Paragon's Re-permissioning Cascade

Get ready for GDPR with Paragon's Re-permissioning Cascade

GDPR Re-permissioning
GDPR is coming ever closer and companies have a duty to ensure they have proper consent to communicate marketing messages to their customers. Consent needs to be  freely given, specific, informed and an unambiguous clear affirmative action. So, if your existing consent does not meet the GDPR definition then you will have to refresh that consent (re-permission) or find an alternative lawful basis (e.g. legitimate interest for direct mail) if that is possible.

Typically consent may not be acceptable in the new GDPR world because it was co-erced – i.e. bundled in with something else that you had to give consent to in order to receive the benefit; it was not an affirmative action – i.e. It was pre-ticked boxes/inferred from silence: you haven’t got proper records that they gave consent: or your permission was gained a very long time ago – ICO suggest over 2 years as a benchmark (but this can vary by sector).

If any of these hold true, then you will need to re-contact parts (or possibly all) of your customer database to get the right permissions. Recent Royal Mail research suggests that nearly one in five companies have already started, but that nearly half of all firms have no plans. As the deadline grows closer, there is a risk of individuals being bombarded with permission requests and choosing to decline much more than if they had been approached sooner.

In all likelihood this is going to involve a multi-wave, multi-channel approach (though mostly around e-mail and direct mail) to gain maximum impact and make sure you can still market to your base post GDPR. It will also help cleanse your data and take out those who really aren’t interested in your company or offering. If they don’t give consent, then in all likelihood they won’t buy/donate/change their behaviour or whatever you are looking for them to do. Looking at it positively, it’s a great re-set point to refresh  your approach and re-engage your prospects and customers.

To help organisations approach re-permissioning, Paragon have developed a Re-permissioning Cascade framework which you can download from the link below.

It is important to look at this in an integrated fashion and plan and co-ordinate channel efforts:

  • Understand which audiences it is key to re-permission (not all will be worth the investment) using  data analytics to profiling your base  in terms of demographics and customer value
  • Understand which channels are open to you to use and prioritise based on audience likelihood to respond and engage and the cost – whilst email is cost effective to reach a large base the physicality of mail lends credibility and trust and customers can feel more valued
  • Work out how often you want to contact them before giving up, making sure you aren't hounding them
  • Track engagement and switch channels as necessary
  • Re-set the clock for when consent will need refreshing in the future

It is vital to get the messaging right and potentially vary this for different audiences using dynamic content for audience based on demographics and making the content most relevant to your audience. ‘Don’t miss out’ (loss aversion), ‘we’re spring cleaning’ , a focus on security and openness about the EU legislation, ‘get a more personalised service’ are amongst the many messaging options being deployed.

But what it comes down to, is that customers are more likely to give you consent if they value what you are offering (value exchange) and they trust and believe that you will do what you promise; that you are capable of holding personal information securely, that you won’t pass it to third parties and that you won’t bombard them with irrelevant marketing.

It needs to be easy for them  to give consent and  you need to ensure that the customer has the control to change their mind and take it away. Usually this will involve directing them to a Preference Centre that sits astride your database and CRM capabilities bringing everything together, offering the customer that control and giving your organisation fully auditable evidence to show that do you have the appropriate consent.  Paragon can help here too building out a microsite Preference Centre and linking it to the relevant data sources and marketing activity.

Re-permissioning is possibly one of the most important marketing campaigns you will ever run and it needs to be properly planned, created and delivered as a co-ordinated activity monitoring engagement (or lack of it) and reacting accordingly with pre-planned business rules. Simply put, getting it right will allow you to continue marketing to your company’s most valuable resource – your customers. 

The Re-permissioning Cascade outlines shows the sort of approach you might wish to take, (focussing on email and direct mail as these are the two main channels in use). Paragon’s planners and data analysts can help  tailor this for your company and its customers, our creatives can help you design and the materials that will  gain consent and we can deliver the programme for you end to end (database, print, mailing, email, Preference Centre, response handling, inbound call handling).

To discuss how Paragon can help you re-permission your customer base, contact us today.

Marc Michaels

Director of Strategy & Insight | Paragon Customer Communications


M: +44 (0) 7875 134 818

Re-permissioning Cascade

To download your Paragon's Re-permissioning Cascade click on the link 






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