.

  • Gain competitive advantage

Use the TPS Assured logo on your website and corporate literature to differentiate your business from those who have not achieved accreditation.

Accreditation also gives consumers confidence that you have been independently assessed.

  • Protect your reputation

Avoid the bad publicity and reputational damage of unwittingly breaking the law – as well as the hefty fines that come with it.

The ICO and Ofcom have issued non-compliant telemarketers with millions of pounds of fines over recent years – and will crack down heavily on any rogue practitioners.

  • Find out more and apply for accreditation

For more information and to apply for TPS Assured accreditation, visit: tpsassured.co.uk

 

Suppression files/’do-not-call’ lists

  • Offer opt-out

When undertaking warm calling, if your customer wishes to have their number added to your in-house suppression file, you should give them the opportunity to identify that they do not wish to receive calls on any telephone number associated with their account.

  • Honour DNC across multiple numbers

Consumers often have multiple devices and numbers and organisations tend to attempt to capture as many numbers as possible for a customer. Your management of suppression files must take this into account.

Scenarios where your customer is called on one number, requests to be added to a do-not-call list, and is then called on another number clearly brings DNC lists into disrepute with consumers.

  • Unsubscribe at individual’s level

Where possible, use account-oriented do-not-call lists so that you can still contact other customers in the same household.

 

Security

  • Be diligent with data

Take appropriate technical and organisational measures to protect the security of personal data, particularly when holding and transferring your consumers’ personal data.

  • Password-protect data

All files should be password-protected.

  • Strictly control access

No one should have access to your data unless they are directly involved in the process of preparation or use of the data.

  • Appoint data compliance officer

Appoint a person or persons to be aware of and responsible for your organisation’s DPA and PECR compliance relating to the security of personal data handled as part of your telemarketing activities.

  • Use DataSeal

DataSeal is the industry standard for security of data handling and covers the transfer or data between two parties.

DataSeal is administered by the DMA. For full information and to apply for accreditation, visit:

dma.org.uk/content/dataseal

 

Using data

Selection and targeting

  • Targeting is critical

Optimum targeting is an absolute imperative.

It is pointless to contact consumers who are inappropriate for the product or service that you are promoting – it will increase your costs, lower your conversion rate and is likely to antagonise some people.

  • Use detailed data

In order to maximise your targeting, use data with as much depth and detail as is possible.

There are many databases available that can provide not just socio-demographics, but also purchasing habits and intentions, hobbies and interests and even household income.

Do not compromise detail in favour of volume.

  • Test data first

Always validate and test each data selection against your campaign objectives prior to roll-out.

  • Over over-contacting consumers

When purchasing data for similar campaigns from the same list source, request the exclusion of data previously supplied in the last 12 months.

This will minimise the risk of consumer antipathy towards your brand from perceived over-contacting.

 

Data volume

  • Assess required data volume

Give special attention to the volume of data you will be using for your campaign. Factors that will influence this include:

  • Number of agents you will be using
  • Length of time that your campaign will run
  • Number of contacts per hour – time of day may influence this
  • Weigh up fine-tuning of data vs volume

Note that a greater emphasis on fine-tune targeting will reduce volume of data.

While it is imperative to ensure that your campaign is aimed at consumers most likely to respond positively, this consideration needs to be balanced with your overall campaign requirements.

You may want to adjust your requirements to take into account a lower volume of higher-quality data.

  • Plan good dialler usage

Do not underestimate the importance of good dialler planning and management – it is imperative that you constantly monitor turnover of your data.

Data that has been churned time and time again will not deliver your desired results.

 

Testing, analysis and refinement

  • Segment and test data

Segmentation of your data into test cells prior to calling and subsequent detailed analysis of results will reap dividends for your future campaigns.

The analysis of non-sales dispositions can optimise your targeting for future campaigns.

  • Gather additional information

Ask consumers to volunteer additional key information (subject to compliance with the DPA) such as date of birth, presence of children or key events.

This will help you to match products to suit your consumer during the course of the call, whilst post-campaign analysis will also help shape appropriate targeting for future campaigns.

  • Continually improve scripts

Refine agents’ scripts as your campaign unfolds. Take the opportunity to learn about and improve your campaign by adapting and testing scripts to suit different datasets.

 

 

 

 

Data Review

Knowing how to contact previous customers, providing you have kept a customer database, ought not to be a problem. Finding new contacts is more difficult. However, you do know that you are looking for more people with familiar characteristics to your current customers. So, you can try looking for them using:

  • the internet
  • local or national telephone directories – Yellow Pages
  • trade directories or yearbooks
  • lists that can be bought or rented from professional brokers

If the last option is one to explore, try contacting the Direct Marketing Association (020 7291 3300). They will be able to put you in touch with suitable list brokers.

Sometimes you may find that trade associations or professional bodies will rent lists of their members. You should:

  • make sure lists match the customer types you seek
  • make sure lists are accurate and up-to-date
  • make sure you are clear about the charges and terms of use
  • check whether you need to register under the Data Protection Act (you almost certainly will)

A list broker should be able to help. Search the internet or look in Yellow Pages under Direct Mail. Also try the Direct Marketing Association.

Leads are those details – names, job titles, email addresses and phone numbers – that are vital to any business. There are numerous ways of sourcing them including searching trade directories, attending trade exhibitions or buying lists of ‘unqualified’ leads from suppliers. The better they fit with your customer profile, the more chance you have of converting them.

You should make sure that anyone you call is not registered with the Telephone Preference Service (TPS).

entral opt out register on which you can record your preference not to receive unsolicited sales or marketing calls. It is a legal requirement that all organisations (including charities, voluntary organisations and political parties) do not make such calls to numbers registered on the TPS unless they have your consent to do so.

Organisations with which you have an ongoing relationship, for example those who regard you as a customer, (or in the case of charities – a donor) may well gather your consent during the early stages of your relationship with them and will therefore be entitled to call you even if your number is registered on TPS, unless you have previously told them specifically that you object to them calling you for marketing purposes.

The TPS can accept the registration of mobile telephone numbers, however it is important to note that this will prevent the receipt of marketing voice calls but not SMS (text) messages. If you wish to stop receiving SMS marketing messages, please send an ‘opt-out’ request to the company involved.

As TPS registration only prevents marketing calls, organisations will still be able to call you for the purposes of genuine market research.