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Lead scoring and GDPR consent

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3 comments

  • David Fowler
    Good question, 
    A lead score can only be generated if a user has provided their email address and is on a beaconed web bowser. The challenge becomes if you have data that has not been consented and is being tracked after GDPR is implemented. You will need to re-permission these records 
    along with disclosures about possible pre existing automated programming as part of your consent obligations. You should make 'affirmative consent' part of your workflow for any subsequent email data building efforts. 
    Thanks 



    ------------------------------
    David Fowler
    Head of Compliance & Deliverability, Act-On Software
    ------------------------------
    -------------------------------------------
    Original Message:
    Sent: 01-19-2018 05:22
    From: Sion Stedman
    Subject: Lead scoring and GDPR consent

    Do GDPR consent requirements present an issue for us in terms of lead scoring?

    Many of us will have in place automated programs that, once contacts reach a certain Act-On score, feed their details to our Sales colleagues. However, if my understanding is correct, Sales would have no authority to approach those people, as they would not have explicitly given their consent to be contacted for marketing/sales purposes. There is no way for a person (or we Act-On users) to know when that person will hit whatever our defined marketing-qualified lead score may be, so there is no possible way for them to give consent.

    Am I overthinking this?

    If not, how does Act-On suggest we ensure we have consent to contact people when the time at which they will be contacted with marketing/sales information is not known?

    ------------------------------
    Sion Stedman
    Idox Software Ltd
    ------------------------------
  • Sion Stedman
    Hi David

    Thanks for coming back on this. I believe we will address the matter in three ways:

    1. By making clear to the individual at the point of sign-up how their information will be used (in this case, by including in the statement they consent to that it will be used 'to help us to deliver, develop and promote our products and services that are relevant to you').
    2. By including in our company Privacy Policy wording on how we use marketing automation​ and scoring to help us provide individuals with information that is relevant to them.
    3. Internally, to set up our automated programs in such a way as to only feed to Sales prospects who have hit their target score within a defined period (in our case, 9 months). That is, we are not going to assume an individual's consent lasts indefinitely – a key principle of data protection. On this basis we can then do regular housekeeping and remove unengaged contacts from our datasets.
    There's another piece slotted into the GDPR jigsaw!

    ------------------------------
    Sion Stedman
    Idox Software Ltd
    ------------------------------
    -------------------------------------------
    Original Message:
    Sent: 01-22-2018 11:22
    From: David Fowler
    Subject: Lead scoring and GDPR consent

    Good question,
    A lead score can only be generated if a user has provided their email address and is on a beaconed web bowser. The challenge becomes if you have data that has not been consented and is being tracked after GDPR is implemented. You will need to re-permission these records
    along with disclosures about possible pre existing automated programming as part of your consent obligations. You should make 'affirmative consent' part of your workflow for any subsequent email data building efforts.
    Thanks



    ------------------------------
    David Fowler
    Head of Compliance & Deliverability, Act-On Software
    ------------------------------

    Original Message:
    Sent: 01-19-2018 05:22
    From: Sion Stedman
    Subject: Lead scoring and GDPR consent

    Do GDPR consent requirements present an issue for us in terms of lead scoring?

    Many of us will have in place automated programs that, once contacts reach a certain Act-On score, feed their details to our Sales colleagues. However, if my understanding is correct, Sales would have no authority to approach those people, as they would not have explicitly given their consent to be contacted for marketing/sales purposes. There is no way for a person (or we Act-On users) to know when that person will hit whatever our defined marketing-qualified lead score may be, so there is no possible way for them to give consent.

    Am I overthinking this?

    If not, how does Act-On suggest we ensure we have consent to contact people when the time at which they will be contacted with marketing/sales information is not known?

    ------------------------------
    Sion Stedman
    Idox Software Ltd
    ------------------------------
  • David Fowler
    Excellent, thanks for the update.

    ------------------------------
    David Fowler
    Head of Compliance & Deliverability, Act-On Software
    ------------------------------
    -------------------------------------------
    Original Message:
    Sent: 01-22-2018 13:24
    From: Sion Stedman
    Subject: Lead scoring and GDPR consent

    Hi David

    Thanks for coming back on this. I believe we will address the matter in three ways:

    1. By making clear to the individual at the point of sign-up how their information will be used (in this case, by including in the statement they consent to that it will be used 'to help us to deliver, develop and promote our products and services that are relevant to you').
    2. By including in our company Privacy Policy wording on how we use marketing automation​ and scoring to help us provide individuals with information that is relevant to them.
    3. Internally, to set up our automated programs in such a way as to only feed to Sales prospects who have hit their target score within a defined period (in our case, 9 months). That is, we are not going to assume an individual's consent lasts indefinitely – a key principle of data protection. On this basis we can then do regular housekeeping and remove unengaged contacts from our datasets.
    There's another piece slotted in to the GDPR jigsaw!

    ------------------------------
    Sion Stedman
    Idox Software Ltd
    ------------------------------

    Original Message:
    Sent: 01-22-2018 11:22
    From: David Fowler
    Subject: Lead scoring and GDPR consent

    Good question,
    A lead score can only be generated if a user has provided their email address and is on a beaconed web bowser. The challenge becomes if you have data that has not been consented and is being tracked after GDPR is implemented. You will need to re-permission these records
    along with disclosures about possible pre existing automated programming as part of your consent obligations. You should make 'affirmative consent' part of your workflow for any subsequent email data building efforts.
    Thanks



    ------------------------------
    David Fowler
    Head of Compliance & Deliverability, Act-On Software

    Original Message:
    Sent: 01-19-2018 05:22
    From: Sion Stedman
    Subject: Lead scoring and GDPR consent

    Do GDPR consent requirements present an issue for us in terms of lead scoring?

    Many of us will have in place automated programs that, once contacts reach a certain Act-On score, feed their details to our Sales colleagues. However, if my understanding is correct, Sales would have no authority to approach those people, as they would not have explicitly given their consent to be contacted for marketing/sales purposes. There is no way for a person (or we Act-On users) to know when that person will hit whatever our defined marketing-qualified lead score may be, so there is no possible way for them to give consent.

    Am I overthinking this?

    If not, how does Act-On suggest we ensure we have consent to contact people when the time at which they will be contacted with marketing/sales information is not known?

    ------------------------------
    Sion Stedman
    Idox Software Ltd
    ------------------------------

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