How to Update Marketing Channels for GDPR
A Practical Guide for Marketers
May 2018
Erik Archer Smith
Marketing Director, ABM
Treasure Data
Treasure Data
• Customer Data Platform
• 6 years in business
• Series C
• Silicon valley + Tokyo + Seoul
• Created Fluentd, and others
WHAT WE WILL COVER
1.Alignment
2.GDPR Controllers, Processors, Subjects
3.Rights of Data Subjects
4.Segmenting and segmenting your database
5.Managing Consent + Privacy Preferences
6.Running Opt in Campaigns
7.Webforms and Inbound Leads
8.Lead Vendors: Lists + SaaS
9.Managing Opt outs
10.Outbound Marketing Tactics: calls, emails, social media, direct mail
11.Field Marketing + Events
12.Digital Ads: retargeting, lookalike, social media, IP targeting, DMPs
ALIGN WITH YOUR LEGAL COUNCIL
WHO’S INVOLVED IN GDPR COMPLIANCE
“PROCESSOR”
A natural or legal person, public authority, agency
or other body which processes personal data on
behalf of the controller
“CONTROLLER”
Natural or legal person, public authority, agency or
other body which, alone or jointly with others,
determines the purposes and means of the
processing of personal data
“DATA SUBJECT”
An identifiable natural person: one who can be
identified, directly or indirectly, in particular by
reference to an identifier– name, identification
number, location, online identifier
DATA IS THE WORLD’S MOST VALUABLE ASSET
RIGHTS OF “DATA SUBJECTS”
The right:
1.To be informed
2.Of access
3.To rectification
4.To erasure
5.To restrict processing
6.To data portability
7.To object
8.Pertaining to automated decisions and profiling
OPT-IN VS OPT-OUT
Opt in
● Email
● Cookies
● Texts
● Pixels / targeted advertising
Opt Out
● Calls
○ Voicemails
● Direct Mail
● Social Media*
SEGMENTING YOUR DATABASE
CRM
Marketing
Automation
Ad Platforms
Customer
Success
Historical
Data
Warehouse
EU companies +
contacts
UK companies +
contacts
Contacts with
UK / EU
Address
SYNCHRONIZE YOUR CONTACT FIELDS
Email opt in / out
Call opt in / out
Cookie opt in / out
Targeted ad opt in / out
Social media opt in / out
Direct mail opt in / out
CRM
Marketing
Automation
Ad Platforms
Customer
Success
Historical
Data
Warehouse
OPT IN CAMPAIGNS (“Permission Passing”)
1. Unify all email databases
2. Create an EU / UK segment in email / marketing
automation software
3. Exclude all contacts who have previously opted
out
4. Customize messaging by vertical (not related to
GDPR, but improves open and response rates)
5. Launch a sequence of three emails, ending with
a “last chance to opt in” call to action
Hi John,
Yes, I would like to continue...
WARNING: RESPECT EXISTING OPT OUTS
“Businesses must
understand they can’t
break one law to get
ready for another.”
- ICO
MANAGING INBOUND LEADS
Simple
1.Create a double opt in form on all
web forms
2.Link to your privacy policy
Advanced
● Use a country pick list to generate
additional GDPR fields when an
affected country is selected
● Use IP lookups and cookies to
dynamically generate GDPR related
forms
COOKIES
Opt in
- Need to have a cookie pop up
- Clearly state what the cookies are
used for
- Provide a link to your terms and
privacy policy
Performance Cookies are OK
- Cookies to track A/B testing
- Cookies to track / optimize site
performance
LEAD / CONTACT LISTS - WAIT AND SEE
SaaS Lead Vendors
“[2 years ago we] implemented a plan
to provide notice to all EU-based
contacts in our database. The notices
state that we are processing their
business contact information in our
database to provide to our paying
clients for their marketing purposes. We
give each such person the right to opt
out of our database upon request, and
have been honoring such requests since
we implemented the notice program.”
List Vendors
LEAD / CONTACT LISTS - WAIT AND SEE
SaaS Lead Vendors
“[2 years ago we] implemented a plan to
provide notice to all EU-based contacts in
our database. The notices state that we are
processing their business contact
information in our database to provide to
our paying clients for their marketing
purposes. We give each such person the
right to opt out of our database upon
request, and have been honoring such
requests since we implemented the notice
program.”
List Vendors
MANAGING CONSENT
Consider a consent / permissions
management system
● Connects to most systems
● Change storage / audit features
● May have templates
OUTBOUND TACTICS: COLD CALLS
Opt-out
TIPS
Ensure all cold calls or voicemails to EU contacts include an opt out: “if you’d
like to stop receiving calls, just let me know”
Document opt outs in activity dispositions:
❏ Voicemail with opt out
❏ Called, qualified, scheduled follow up
❏ Called, incomplete, scheduled follow up
❏ Called, sent [asset name], scheduled follow up
❏ Called, sent [asset name],
❏ Called, incomplete, opted out of calls
OUTBOUND TACTICS: COLD EMAILS
Can legitimate interest be used to cover cold emails?
Wait and see
OUTBOUND TACTICS: DIRECT MAIL
Direct Mail is “Opt-out”
- Document activity in your CRM
- Include opt out information in the
package itself
Field Marketing
● Review organizer contracts
● Add “opt in” to lead scanner
● Have a sign at the booth
● Train / certify booth staff
ADVERTISING
PII: Contact based, cookie based, IP based, Device ID
- Opt in
- Disclosed in terms + privacy on form fill or cookie notification
Lookalike
- Model off of “opt in” contacts
- Anonymized or pseudo anonymised data - wait and see
Corporate IP Address (ABM):
- Ok but don’t blend with other data-points
DMPs
Social Media
TAKEAWAYS
1.Ensure all your different prospect and customer databases have consistent
communications preferences fields that are synced daily
2.Run an opt in / permission passing email campaign for your current EU / UK
contacts
3.Remove residual pixels + cookies
4.Update your lead capture forms and cookies to be opt in
5.Revisit your programmatic advertising and strongly consider stopping any
channel that relies on PII that you do not directly control
6.Create a universal permissions page to meet access, edit, delete requests
Marketers Guide to GDPR
https://www.treasuredata.com/resources/marketers-guide-to-gdpr/
Thank You
GDPR Resources
1.GDPR Blog: GDPR is Approaching: Are You Ready for the Data Privacy Challenge?
2.GDPR FAQ for Customers: Using the Treasure Data Platform in a GDPR World
3.GDPR Whitepaper: https://www.treasuredata.com/resources/marketers-guide-to-gdpr/

GDPR: A Practical Guide for Marketers

  • 1.
    How to UpdateMarketing Channels for GDPR A Practical Guide for Marketers May 2018 Erik Archer Smith Marketing Director, ABM Treasure Data
  • 2.
    Treasure Data • CustomerData Platform • 6 years in business • Series C • Silicon valley + Tokyo + Seoul • Created Fluentd, and others
  • 3.
    WHAT WE WILLCOVER 1.Alignment 2.GDPR Controllers, Processors, Subjects 3.Rights of Data Subjects 4.Segmenting and segmenting your database 5.Managing Consent + Privacy Preferences 6.Running Opt in Campaigns 7.Webforms and Inbound Leads 8.Lead Vendors: Lists + SaaS 9.Managing Opt outs 10.Outbound Marketing Tactics: calls, emails, social media, direct mail 11.Field Marketing + Events 12.Digital Ads: retargeting, lookalike, social media, IP targeting, DMPs
  • 4.
    ALIGN WITH YOURLEGAL COUNCIL
  • 5.
    WHO’S INVOLVED INGDPR COMPLIANCE “PROCESSOR” A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller “CONTROLLER” Natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data “DATA SUBJECT” An identifiable natural person: one who can be identified, directly or indirectly, in particular by reference to an identifier– name, identification number, location, online identifier
  • 6.
    DATA IS THEWORLD’S MOST VALUABLE ASSET
  • 7.
    RIGHTS OF “DATASUBJECTS” The right: 1.To be informed 2.Of access 3.To rectification 4.To erasure 5.To restrict processing 6.To data portability 7.To object 8.Pertaining to automated decisions and profiling
  • 8.
    OPT-IN VS OPT-OUT Optin ● Email ● Cookies ● Texts ● Pixels / targeted advertising Opt Out ● Calls ○ Voicemails ● Direct Mail ● Social Media*
  • 9.
    SEGMENTING YOUR DATABASE CRM Marketing Automation AdPlatforms Customer Success Historical Data Warehouse EU companies + contacts UK companies + contacts Contacts with UK / EU Address
  • 10.
    SYNCHRONIZE YOUR CONTACTFIELDS Email opt in / out Call opt in / out Cookie opt in / out Targeted ad opt in / out Social media opt in / out Direct mail opt in / out CRM Marketing Automation Ad Platforms Customer Success Historical Data Warehouse
  • 11.
    OPT IN CAMPAIGNS(“Permission Passing”) 1. Unify all email databases 2. Create an EU / UK segment in email / marketing automation software 3. Exclude all contacts who have previously opted out 4. Customize messaging by vertical (not related to GDPR, but improves open and response rates) 5. Launch a sequence of three emails, ending with a “last chance to opt in” call to action Hi John, Yes, I would like to continue...
  • 12.
    WARNING: RESPECT EXISTINGOPT OUTS “Businesses must understand they can’t break one law to get ready for another.” - ICO
  • 13.
    MANAGING INBOUND LEADS Simple 1.Createa double opt in form on all web forms 2.Link to your privacy policy Advanced ● Use a country pick list to generate additional GDPR fields when an affected country is selected ● Use IP lookups and cookies to dynamically generate GDPR related forms
  • 14.
    COOKIES Opt in - Needto have a cookie pop up - Clearly state what the cookies are used for - Provide a link to your terms and privacy policy Performance Cookies are OK - Cookies to track A/B testing - Cookies to track / optimize site performance
  • 15.
    LEAD / CONTACTLISTS - WAIT AND SEE SaaS Lead Vendors “[2 years ago we] implemented a plan to provide notice to all EU-based contacts in our database. The notices state that we are processing their business contact information in our database to provide to our paying clients for their marketing purposes. We give each such person the right to opt out of our database upon request, and have been honoring such requests since we implemented the notice program.” List Vendors
  • 16.
    LEAD / CONTACTLISTS - WAIT AND SEE SaaS Lead Vendors “[2 years ago we] implemented a plan to provide notice to all EU-based contacts in our database. The notices state that we are processing their business contact information in our database to provide to our paying clients for their marketing purposes. We give each such person the right to opt out of our database upon request, and have been honoring such requests since we implemented the notice program.” List Vendors
  • 17.
    MANAGING CONSENT Consider aconsent / permissions management system ● Connects to most systems ● Change storage / audit features ● May have templates
  • 18.
    OUTBOUND TACTICS: COLDCALLS Opt-out TIPS Ensure all cold calls or voicemails to EU contacts include an opt out: “if you’d like to stop receiving calls, just let me know” Document opt outs in activity dispositions: ❏ Voicemail with opt out ❏ Called, qualified, scheduled follow up ❏ Called, incomplete, scheduled follow up ❏ Called, sent [asset name], scheduled follow up ❏ Called, sent [asset name], ❏ Called, incomplete, opted out of calls
  • 19.
    OUTBOUND TACTICS: COLDEMAILS Can legitimate interest be used to cover cold emails? Wait and see
  • 20.
    OUTBOUND TACTICS: DIRECTMAIL Direct Mail is “Opt-out” - Document activity in your CRM - Include opt out information in the package itself
  • 21.
    Field Marketing ● Revieworganizer contracts ● Add “opt in” to lead scanner ● Have a sign at the booth ● Train / certify booth staff
  • 22.
    ADVERTISING PII: Contact based,cookie based, IP based, Device ID - Opt in - Disclosed in terms + privacy on form fill or cookie notification Lookalike - Model off of “opt in” contacts - Anonymized or pseudo anonymised data - wait and see Corporate IP Address (ABM): - Ok but don’t blend with other data-points DMPs Social Media
  • 23.
    TAKEAWAYS 1.Ensure all yourdifferent prospect and customer databases have consistent communications preferences fields that are synced daily 2.Run an opt in / permission passing email campaign for your current EU / UK contacts 3.Remove residual pixels + cookies 4.Update your lead capture forms and cookies to be opt in 5.Revisit your programmatic advertising and strongly consider stopping any channel that relies on PII that you do not directly control 6.Create a universal permissions page to meet access, edit, delete requests
  • 24.
    Marketers Guide toGDPR https://www.treasuredata.com/resources/marketers-guide-to-gdpr/
  • 25.
  • 26.
    GDPR Resources 1.GDPR Blog:GDPR is Approaching: Are You Ready for the Data Privacy Challenge? 2.GDPR FAQ for Customers: Using the Treasure Data Platform in a GDPR World 3.GDPR Whitepaper: https://www.treasuredata.com/resources/marketers-guide-to-gdpr/