• by Ray Schultz , Columnist, December 7, 2020

How can a brand be compliant while breaking the rules? 

Publishers Clearing House is walking that fine line, according to Sal Tripi, vice president, digital operations and compliance for PCH. 

The venerable sweepstakes company shoots out 6 billion emails a year, and averages a click rate of 28% for sent emails, Tripi said, speaking at MediaPost’s Email Insider Summit on Monday.

Operating at that scale takes time, talent and technology.  

It begins with its data governance. When the California Consumer Privacy Act was passed, PCH looked at it as an albatross, but the company soon saw opportunities for improving its data operation. 

Along the way, the company named a data czar, and purged “an enormous amount of data,” Tripi said. It also tried to look beyond CCPA. 

“There are a lot of nebulous areas, and no case law to go back and find what did they really mean,” Tripi observed. So PCH considers not only the letter of the law, but the intention. 

The first priority is transparency — as per the law, consumers can get access to everything that is held on them. 

Compliance also requires that vendors are compliant with regulations and are held accountable. 

But how does a brand like PCH get data? 

In the past, there were third-party data sources readily available, but those are shrinking. The company now must get first-party data direct for the consumer. 

PCH takes a staggered approach, picking up data based on affinities: hunting, fishing, country music, pets, cars and sports. The consumer may not even realize this is happening. 

“We’re not trying to get the mother lode of data in one sitting,” Tripi said. “each time they come back we get another little nugget of data.” 

It also tries to ensure that the data it has is actionable.

What does “actionable” mean? It means, first, that consumers shouldn’t have to scroll through multiple pages to find the content they want. They need to have it in real-time — not in two days.  

It also means that the content has to be fresh. “We’re fighting boredom,” Tripi admitted. Each email has to be “new, fresh, specific.”

Tripi advises brands to break 50% of the rules. But what does he mean by breaking the rules?

That’s more of a creative imperative. One email pro was ragging him about “ugly” PCH emails. “I showed him the stats,” Tripi laughed. “Ugly isn’t always bad.”