DLG (t/a Consumer Lifestyles) – complaints about direct marketing
The Direct Marketing Commission had received two complaints against Consumer Lifestyles, a trading name of Data Locator Group (DLG) from consumers who were registered on the Telephone Preference Service. The Commission was asked to consider whether the company was complying with rules regarding calls to those registered with the TPS, whether there were issues in relation to customer service and whether the purpose of the calls was clear.
The Commission’s decisions were based on an analysis of those complaints and a considerable number of other complaints made to the Telephone Preference Service over the period of a year. The Commissioners welcomed DLG’s willingness to share this and other data and their views were informed by the actions taken by DLG to make changes to their marketing practices and processes. It was clear from information from TPS and DLG that these actions had led to a big fall in complaint levels.
This case was important in terms of the volume of complaints recorded by TPS and highlighted issues around consumer consent, the importance of clear and transparent permission methods and the transparency of ongoing contact with consumers. The Commission concluded DLG had made calls based on consents received from online surveys and previous telephone marketing. They saw grounds for mitigation because DLG had made a number of changes in order to reduce TPS complaints. The Commission did, however, conclude there had been two breaches of the Direct Marketing Code. These were in relation to the clarity of their communication when consent is secured on-line and the importance of ensuring that the purpose of a telephone call, as a form of lead generation, is made clear when contact is then made subsequent to the initial consent. These breaches related to clauses 6.17 and 21.9 of the Code. The Commission welcomed the relevant changes now taken by DLG to ensure these issues are addressed.
The Commissioners were grateful for DLG’s willingness to work with the Commission during this investigation, and to undertake a full review of their data journey and how this impacts the consumer. On this basis and in light of the assurances given by DLG the Commission reprimanded DLG and reminded the company of its obligations under the Code of Practice.