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GDPR consent and lead scoring

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2 comments

  • Sarah Daily
    Thanks for bringing this up, Sion.

    In addition to this question, I'm curious how we would provide this type of information to our subscribers if they requested it. According to my understanding of GDPR, all information (including indirect information like a lead score) must be provided upon request.

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    Sarah Daily
    Digital Marketing Manager, The Enrollment Management Association
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    Original Message:
    Sent: 01-19-2018 05:26
    From: Sion Stedman
    Subject: GDPR consent and lead scoring

    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?

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    Sion Stedman
    Idox Software Ltd
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  • Sion Stedman
    Hi Sarah

    Thanks for coming back on this. I believe my company will address the issue I raised 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.
    Regarding giving a person details of their Act-On score: in the interests of transparency, I don't see any reason not to include this, whenever it is that a person makes a Data Subject Request. However, Act-On have not yet said how Data Subject Requests and 'right to be forgotten' will be handled in the software. Perhaps @david fowler has a further update to this post?

    If you are not already following it, Act-On's dedicated GDPR Hub can be found here.

    Personally, I have also found the DMA's GDPR page here very useful – particularly in terms of progress on the passage of other European digital marketing legislation. Which is only as thrilling as one makes it!


    ------------------------------
    Sion Stedman
    Idox Software Ltd
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    -------------------------------------------
    Original Message:
    Sent: 01-22-2018 10:56
    From: Sarah Daily
    Subject: GDPR consent and lead scoring

    Thanks for bringing this up, Sion.

    In addition to this question, I'm curious how we would provide this type of information to our subscribers if they requested it. According to my understanding of GDPR, all information (including indirect information like a lead score) must be provided upon request.

    ------------------------------
    Sarah Daily
    Digital Marketing Manager, The Enrollment Management Association
    ------------------------------

    Original Message:
    Sent: 01-19-2018 05:26
    From: Sion Stedman
    Subject: GDPR consent and lead scoring

    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
    ------------------------------
    0
    Comment actions Permalink

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