Commentary

Lead Gen Best Practices Puzzle Almost Complete -- But Still Missing Data-Sharing Piece

While attending the recent OMMA Global Conference in Manhattan, I bumped into a client who asked me about the IAB's online lead generation best practices announced in February 2008. She reminded me that they remained incomplete without addressing the problem of data-sharing -- specifically, the sharing of data with third-party marketing partners for the purpose of sending email. I had posted a comment to this effect on an article appearing in Performance Insider, stating that at the minimum, the IAB should call for a global unsubscribe system for any marketers who are licensing their data to third parties.

Upon returning from New York, I was pleased to hear that the IAB had just announced (Sept.18) Email Data Management Best Practices, but after reading the document, I was somewhat disappointed with what I found regarding data-sharing. Although I am glad the IAB has recommended a global opt-out provision -- requiring marketers who extend the permission they obtain from individuals to third-party marketers to provide a global remove on their Web site and in the emails sent out by their contracted third parties -- I see this as a minimum step. I don't understand why the practice of sharing data itself was not strongly discouraged.

If the IAB Email Data Management is truly a "best practices" document, then the IAB should recommend that marketers follow a simple "opt-in" standard. The sharing of email addresses with multiple marketing companies for the purpose of sending multiple email messages from different senders is simply not a best practice. The IAB needs to revise its definition of permission in the document and remove the part about third-party marketing partners altogether. The definition, found on page 5, should read: "In the context of email marketing, permission refers to an individual's informed consent to receive commercial email. Permission may be extended to a marketer alone." The IAB should then go further and say that the minimum requirement for marketers who are failing to establish permission and participating in data sharing must be to provide a global opt-out.

The signs are everywhere that abuses due to data-sharing are still rampant and the potential for a strong regulatory response from the Federal government still threatens our industry. In May of this year, the Federal Trade Commission released new provisions to strengthen the CAN SPAM Act, putting into law many of the opt-out requirements that the global unsubscribe system the IAB is now recommending would address. It's good for our industry to be in line with these new regulations. Now our challenge is to make sure we stay in front of issues like this -- to be proactive instead of reactive. For good reason, consumers are still very concerned about online privacy issues, as can be seen in the ongoing debate this year regarding behavioral targeting approaches and what's deemed acceptable -- versus consumer perceptions that marketers are spying on them while they're online.

AOL's fourth annual Email Addiction Survey, released late this summer, seems to be all good news for marketers who use email to connect with consumers. Forty-six percent of email users surveyed said that they were addicted to email -- up from just 15% in 2007. Fifty-one percent said they check their email four or more times a day. But other data from the study is not so positive. Twenty-seven percent surveyed said they are so overwhelmed by their email that they've declared "email bankruptcy" -- meaning they're planning to delete all of their email messages to clean out their inboxes and start fresh. Nearly 70 percent surveyed (up from 52% in 2007) said that they use multiple accounts to manage the flood of email.

These findings show that marketers who use email as a component of lead generation campaigns must work harder to ensure their email campaigns are targeted, relevant and mapped directly to consumers' stated preferences. Otherwise, at best, your email campaigns will be consigned to the inactive "dummy" email account, or simply deleted as part of periodic inbox purging of unwanted messages. More damaging is when consumers report your messages as spam. Other industry studies have shown that even consumers who have given you permission to email them will perceive irrelevant email messages as spam. Spam complaints damage your email reputation and ultimately reduce your deliverability rate and the likelihood that your email offers and promotions will ever be opened or read.

As other Performance Insider columns have pointed out, 2008 has indeed been a pivotal year for our industry. We've made great progress in taking these first steps to build our best practices foundation, but it's important to remember that this is just the beginning. It's fine to recognize our achievements, but best practices must evolve, so instead of patting ourselves on the back and declaring victory, it's time for all of us to continue doing everything we can to live up to our own high standards, now and for the future.

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