On 25 May 2018, the data protection landscape changed forever. With a level of hysteria akin to the Millennium Bug, the implementation of the EU’s General Data Protection Regulation (GDPR) had brought with it both fear and anticipation.
For the unprepared the impending new rules, which increase the rights of individuals to control who holds information on them, what information is held and how it is used, had marked a potentially daunting task ahead to tighten up their processes in order to comply.
But many of those who acted early on to get their houses in order were able to take the time to process and prepare for the potential opportunities on the horizon.
For print, and direct mail in particular, GDPR presented an opportunity, not least because under ‘legitimate interest’ it does not require the same consent as other communications methods.
Yet the Advertising Association/WARC H1/Q2 2018 expenditure report found that spending on direct mail fell by 5% in H1 2018 compared to H1 2017, with a 4.5% decline forecast for the full year.
Additionally, in its results for the 26 weeks to 23 September 2018, Royal Mail reported that addressed letter volumes and total letter revenues including marketing mail were both down by 7% year-on-year.
Alongside GDPR’s one-time effect, marketing plans and, consequently, mail volumes and spending were also likely to have been affected by both continued paper price increases and uncertainty around Brexit during 2018.
There is a general feeling, however, that marketers and brands have been in a holding pattern of sorts while they take stock of the situation, and that some recovery is due sooner rather than later.
“Most organisations that we’ve spoken to have delivered on what’s necessary; they are broadly compliant with the new laws, they’ve taken on things like revising and updating their privacy policies, conducting the necessary audits of their data and putting in place the processes and technology they need to as part of GDPR,” says DMA head of insight Tim Bond.
“But because a lot of marketing departments’ attention was very much focused on making sure they were compliant and abiding by the new rules by May, there has potentially been a natural slowdown after that because of departments not having their new campaigns ready.”
Bond adds that as brands were starting to belatedly build their future campaigns, some companies that had used mail in the past were planning to use more of it while others that had never used it before were “potentially dipping their toe in for the first time”.
“That won’t show up in the figures yet but we’re confident that when we get into the new year and some of these pieces start to land, we will then start to see that the industry is still strong and rife,” he says.
Webmart chief executive Simon Biltcliffe says his company is indeed currently introducing – or reintroducing – direct mail to many businesses.
“B2C and B2B customers have typically reduced their mailings or their prospect list by 75%. Unless they have a specific knowledge of their customers, they have decided to opt them out.
“However, they are starting to feed them back in now because it has settled down a bit and we’ve got Partially Addressed Mail, door drop and unaddressed mail options, which are all quite exciting for reactivation.”
Partially Addressed Mail is a new mailing technique that Royal Mail has been trialling in recent months.
A GDPR-compliant, standard addressed advertising mail product, the initiative enables targeted mail marketing without using recipients’ personal data, by targeting households using geo-demographics at postcode level.
Biltcliffe says that while it’s “an exciting time” for those that are using direct mail for the first time, there is also an education process required.
“I think it’s too complex to do direct mail without assistance – that could be from a printer, a print manager, an agency, or Royal Mail themselves, but you need your hand holding through it.
“The reassuring tangibility that we see from direct mail is quite scary from a digital marketing person’s point of view. If there’s anything that isn’t quite right they can just change digital marketing, whereas it is a lot more difficult to correct printed physical tangible product on the fly.”
He adds: “Once [they’ve] gone back to mailing, then you can talk about impact and the exciting things that they can do with it.”
The fuller effects of GDPR are perhaps more likely to be felt much further down the line. With Christmas just around the corner and festive campaigns well underway, most mail houses are currently seasonally busy.
But as 2019 dawns and things quieten down, the new rules still present further opportunity ahead for print, particularly as at the same time there are rumblings that marketers and brands are becoming increasingly weary of the trustworthiness and effectiveness of digital alternatives.
But Jenny Moseley, co-founder and director of Opt-4 and the Data Protection Network, notes many businesses still have a lot of catching up to do.
“You ain’t seen nothing yet,” she quips. “There was a race to get things done, everybody thought 25 May was the deadline and it was up to a point. But beyond that you can’t rest a day since and companies are now beginning to realise that.”
And as data processors, she adds, printers also have additional challenges and liabilities under GDPR.
“My advice to any data processor is to make sure that your controllers are compliant as well as yourself. We’ve got some evidence that clients/controllers are requiring more of their data processors – in contracts they are trying to cover themselves and processors ought to be covering themselves too.”
She concludes: “And processors need to make sure that they’re not stepping into the controller role because they would be more liable if something goes wrong.”
Most sectors are returning to normal after a wobble
Judith Donovan, chair, The Strategic Mailing Partnership
There was undoubtedly a short-term wobble around GDPR immediately after its implementation; July and August were quieter than most of our members would normally expect to be. But while most sectors have now calmed down and come back to being normal, the exception is the charity sector.
It has not come back, and there is no doubt that charities are still extremely risk averse because they’ve had a double fight, not only because of GDPR but also because of the dangers of targeting vulnerable people with an overwhelming volume of requests for donations, which ultimately led to the introduction of the Fundraising Regulator.
Their entire landscape changed, both the voluntary and the regulatory side, and between that and GDPR they basically shut down. We’ve been talking to a lot of charities to stress that there is guidance and that legitimate interest is fine, but they say ‘our lawyers say we daren’t’.
I very much hope that the fall in direct mail volumes seen in the Royal Mail’s half-year results is a one-time effect. With the introduction of GDPR, I think many people were sitting on their hands as though the world had ended, and when they realised it hadn’t they started to act but there is a lead time to getting things out.
Stuff is now being sent out but it’s probably four to eight weeks later than it might have been. I would very much hope that some of the volume decline was that lag. All my board are reporting full order books until Christmas so it’s not that the demand isn’t there.
I think the Royal Mail’s Partially Addressed Mail service is a very imaginative solution. There are ways of doing a cold approach without having to get into GDPR and the rest of it, but it takes a while for the message to get through to people.
Where do you stand six months on from GDPR?
Patrick Headley, group chief executive, Go Inspire Group
“I don’t think volumes are going down anymore, not for the last couple of months; we are starting to see an increase now. I have been party to mailing plans for next year, which have doubled for one particular customer because they want cut-through. Retailers need people in their stores, clicking on their websites and buying stuff and they have to advertise what’s going on. We’ve all got a letterbox and it’s being underutilised at the moment. If you want cut-through, I wouldn’t send an email at the moment.”
Jacky Hobson, director, Up Marketing
“With GDPR there is a fabulous opportunity for direct mail, which some printers have probably seized but others have just missed it. I’m still seeing such a lot of misinformation around consent and legitimate interest and I think people either just didn’t bother to find out about it or were very ill-informed. As printers I think we should have been talking to customers and prospects, saying ‘don’t worry about GDPR because you’re definitely still safe with direct mail’. But in the B2B space really nothing much has changed.”
Robin Sumner, managing director, Romax
“Although clients understandably went through a nervous period leading up to May and for a month or two afterwards, in the last six months we are dramatically up on last year’s volumes, on average by about 30% year-on-year. Clients are increasingly curious about direct mail because of legitimate interest and GDPR is key in terms of data security and data management. I think businesses that have managed to get that and be ahead of the curve, and can demonstrate that to their clients, are in a strong position right now.”