GDPR Consent and “the re-permissioning dilemma”

Written by Jason Groom
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Originally published
March 21 2018,
April 10 2021

Keeping track of your customers, members and supporters is a headache, even for the smallest of businesses. Disparate systems, siloes of information, and data from indeterminate sources, is something most of us marketers are battling as GDPR approaches. Spare a thought then for those with literally hundreds of millions of subscribers, spread across all continents, and whose only prospect of 1:1 communications is electronic.


The Red Devils
More than just a football club, Manchester United is a brand recognised around the world.

 In 2011 it used a market research company, Kantar, to carry out a worldwide survey. It polled around 54,000 people in 39 countries and then extrapolated from these survey results to produce a global supporter estimate that reached a total of 659 million fans. Though they’re not necessarily all email subscribers, that’s quite a red army!


Stay United
manutd.jpgGary Lineker and his pundit pals are a weekend institution in our house. Our club allegiance rests elsewhere (sadly, in another league entirely!) but I noticed during recent TV coverage, pitch-side advertisements imploring fans to #StayUnited. Turns out this is MUFC’s campaign to re-permission their email subscribers and gain their consent to continue to receive email marketing from the club.

And there’s an incentive for doing so. Supporters that visited the Preference Centre and updated their preferences (irrespective of whether that was opt-in or opt-out) by the end of 2017 were entered into a prize draw with a chance to win 1 of 10 signed shirts. The incentive has since been refreshed to win a pair of David De Gea’s signed gloves.


Re-permissioning Stats
Back in August 2017 Campaign magazine ran a story that cited research by W8 Data and which found that only 25% of existing customer data meets GDPR requirements. Put another way, that “GDPR will render 75% of UK marketing data obsolete”.1 Because, to use it, marketers will need a fully documented permission trail, showing the source and a record of the consent obtained. Scary stuff. No wonder then, it maintains that one in three marketing campaigns are now focused on securing compliant consents!


Consent – what does it look like?
The ICO is always the “go to” resource for the facts and in-depth analysis2 but we found this quick and basic checklist, again from Campaign magazine3, really helpful: 

Have we asked for consent…

  • Prominently and separate from our usual terms and conditions?
  • In clear, plain and easy to understand language?
  • With an explanation as to why we want their data and all the ways we plan to use it?
  • For ourselves and for all the third parties the data may be shared with by name?
  • So that users understand they can withdraw or withhold consent without detriment?

 Answer a “no” to any or all of these and, if you’re planning on using consent as your legal grounds for processing data and contacting them electronically, you’ll need to think about re-permissioning yours too. Worth remembering though, that for direct mail – still leading the way in direct marketing ROI – the rules are not so onerous4.

Unless the #StayUnited campaign is a roaring success, you can expect to see some bulging postboxes around the M16 0RA area!

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