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Stephen Almond, Executive Director, Regulatory Risk, who leads the ICO’s team responsible for anticipating, understanding and shaping the impacts of emerging technology and innovation on people and society.
“Last November we wrote to 53 of the UK’s top 100 websites, warning that they faced enforcement action if they did not make changes to advertising cookies to comply with data protection law.
We’ve had an overwhelmingly positive response to our call to action. Of the 53 organisations we contacted, 38 organisations have changed their cookies banners to be compliant and four have committed to reach compliance within the next month.
Several others are working to develop alternative solutions, including contextual advertising and subscription models. We will provide further clarity on how these models can be implemented in compliance with data protection law in the next month.
We expect all websites using advertising cookies or similar technologies to give people a fair choice over whether they consent to the use of such technologies. Where organisations continue to ignore the law, they can expect to face the consequences.
We will not stop with the top 100 websites. We are already preparing to write to the next 100 – and the 100 after that.
To accelerate our efforts we are developing an AI solution to help identify websites using non-compliant cookie banners. We’ll run a ‘hackathon’ event early in 2024 to explore what this AI solution might look like in practice.
Our advice to all organisations is to take action now to become compliant. We can already see the ripple effect of our intervention with many organisations making changes to cookie banners without receiving a letter from us.
And as we’ll be steadily working our way through the list of websites offering services to UK users to give them all the same message, it makes sense to be compliant before the regulator comes knocking.”
Emma Martins has been named as the new Chief Commissioner of the Data & Marketing Commission (DMC) – the independent body that oversees and enforces the Data & Marketing (DMA) Code.
Led by the Chief Commissioner, the DMC investigates and adjudicates on reported breaches of the DMA Code by DMA members. The team of commissioners work to ensure responsible and ethical marketing practices are maintained.
Commenting on her appointment, Emma Martins, the new Chief Commissioner of the DMC said: “Over the past 25 years, I have been a strong advocate of ethical data handling, transparency and accountability, so I am delighted to represent an organisation which embodies these values. I am honoured to lead the DMC into the next stage of its evolution where we continue to work towards becoming an ICO accredited monitoring body, tasked with upholding a GDPR Code of Conduct, which, when approved, will offer more direction to the industry on best practice and resources to support consumer complaints. Ultimately, we are all striving to improve trust in the industry and build a better experience for the customer.”
Emma Martins is an experienced data protection and governance professional, having worked in the regulatory environment for over 25 years. She has been the Data Protection Commissioner at the Office of Data Protection Authority, Bailiwick of Guernsey since 2018. Prior to that, she was Information Commissioner for the Channel Islands between 2012–2018. She was the Data Protection Commissioner of Jersey between 2005–2012.
This appointment comes as Amerdeep Somal steps down as Chief Commissioner after four years with the DMC.
The DMC Board put on record their appreciation of Amerdeep Somal’s achievements, saying “We are incredibly grateful for Amerdeep’s dedication, hard work, and guidance throughout a challenging period for our industry and the UK. It is testament to her expertise and leadership qualities that the DMC has gone from strength to strength. The Board is delighted to welcome Emma Martins as the new Chief Commissioner. Her vast knowledge and experience as a data protection commissioner will be invaluable to the DMC as its remit and responsibilities continue to grow.”
This case looked at concerns raised by a complainant who was in receipt of a number of unwanted emails. The member runs an affiliate network and the affiliate had sent out emails frequently to the complainant promoting different brands. It appeared that only one of the brands involved was connected to the member’s network.
The individual said he did not opt-in to the original data collection point – a prize competition website; that he had attempted to unsubscribe repeatedly using the opt-out/unsubscribe button; and that he was passed from the brand to the member at which point he said he attempted contact with the member on many occasions.
The member informed the Commission that it would be detrimental to their business for the unsubscribe mechanism not to work on their campaigns, and if there were over 2% of unsubscribes then this would result in a campaign pausing. They did accept however that the individual said he had tried to repeatedly opt-out using the unsubscribe button. The Commissioners also noted that the complainant had continued to receive emails even when the member’s client/brand informed him that his details had been removed from the affiliate partner’s database. The Code, rule 1.2 below, references the requirement for members to operate and maintain an in-house suppression file.
The Commission’s investigation also led to findings around the consent mechanism at the data source. These related to GDPR rules around the permission statement from the data supplier to the affiliate and the lengthy privacy notice linked to emails received from the affiliate. Additionally, the Commissioners did not see evidence of a contractual agreement in place with the affiliate. Rules 4.1;4.3;4,6;4.8 below were upheld.
The Commissioners took into account that the member had previously enlisted the help of a compliance consultancy to help them meet GDPR requirements and that in the light of this complaint they had paused their relationship with the affiliate. The Commissioners thought it vital that the member implement changes to ensure all parties associated with its network were compliant to reduce the risk of further complaints. The Commissioners asked for a report in three months’ time which included a template contractual agreement, precise complaint statistics and details of other changes implemented as a result of the Commission’s findings.
Code Rules:
1.2 Member must operate and maintain an in-house suppression file -including the least amount of contact detail to identify consumers who have indicated they do not wish to receive commercial communications via all or particular channels. This includes receivers of third-party communications who have indicated at the first contact that they do not want to receive further communications.
4.1 Members must act decently, fairly and reasonably, fulfilling their contractual obligations at all times.
4.3 Members must accept that in the context of this Code they are normally responsible and accountable for any action (including the content of commercial communications) taken on their behalf by their staff, sales agents, agencies, marketing suppliers, sub processors and others.
4.4 Members acting as an agency or supplier for a non- member’s one-to-one marketing activity must advise the non-member to act within the Code. If the non-member client does not take that advice, the member must insist as a condition of acting for the non-member that the Code is followed in respect of all relevant work.
4.6 Members must maintain adequate records to demonstrate compliance with the Code – and must maintain an adequate system of monitoring and audit.
4.8 Members must at all times give prompt, efficient and courteous service to customers – and must ensure they have in place adequate administrative procedures and resources to achieve this.
“In general, members are aware of the key message – to put the customer first, and we know that
consumers are alert to the fact that their data really matters and they understand the importance of their
privacy.”
Comments by Chief Commissioner, Amerdeep Somal, following the publication of the Data & Marketing Commission’s (DMC) 2022-23 Annual Report.
Full details on the complaints, investigations, and more thoughts from the DMC’s Commissioners are available in the full Annual Report here.
The DMC investigated a complaint from the daughter of an elderly and vulnerable lady who had received a coin she said she did not order. The complainant’s mother had returned the coin to the member but her account was still passed to debt collectors. A number of unsuccessful attempts had been made to contact the member’s customer service by phone and the elderly lady was bewildered and fearful as a result of her account being passed to debt collector agencies.
Correspondence from the complainant highlighted an inadequacy and lack of resource in the member’s customer service process and this was recognised and accepted by the Bradford Exchange which acknowledged that its performance in terms of customer care fell short of fair and reasonable. The member agreed that given the situation, the vulnerable and elderly lady should not have been asked to return the coin, and there should have been an easily accessible phone system in place to take calls of concern about the return process and debt collection issues.
The Board’s investigation identified concerns that an internet led customer service was not always appropriate for those elderly and vulnerable consumers who are not computer literate, and the Board thought that a dedicated returns line or at the very least a process, allowing a consumer to speak to a person to return goods or to make a complaint about the return process, should be easily accessible to those who do not have digital access. Overall, the DMC did not think that the member had taken particular care when dealing with those who were vulnerable and there seemed to be a disparity between clear tracking and audit trails in place around customer sales versus inadequate audit trails around customer care.
The DMC considered that the Bradford Exchange was in breach of the following rules set out in the DMA Code:
2.4 Members must not send goods or provide services for which payment is requested to any consumer without first having received an instruction to supply such goods or services.
Members must not demand that any consumer either pay for or return unsolicited products, except for substitute products.
4.3 Members must accept that in the context of this Code they are normally responsible and accountable for any action (including the content of commercial communications) taken on their behalf by their staff, sales agents, agencies, marketing suppliers, sub processors and others.
4.8 Members must at all times give prompt, efficient and courteous service to customers – and must ensure they have in place adequate administrative procedures and resources to achieve this.
The Board decision was informed by the member’s willingness to implement changes to bring them into compliance and reduce the risk of further complaints and it took into consideration its apology to the complainant when made aware of the issues. The member told the Board that a new customer service platform was to be in place in the Autumn, and whilst this would be internet led, it would, in the member’s view, free up resource for a more readily accessible telephone system for those who do not have digital access.
The DMC Board asked that the member revert back in the Autumn with a full Review and Report – this would help the member and the Board to have more visibility of its processes and identify any ongoing improvements. The Report was to include a full action plan, data journey, training programme, risk assessment and appropriate compliance changes as necessary to any ongoing progress.
Update: The Bradford Exchange provided a report and review. The company have now resigned membership of the DMA.
Data & Marketing Commission announces new Independent Commissioner
Kate Staples has been named as the new Independent Commissioner of the Data & Marketing Commission (DMC) – the industry body that oversees and enforces the DMA Code.
Led by the Chief Commissioner, Amerdeep Somal, the DMC investigates and adjudicates on reported breaches of the DMA Code by members of the Data & Marketing Association (DMA). It is also now in the process of becoming a Monitoring Body for the Information Commissioners’ Office following approval of an industry GDPR Code.
The DMC also has a further extended remit in support of the Advertising Standards Authority (ASA) with complaints by consumers in relation to data and in particular Legitimate Interest and related matters.
The team of Commissioners work to ensure responsible marketing and ethical marketing practices are maintained.
Amerdeep Somal said:
“I am delighted to welcome Kate to the DMC and the wealth of experience she will bring to the Commission will be of huge importance and benefit at this pivotal stage in our evolution, as we become an independent monitoring body.”
DMC’s new Independent Commissioner
Kate Staples, an experienced NED and former General Counsel and Secretary to the Civil Aviation Authority, who is due to start her tenure on 1st March 2023 said:
“I am very pleased to be joining Amerdeep and the team at the DMC. It’s an exciting time for the DMC and DMA and I look forward to making a valuable contribution.”
For further information contact:
Suzi Higman, DMC – suzi.higman@dmcommission.com
“Our industry must use complaint feedback to enhance data privacy learning for SMEs when UK GDPR is reformed”
Comments by Chief Commissioner, Amerdeep Somal, following the publication of the Data & Marketing Commission’s (DMC) 2021-22 Annual Report.
The Data & Marketing Commission’s (DMC) Chief Commissioner, Amerdeep Somal, issues comments about how regulators can help businesses, especially SMEs, when UK data protection laws reform – following the publication of the DMC Annual Report 2021-22.
The DMC’s plans are progressing to become an accredited Monitoring Body for the ICO with an enhanced remit to enforce the Data & Marketing Association’s (DMA UK) Industry Code. It is hoped that this Monitoring Body status will be achieved by early 2023.
“The DMC is working closely with the ICO to help change perceptions of regulators, so we are not just seen as regulation enforcers, but also as free knowledge hubs for businesses and consumers. The DMC believes there is a great opportunity to create industry-wide feedback reports more frequently with additional best practice learnings, to further support the business community through both challenging and uncertain times,” said Amerdeep Somal, Chief Commissioner of the DMC.
The DMC believes the marketing industry must bring education to the forefront and share learnings from investigations to improve industry practices. This will help create an environment where businesses and marketers are encouraged to learn and increase the flow and exchange of information.
“Annual Reports like ours and the ICO’s are a great resource for business learning through their evidence-based reporting and unique industry insights. The reports provide timely insights into industry issues to help businesses learn from common mistakes, helping to prevent expensive legal costs and reduce training fees which can be a huge burden on businesses, especially SMEs. For these reasons, our industry must use complaint feedback more to enhance data privacy learning for SMEs when UK GDPR is reformed.”
Number of complaints against industry declines
In the year ranging from July 2021 to June 2022, overall complaints against the marketing industry declined. Although the DMC reported an increase in the percentage of customer service complaints, rising to 31% (up from 18%). Most of the complaints received still relate to data, privacy, and quality (62%), with contractual (8%) problems making up the remainder. The total number of complaints against non-DMA members declined by 44% this year.
For the second year running, the DMC investigated fewer complaints involving members of the DMA during this period – falling by 25% when compared to the previous year’s total. Member complaints amounted to nearly a quarter of the total number of complaints (24%).
“Not only have complaints against DMA Members continued to decline year-on-year, but we have also observed a sharp decline against non-DMA Members too. This is likely due to growing awareness by organisations about their obligation to their customers to be transparent and respectful. However, with UK data protection laws due to reform soon, businesses must stay vigilant, engaged, and responsible – ready to embrace the reforms with the help of regulators like the DMC,” added Somal.
Organisations that are not members of the DMA, were referred by the DMC to other statutory or self-regulatory bodies.
Full details on the complaints, investigations, and more thoughts from the DMC’s Commissioners are available in the full Annual Report, available here: https://www.dmcommission.com/wp-content/uploads/2022/11/DMC-Annual-Report-2021-22-Final-1.pdf
For further enquiries contact suzi.higman@dmcommission.com
Steve Wood has been named as the new Independent Appeals Commissioner of the Data & Marketing Commission (DMC) – the industry body that oversees and enforces the DMA Code.
When the DMC concludes that a member is in breach of the DMA Code, a member can appeal against the ruling, or any sanctions imposed. The Independent Appeals Commissioner will be expected to consider an appeal when lodged by a member company of the DMA or in future by a signatory organisation to the GDPR Code or by a complainant which has had complaints upheld by the DMC.
Steve, whose tenure will commence on 1st January 2023, is an Independent consultant, researcher & writer who has his own company, PrivacyX Consulting and was former Deputy Commissioner at the Information Commissioner’s Office. He will be replacing the DMC’s long-standing Appeals Commissioner, John Bridgeman CBE TD DL who is retiring this year.
Led by the Chief Commissioner, Ms Amerdeep Somal, the DMC investigates and adjudicates on reported breaches of the DMA Code by members of the Data & Marketing Association (DMA). It is also now in the process of becoming a Monitoring Body for the Information Commissioner’s Office following approval of an industry GDPR Code.
The DMC also has a further extended remit in support of the Advertising Standards Authority (ASA) with complaints by consumers in relation to data and in particular Legitimate Interest and related matters.
Amerdeep Somal stated, “I am delighted to welcome Steve Wood as the new Independent Appeals Commissioner. He brings with him a wealth of knowledge and experience that will be invaluable in his crucial role as the independent Appeal function against decisions made by the DMC. I also sincerely thank John Bridgeman CBE TD DL for his many years of service as the first Independent Appeals Commissioner and I am grateful for his wonderful work legacy.”
For further information contact:
Suzi Higman, DMC – suzi.higman@dmcommission.com
Richard Thompson has been named as the new Independent Complaints Assessor of the Data & Marketing Commission (DMC) – the industry body that oversees and enforces the DMA Code.
The Independent Complaints Assessor can consider complaints about the standard of service provided by the DMC. This covers the practical handling of a case – but not disagreements about its outcome. There is a separate service for appealing case rulings and sanctions.
Richard is an Executive Director responsible for leading strategic approach and operational delivery of high-volume casework, quality assurance and customer excellence. He is an accredited commercial mediator with 25 years’ experience in regulation, complaint handling and dispute resolution. His tenure will commence on 1st January 2023.
Led by the Chief Commissioner, Amerdeep Somal, the DMC investigates and adjudicates on reported breaches of the DMA Code by members of the Data & Marketing Association (DMA). It is also now in the process of becoming a Monitoring Body for the Information Commissioner’s Office following approval of an industry GDPR Code.
The DMC also has a further extended remit in support of the Advertising Standards Authority (ASA) with complaints by consumers in relation to data and in particular Legitimate Interest and related matters.
Amerdeep Somal stated, “I am delighted to welcome Richard Thompson as the first Independent Complaints Assessor to the DMC. He will bring a wealth of experience, knowledge and challenge to the DMC.”
For further information contact:
Suzi Higman, DMC – suzi.higman@dmcommission.com
Location: London
Approximately 7-10 days p/a
Salary: £5,250 p/a plus reasonable expenses
Closing Date: 1st December 2022
The Data & Marketing Commission (DMC) is the body which oversees and enforces the Data & Marketing Association (DMA)’s Code. The Code and DMC are there to give effective protection to recipients, users and practitioners of the data driven marketing sector. It aims to ensure companies observe the highest standards of integrity and trade fairly with their customers and with each other. This is achieved by investigating complaints and identifying trends in data driven marketing that might raise issues for consumers and the sector. The DMA are looking to appoint a new Independent Commissioner as the current incumbent’s term is due to expire. The term would be for three years, renewable once.
Historically the DMC has adjudicated against complaints about DMA members only but it is now in the process of becoming a Monitoring Body for the Information Commissioners’ Office following approval of an industry GDPR Code of Conduct. The DMC also has a further extended remit in support of the Advertising Standards Authority (ASA) with complaints by consumers in relation to data and in particular Legitimate Interest and related matters.
The Independent Commissioner will need to have experience in a senior strategic role within regulation or governance, and to have a broad understanding of regulatory principles, process and practice. As a key player in the ongoing development of the new DMC as a Monitoring Body, the Independent Commissioner will need to show demonstrable experience of strategy development, strategic planning, risk and high-performance management, with the ability to scrutinise and monitor at a senior level. It would be desirable for the candidate to have experience in or have the ability to interrogate annual budgets and the ongoing financial management of the DMC.
Duties
The Independent Commissioner will be expected to attend a minimum of four meetings a year held at the DMA’s offices, attend adjudications, and review and process case and other paperwork relating to these meetings as well as assist in the ongoing development of the new DMC.
The Independent Commissioner will also be expected to represent the DMC at DMA meetings and other events and meetings as required.
Qualities
- Sound judgement and analytical skills
- Ability to digest and make good sense of complex cases
- Able to scrutinise and monitor at a senior level
- Ability to understand the legal context in which an adjudication is required
- Ability to work and debate effectively
- To adjudicate, acting objectively
For a full Job Description and how to apply please email dm@dmcommission.com.
Robert Bond and Gilbert Hill have been named as the two new Industry Commissioners of the Data & Marketing Commission (DMC) – the industry body that oversees and enforces the DMA Code.
Led by the Chief Commissioner, Amerdeep Somal, the DMC investigates and adjudicates on reported breaches of the DMA Code by members of the Data & Marketing Association (DMA). It is also now in the process of becoming an Independent Monitoring Body for the Information Commissioners’ Office following approval of an industry GDPR Code.
The DMC also has a further extended remit in support of the Advertising Standards Authority (ASA) with complaints by consumers in relation to data and in particular Legitimate Interest and related matters.
The team of Commissioners work to ensure responsible marketing and ethical marketing practices are maintained.
Amerdeep Somal stated “I am delighted to welcome Robert and Gilbert to the DMC and the wealth of experience each will bring to the organisation. I would like to thank Fedelma Good and Charles Ping, our Industry Commissioners, who will shortly be leaving us, having served their terms. The insight and wisdom they have brought to the DMC has been of immense importance and benefit.”
DMC’s new Industry Commissioners
Robert Bond, a Solicitor & Notary Public and a Compliance & Ethics Professional who is due to start his tenure on 1st September said:
“I am honoured and delighted to be appointed as an Industry Commissioner. I will do my best to emulate the high standards set by Fedelma Good and Charles Ping.”
Gilbert, a privacy technologist, speaker and entrepreneur, currently Chief Strategy Officer at Pool Data and commencing his tenure on 1st December this year said:
“In a time of unprecedented change and opportunity in our industry, the DMC is a highly respected arbiter of responsible marketing and I look forward to helping expand its influence and remit in the role of Industry Commissioner.”
For further information contact:
Suzi Higman, DMC – suzi.higman@dmcommission.com
Data, privacy and quality continue to lead complaints received by the DMC,
with the number of complaints about non-DMA Members rising and DMA Members falling year-on-year
Issues around data management and privacy were the biggest concerns in 2020/21, according to the Data and Marketing Commission’s (DMC) latest Annual Report. In the year ranging from July 2020 to June 2021, the DMC reported a rise in complaints against businesses across the data and marketing sector – rising by 33% year-on-year (from 63 to 84).
However, the DMC investigated fewer complaints involving members of the Data and Marketing Association (DMA) during this period – falling by 30% when compared to the previous year’s total. Member complaints amounted to a fifth of the total number of complaints (19%). 75% of these were consumer complaints and 25% were about B2B issues.
The majority of complaints relate to data, privacy and quality (64%), with contractual (18%) and customer service (18%) problems making up the remainder.
“Since the introduction of the GDPR, we have seen complaints against DMA Members gradually lessen. A key reason for this is likely down to an increasing awareness by member organisations of their obligation to be transparent, to be clear, to be respectful – subsequently more customers now recognise that their data is valued and protected,” said Amerdeep Somal, Chief Commissioner of the DMC.
The largest proportion of complaints (81%), which involved organisations that are not members of the DMA, were referred by the DMC to other statutory or self-regulatory bodies. However, in some cases, particularly where they involved consumers unable to unsubscribe from unwanted communications, the DMC did reach out to the business to provide a reminder of its legal commitments and request that it unsubscribe the individual.
Somal continues: “Treating customers with empathy, authenticity and giving them a personal experience will impact customer sentiment in a positive way and will encourage the industry to use big data and other technology tools as a force for good. Ultimately, we all must strive to improve trust in the industry and build a better experience for the customer.”
The evolving role of the DMC and industry regulators
In the coming year, the DMC aims to become an ICO accredited Independent Monitoring Body with a clear remit to enforce a new GDPR Industry Code, through the registration of organisations who sign-up to the Code and the investigation of complaints.
A key challenge for regulators this year must be to boost industry knowledge surrounding grey areas of the GDPR – the industry must receive clarity around the use of legitimate interests for marketing. Regulators also continue to receive complaints from consumers post-GDPR about service emails, which should exist to provide key service updates. But there is still confusion about whether a service email is just a masked marketing email.
“As our industry evolves so, too, must the role of regulators like the ICO and DMC. We must bring education to the forefront and share learning from our investigations to improve industry practices. This will help create an environment where businesses and marketers are encouraged to learn and increase the flow and exchange of information,” concluded Somal.
Full details on the complaints, investigations and more thoughts from the DMC’s Commissioners are available in the full Annual Report, available here: https://www.dmcommission.com/wp-content/uploads/2021/12/DMC-Annual-Report-2020-21.pdf
– ENDS –
For further information contact the DMA Press Office:
James Davis, PR Manager
T: 020 7291 3375
About the Data & Marketing Commission
The Data & Marketing Commission (DMC) is the body which oversees and enforces the DMA Code. The Code and DMC are here to give effective protection to recipients, users and practitioners of the data driven marketing sector. We aim to ensure companies observe the highest standards of integrity and trade fairly with their customers and with each other, and we do this by investigating complaints, and scrutinising data driven marketing issues and practices.
The DMC also acts as an expert panel to provide advice to the CAP Executive, the ASA Executive and the ASA Council in cases where “legitimate interests” has been put forward as a basis for processing personal data for the purpose of producing and/or distributing a marketing communication, and related matters. The DMC operates under a publicly available memorandum of understanding with CAP.
About the Data & Marketing Association
The DMA is the UK trade association for the data and marketing industry led by customer-first principles and a Code of ethics. The DMA has over 1,000 member organisations across the UK and almost a century of experience pioneering approaches in industry. Through the IDM, it continues to drive for marketing excellence through development and learning opportunities. DMA Talent’s range of initiatives is inspiring the next generation into the data and marketing industry to help meet the needs of today and tomorrow.
The DMA offers access to industry-leading events, the latest insight, advocacy, legal support and guidance. It anticipates and campaigns for the needs of the data and marketing industry through its close relationship with government and regulators. From the classroom to the boardroom, the DMA is driving the force of intelligent marketing, moving the data and marketing industry forward – for the good of marketers, businesses and most importantly, customers.
Issues around data management and privacy are the biggest concerns in 2019/20, according to the Data and Marketing Commission’s (DMC) latest Annual Report. In the year ranging from July 2019 to June 2020, the DMC reported a marked reduction in complaints against businesses in the data and marketing sector – from over 130 in 2018/19 to just 63 in the last year.
The DMC investigated 23 complaints involving members of the Data and Marketing Association (DMA), 15 of which were consumer complaints and 8 were about B2B issues. The majority of these issues relate to data, privacy and quality (62.5%), with contractual (25%) and customer service (12.5%) problems making up the remainder.
The remaining 40 objections involved organisations that are not members of the DMA and so were referred by the DMC to other statutory or self-regulatory bodies. However, in some cases, particularly where they involved consumers unable to unsubscribe from unwanted communications, the DMC did reach out to the business to provide a reminder of its legal commitments and request that it unsubscribe the individual.
“Understanding how customers think and feel, and what drives their behaviours, is key to customer management and to maximising loyalty. Underlying all the complaints that we see is the standard and quality of an organisation’s customer service,” said Amerdeep Somal, Chief Commissioner of the DMC. “How does a business capture the right information to get to the heart of what matters to a customer, then act on this information to improve customer experience? This will be more important than ever during these challenging times, the pandemic and post Brexit.”
Over the past year, the DMC Board decided it was necessary to conduct one formal investigation into a business. The case involved complaints from two businesses that paid for a service they felt had not been adequately delivered. The DMC Commissioners did not think that the DMA Member had complied with any of the DMA Code’s key principles. Following further failures to engage with the clients or the investigation, the DMC recommended considering the removal of the company from membership, a sanction that the DMA Board approved and imposed.
Somal continues: “The impact the pandemic has had on our society cannot be underestimated and we all have a crucial part to play in weathering the storm. More important still is the change that is required within the industry itself to ensure it retains, and in some cases regains customer support. That means keeping front of mind the lessons of the lockdown that the success of the industry is founded on customer support, which should never be abused or taken for granted.”
On 16 September 2020, we said goodbye to Matti Alderson, former Chair of the Direct Marketing Authority (before she launched the Direct Marketing Commission) and former Director General of the Advertising Standards Authority (ASA), but we have not lost her legacy, described as “an unrelenting focus on making sure that all UK ads are legal, decent, honest, and truthful.”
A passionate advocate of self-regulation, Matti was a committed leader of the UK ad watchdog, which has credited her as a “driving force” in raising its profile. In 1974, Matti joined the ASA as a case officer and became Director General in 1990, spending ten years in the role, in which she particularly focussed on regulating tobacco advertising.
During her tenure, Matti also helped co-found the European Advertising Standards Alliance (EASA), the organisation that coordinates advertising work of self-regulatory bodies across Europe. She became Vice Chair in 1997, the same year Matti joined other industry figures at the European Parliament to give a powerful presentation on the portrayal of women in advertising.
When Matti left the ASA in 2000, its annual report praised her contributions.
She went on to become Managing Director of FireHorses, which providedadvice on regulatory policy and strategy to clients in the public and private sectors, and lead the Direct Marketing Authority (now the Direct Marketing Commission). She expanded the DMC’s role and influence, developed the responsibilities of its directorate, and strengthened relationships with the industry and consumers.
Charles Ping, former DMA Chairman and currently Industry Commissioner on the DMC, said:
“I was lucky enough to work with Matti as DMA Chair when she started her tenure at the DMC.
Matti arrived at the Direct Marketing Commission with a fully rounded understanding of how a regulator works, and what makes the difference between a regulatory environment that supports good business and one that doesn’t. Her view was robust, questioning and always centred in a fair view of how regulation should work.
From her time at the ASA, she instinctively understood that clarity and consistency were key, as well as the ability to clearly articulate the logic behind decisions. It was a challenge within a regulator who had a remit to regulate the code of a body, not an all-encompassing industry wide endeavour, and this made for an interesting journey over the years.
Matti’s commitment to the DMC was clear and she will be remembered by me, and those with whom she worked, as a professional committed to improving the standards of industry through better regulation.”
The obituary from The Times stated that Martha (Matti) Hallyburton Connolly was born on 20 December 1951 in Alexandria, West Dunbartonshire, the daughter of Edward, a captain in the Merchant Navy, and Helen, a nurse. She lived in London with her husband Alan Alderson, IT Director for the Bauer Media Group.
“The couple did not have children, but welcomed young people into their home every year from the former Soviet regions affected by the Chernobyl disaster. They never formally adopted but supported one Belarusian boy from the age of 11 through school and university. He later changed his name to Alex Alderson and called the couple mum and dad.”
Matti died peacefully of undisclosed causes at the age of 68.
The DMA and DMC expresses their deepest condolences to Matti’s family, and the many colleagues and friends she left behind within the ad industry and beyond.
Amerdeep Somal confirmed as new Chief Commissioner of the Data & Marketing Commission
07 May 2020 – Amerdeep Somal has been named as the new Chief Commissioner of the Data & Marketing Commission (DMC) – the industry body that oversees and enforces the DMA Code.
Led by the Chief Commissioner, the DMC investigates and adjudicates on reported breaches of the DMA Code by members of the Data & Marketing Association (DMA). The team of commissioners work to ensure responsible marketing and ethical marketing practices are maintained.
“I am honoured to be appointed as the new Chief Commissioner. Over the past 25 years, I have remained committed to serving organisations where independence, public interest and trust are placed front and centre of all practices,” said Amerdeep Somal, Chief Commissioner of the DMC. “Responsible marketing, transparency and ethics are key drivers for building consumer trust in the data and marketing industry – the DMC will continue to promote and enforce these values across the DMA’s membership. I am privileged to lead the DMC into the next stage of its evolution.”
Somal brings 25 years’ senior executive and non-executive experience to the position, previously operating within a series of high-profile stakeholder roles across a variety of sectors.
Previous roles include founding Commissioner and Board Member at the Independent Police Complaints Commission. She is presently Independent Assessor of the Financial Ombudsman Service, She will also continue to hold her positions as a Judge at the Ministry of Justice UK, Council Member of the General Medical Council and Board Trustee at Refuge.
Somal’s appointment comes as George Kidd comes to the end of his term, after 12 years with the DMC – first as an independent member of the DMC Board and then selected as Chief Commissioner in 2010.
“I’d like to personally thank George for his leadership, expertise and commitment to the DMC throughout his long tenure. He has been a truly remarkable ambassador to our industry,” added Stephen Maher, Chair of the Data & Marketing Association Board. “I am also delighted to welcome Amerdeep as the new Chief Commissioner. Her wealth of experience and invaluable knowledge of regulatory and judiciary practices will help drive the DMC forward into a new era.”
“We are pleased to share our latest Annual Report of the Data & Marketing Commission. If there is a message running through the report it is one of partnership: partnership with the DMA as the author of the Code and partnership with fellow regulators of data, privacy and marketing practice. This becomes ever more important as technology enables amazing innovation that goes beyond the understanding people have of how information about them is collected, built on and interpreted when offers are then put before them.”
Please see here for a copy of the 2018-19 Annual Report
George Kidd, Chief Commissioner
The DMC investigated complaints from two businesses who had ordered a door drop delivery. Neither complainants were satisfied that the deliveries had been carried out adequately and they had both described their relationship with the member as strongly lacking in terms of engagement, responses and assurance that their leaflets had been delivered.
In the materials provided by the complainants, the DMC could not find any evidence to show that Postra Communications had been clear and transparent with its two clients. It appeared that the clients had made multiple attempts to make contact so that they could be assured their deliveries were to be carried out as agreed and ordered. The material seen clearly indicated a reluctance or inability to share information on delivery schedules or evidence of completed deliveries. In the absence of any meaningful responses to the DMC or the clients on the matters raised it seemed appropriate to conclude Postra misled customers over performance under the contracts in question and that the deliveries were not adequately fulfilled.
The DMC did not think that Postra had complied with any of the key principles which asks members to value their customers, to act in accordance with their expectations, to be honest, fair and transparent and to act responsibly at all times. The DMC considered that Postra was in breach of the following rules set out in the DMA Code because it did not give the DMC any reason to believe that it had adhered to them.
2.1 Companies must not mislead customers; companies must be clear, open and transparent.
4.1 Members must act decently, fairly and reasonably, fulfilling their contractual obligations at all times.
4.6 Members must maintain adequate records to demonstrate compliance with the Code – and must maintain an adequate system of monitoring and audit.
4.8 Members must at all times give prompt, efficient and courteous service to customers – and must ensure they have in place adequate administrative procedures and resources to achieve this.
The lack of engagement and responses to Postra’s two clients was also mirrored in its lack of engagement with the DMC process. The DMC did not think Postra had co-operated fully with its investigations or enquiries and had ignored frequent approaches. The DMC found a breach of rule 4.9 in the DMA Code which states:
Members must accept the jurisdiction of the Data & Marketing Commission (DMC) and co-operate fully with their investigations or enquiries. Members must comply with any conclusion reached by the DMC, including any decision to take disciplinary action resulting from a breach of the Code.
The DMC reached the view that Postra had shown itself unconcerned by a failure to meet contractual commitments, with failures thereafter to engage with clients or in any meaningful way with the DMC. Commissioners saw nothing to show the company was committed to complying with the DMA Code and the DMA principles.
The DMC would recommend to the DMA Board that it considers removing Postra from membership of the Association.
The DMA Board approved and the member has now been removed from membership.
The ICO has published its long-awaited draft of the direct marketing code of practice and invited comments from professionals across the industry.
It is a critical document for the data and marketing industry because its elevated status as a code of practice, as opposed to guidance, will give it statutory status. Meaning that it will effectively become the legal rulebook for the sector.
The code consolidates previous GDPR guidance, PECR and cookie advice, and focusses solely on direct marketing – defined by the ICO as essentially one-to-one marketing.
The code has really benefitted from the experience and knowledge that the ICO have gathered since May 2018, in terms of frequently asked questions (FAQs) by organisations and case studies.
The ICO have included relatable, straightforward subject matter and examples that clearly make use of their learnings from previous industry engagement that help clarify grey areas and common mistakes made.
Their understanding of the data and marketing industry has expanded and been brought in line with modern technological advancements and regulatory changes.
There is plenty of useful preamble and scene setting – defining terms i.e. ‘direct marketing’ and ‘service messages’ etc. It also specifically mentions the DMA Code as a point of reference for marketing best practice.
It is aimed at “anyone that processes personal data for direct marketing. purposes”.
Key takeaways and chapter summaries
The code does not address each marketing channel or type of processing separately, as was the case with its predecessor.
Instead it takes a “lifecycle approach” with the main chapters including:
Planning
Generating and collecting data
Profiling
Sending messages
There are also chapters on online advertising, selling and sharing data, and individual rights.
In addition, the code includes sections on marketing in mobile apps, in game advertising, TV advertising, and location-based marketing etc.
It also addresses the impact on different sectors, such as charity and B2B, where the rules are applied slightly differently.
In the planning chapter, there is a lot of focus on getting things right from the start by talking about data protection by design and the benefits of doing data protection impact assessments (DPIA) and conducting appropriate due diligence.
As well as how to understand the correct legal basis to use and the data controller to processor relationship.
Well established marketing practices are clearly explained and there are no huge issues or concerns in the interpretation of the law.
Although some of the finer details may come as a surprise to some i.e. Data appending is considered unfair processing, hosted email campaigns breach PECR, as do ‘Refer a Friend’ promotional campaigns.
Article 14 of GDPR says that if you obtain personal data from somewhere other than directly from the data subject, you are obliged to provide privacy information to that person within a month.
For companies that collect data from such sources as Companies House, Edited Electoral Roll or third-party data providers, this could have a major impact.
There is also a section on sharing data and switching legal basis that appears to be written because the ICO have seen this in practice and want to address it.
There are outstanding compliance questions regarding digital advertising and naturally these are not resolved by this code.
The online advertising and new technologies section has a focus on the need for transparency and the benefits of conducting a DPIA. It also summarises the relevant cookie requirements.
For those that use social media, the code makes it clear that social audiences and ‘lookalike’ audiences require consent.
Also, as a joint controller, the marketer needs to undertake due diligence on the social media platform to ensure that the data being used has valid consent.
Additionally, the code also states that in-app marketing will now need consent by the user, which could significantly impact the market for free apps in the future.
Next steps
The code will be circulated for consultation until 4 March 2020 and the final version is expected to be published later this year.
John Mitchison
Data & Marketing Association
Director of Policy and Compliance
The Data & Marketing Commission has had complaints relating to direct mail and telephone marketing where the activity was based on a Legitimate Interest rationale. This is permissible under ICO guidance and the DMA and others have also issued guidance. The complaints received prompted an assessment of the practices seen in terms of the DMA Code, looking in particular at the timeframes in which data might be used and what might be considered ‘fair and reasonable’; a key Code provision. The assessment did not result in any formal adjudications but we will use this set of conclusions in considering any future complaints:
- Direct Marketing, in particular for post and telephony, will often be practiced under the grounds of Legitimate Interest as is provided for in law and supporting guidance.
- The DMC believes the reasoning behind a wholly consistent approach to timeframes for use of data irrespective of the basis on which it is used, is sound and unexceptional.
- In the light of some evidence seen the DMC believes there is a need to address parameters for the use of data for marketing purposes. It believes this will be valuable to businesses wishing to use Legitimate Interests and, therefore, required to carry out a Balancing Test.
- Whilst the DMA guidance on the minimum standards of the lifetime of consent was levered towards the grounds for Consent, the DMC intends to use the same guidance applied to the grounds for Legitimate Interest for both third party and first party processing activity.
- This means the DMC intends to use the six and 24 month standard set out in DMA guidance for the valid use of Consent* (see below) to market to apply equally to marketing based on Legitimate Interests.
- These time periods are for guidance and it will be up to individual users of data to consider, justify and record any applicable valid reasons for extending the time period. These could include an annualised product purchase cycle, such as in travel, insurance or utilities.
- When considering data used under a legitimate interest purpose that is coming to the end of a valid lifetime period, the new legitimate interest assessment should treat the time since the original personal data point was captured as a key factor in the assessment.
- Building on this move to alignment over the timeframes for marketing based on Consent or a Legitimate Interest the DMC thinks it is right that there should be broad consistency in relation to how data subjects can exercise a right to opt-out of marketing.
- The DMC believes marketing activity based on Legitimate Interest should make clear how people can ask to stop the unwanted mailings. That explanation should be prominent and the process should be as simple to use as possible. Wherever possible the DMC would expect a request to be removed for marketing lists operated under the Legitimate Interest rationale i.e. it should go to the entity providing this data to third parties. That is to say the consumer should not have to make repeated opt-out requests to individual marketeers. Their wish should be actioned by the originator of the data.
DMA guidance on consent timescales *
The DMA advises its members to adhere to these minimum standards on the lifetime of consent:
- For third-party data: telephone, email, SMS; the maximum time that consent can remain valid is six months after initial collection or any other positive contact
- For third-party postal marketing: the maximum time consent can remain valid is 24 months after initial collection or any other positive contact
- For all first-party data: telephone, email, SMS and post; the maximum time that consent can remain valid is 24 months after initial collection or any other positive contact
The timeframes run from either the initial collection or further positive contact with the customer.
The DMC is seeking a Independent Commissioner. Please see details below. Applications to dm@dmcommission.com.
Independent Commissioner
Location: London
Approximately 7-10 days pa.
Competitive Salary: plus reasonable expenses
Closing Date end 2019
The Direct Marketing Commission (DMC) is the body which oversees and enforces the Data & Marketing Association (DMA)’s Code. The Code and DMC are there to give effective protection to recipients, users and practitioners of the data driven marketing sector. It aims to ensure companies observe the highest standards of integrity and trade fairly with their customers and with each other. This is achieved by investigating complaints and identifying trends in data driven marketing that might raise issues for consumers and the sector. The DMA are looking to appoint a new Independent Commissioner as the current incumbent’s term is due to expire. The term would be for three years, renewable once.
Historically the DMC has adjudicated against complaints about DMA members but will have an extended remit in support of the Advertising Standards Authority (ASA) with complaints by consumers in relation to data and in particular Legitimate Interest and related matters.
The Independent Commissioner will need to have experience in a senior strategic role within regulation or governance, and to have a broad understanding of regulatory principles, process and practice, and ideally have a legal background.
Duties
The Independent Commissioner will be expected to attend a minimum of four meetings a year held at the DMA’s offices, attend adjudications, and review and process case and other paperwork relating to these meetings.
The Independent Commissioner will also be expected to represent the DMC at DMA meetings and other events and meetings as required.
Qualities
- Sound judgement and analytical skills
- Ability to digest and make good sense of complex cases
- Ability to understand the legal context in which an adjudication is required
- Ability to work and debate effectively
- To adjudicate, acting objectively
A full Job Description is available on request.
The DMC is seeking a Chief Commissioner. Please see details below. Applications to dm@dmcommission.com.
Chief Commissioner
Location: London
Approximately 20-25 days pa.
Competitive Salary: plus reasonable expenses
Closing Date end 2019
The Direct Marketing Commission (DMC) is the body which oversees and enforces the Data & Marketing Association (DMA)’s Code. The Code and DMC are there to give effective protection to recipients, users and practitioners of the data driven marketing sector. It aims to ensure companies observe the highest standards of integrity and trade fairly with their customers and with each other. This is achieved by investigating complaints and identifying trends in data driven marketing that might raise issues for consumers and the sector. The DMA are looking to appoint a new Chief Commissioner as the current incumbent’s term is due to expire. A handover process of six months is envisaged. The term would be for an initial period of three years but this is renewable.
Historically the DMC has adjudicated against complaints about DMA members but will have an extended remit in support of the Advertising Standards Authority (ASA) with complaints by consumers in relation to data and in particular Legitimate Interest and related matters.
The Chief Commissioner must be entirely independent of the data driven marketing industry and should have a genuine independence of mind and approach. The Chief Commissioner will be expected to feedback to the DMA Board and Executive, to act as the public face of the DMC and deal with all stakeholder relations and to ensure that the affairs of the DMC, as a registered company are properly conducted.
Duties:
The Chief Commissioner will be expected to chair a minimum of four meetings a year held at the DMA’s offices, as well as attend any adjudications or other meetings as necessary. The Chief Commissioner will read papers as needed on complaint resolution and be familiar with general issues of the data driven marketing industry of relevance to self-regulation.
In addition to formal meetings of the Commission throughout the year, the Chief Commissioner will work closely with the Commission’s Secretariat on complaints to be processed through informal resolution as well as on day to day issues of relevance to the Commission.
Qualities and responsibilities required are:
- Sound leadership skills, strategic vision and industry credibility
- Judgement and analysis of complex material
- Independence
- Experience and knowledge
- Communication and listening skills
- Social skills
- Media literacy
- Awareness and experience of regulation
- Time commitment
- Due process and natural justice
A full Job Description is available on request.
DM Commission investigation into Fulcio Marketing identifies several breaches to the DMA Code
9 May 2019 – Fulcio Marketing, a business-to-business direct marketing company, has had their DMA membership revoked. The Direct Marketing Commission (DMC), an independent body that oversees and enforces the DMA Code to which all DMA members must comply, launched a full investigation after receiving a number of complaints.
The DMC’s investigation identified several serious breaches relating to the absence of contracts and supply agreements, unsubstantiated responses (to both complainants and the DMC), and lack of evidence to the DMC of due diligence done by Fulcio in relation to the data it sourced and supplied. Complaints also made reference to poor customer service and unprofessional conduct.
The DMC concluded that Fulcio Marketing was in breach of a number of Code provisions and was not working to the customer first principles expected of DMA members. In response to the investigation’s conclusive evidence and the DMC’s recommendation, the DMA’s Board of directors took prompt action to revoke Fulcio Marketing’s membership.
Rachel Aldighieri, MD, DMA, said: “The DMA Code is an agreement undertaken by all DMA members upon joining the association. It demands that members put the needs of their customers first and be accountable for their actions. The data and marketing industry is on a positive trajectory and it is essential to the future of our industry that organisations adhere to the high standards set out by the DMA Code. It is never an easy decision to remove a member, but the integrity of the industry and customers’ best interests will always take precedence.”
George Kidd, Chief Commissioner of the DM Commission, added: “Consumers and businesses need to know they are dealing with organisations that are transparent, honest, efficient and professional, but also responsive if things go wrong. Complaints about Fulcio Marketing listed concerns over poor customer service, an absence of clear terms & conditions to underpin customer orders, and misleading information contained on Fulcio’s marketing material. This was followed by repeated failures to deal with legitimate queries and customer complaints.”
Fulcio Marketing (Rodgerson Black) – complaints about direct marketing
George Kidd, Chief Commissioner:
We are pleased to confirm the DMC will be supporting the ASA in relation to complaints relating to data use and particularly any issues around the legitimate interest grounds that can be referenced under GDPR. The DMC has years of experience in dealing with issues of data supply chains and the consents or other grounds that will give them the possibility of consulting the DMC as an advisory panel. This strengthens the self-regulatory arrangements that complement the ICO by helping address consumer concerns quickly and ensure high compliance.
https://www.asa.org.uk/transparency/who-we-are-and-what-we-do.html
(Information on the partnership under Organisations with Whom We Work in Partnership)
This investigation centred on five complaints received against Fulcio Marketing, a Business to Business direct marketing company. The complainants raised alleged failures to supply data in conformity with orders; misleading actions in supplying education sector data that proved to be sourced by a Freedom of Information request; claims for repeat annual payments for data that was not seen to be sold on that basis; a failure to respect previous requests not to be contacted and a failure to meet a subject access request.
The DMC had identified a number of themes that recurred. These related to the absence of contracts and supply agreements and the absence of any documented mechanic for resolving disputes. There were unsubstantiated responses (to both complainants and the DMC), and little to no evidence to the DMC of due diligence done by Fulcio in relation to the data sourced and supplied. There was no evidence to demonstrate processes that could adequately ensure contract fulfilment. Most complaints also made reference to poor customer service and unprofessional conduct.
Online and in marketing correspondence the company made repeated and pointed reference to its DMA membership and the assurance this should give in terms of the quality of data provided. In correspondence the company made reference to supplying data to the ‘corporate level standard of the DMA’. No such standard exists. A review found the Fulcio website also lacked essential links, including to its terms and conditions and privacy policy. This situation was unchanged during the course of the investigation.
The DMC was concerned over the failure generally of Fulcio to respond fully and in a timely manner to questions raised during the investigation. It was concerned also over the extent to which the company seemed to pursue and secure business based on the promotion of its credentials as a DMA member. In finding Fulcio in breach of a number of Code provisions the DMC reached the conclusion that its failures could be thought to bring the DMA into disrepute.
Having reached decisions on the Code rules breached (see below) and taken a view on the seriousness or harm, the DMC proceeded to consider the most appropriate sanction or action. It examined the extent to which the trends of concern had existed over a more extensive period of time. It found issues around data accuracy, customer service and the absence of evidence of robust processes was evident in a further eleven previous complaints made against the business over the last four years. Generally these complaints had been treated under informal case procedures and resolved based on undertakings to comply.
The DMC reached the view that Fulcio Marketing was not committed to complying with the DMA Code and its principles and would recommend that the DMA remove it from membership of the Association.
1.2 Members must operate and maintain an in-house suppression file – listing the names and contact details of consumers who have indicated they do not wish to receive commercial communications via all or particular means of communication.
3.1 Members must follow all legislation relating to the processing of data, including the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003.
4.1 Members must act decently, fairly and reasonably, fulfilling their contractual obligations at all times.
4.2 Members must ensure they do nothing that could bring into disrepute the public image of one-to-one marketing or the DMA.
4.6 Members must maintain adequate records to demonstrate compliance with the code – and must maintain an adequate system of monitoring and audit.
4.8 Members must at all times give prompt, efficient and courteous service to customers – and must ensure they have in place adequate administrative procedures and resources to achieve this.
4.9 Members must accept the jurisdiction of the Direct Marketing Commission (DMC) and co-operate fully with their investigations or enquiries.
Data, privacy and quality of data continue to lead consumer complaints,
according to the latest DM Commission report
Issues around data, privacy and its accuracy are the biggest concerns for consumers in 2018, according to the DM Commission’s Annual Report. In a year that saw the introduction of the General Data Protection Regulations (GDPR) coming into force, the DM Commission reported a marked reduction in complaints to the Commission against businesses in the direct marketing sector – from over 200 in 2017 to just over 100 this year.
The Commission investigated 27 cases involving members of the DMA in 2018. Of these, 83% related to data, privacy and quality (up from 69% last year), with the remaining complaints split between customer service (14%) and contractual (3%) issues. The Commission referred 76 complaints against non-member organisations to other relevant statutory or self-regulatory bodies, but also reached out to the businesses involved to inform them of the complaints, remind them of their legal and regulatory duties and ask them to address the consumers’ concerns.
Over the course of the year, the Commission Board decided it was necessary to conduct formal investigations into two businesses, finding one in breach of the DMA Code. Both of these cases were looked at against the DMA Code and the guidance in place at the time of the incidents reported, so prior to the onset of GDPR in May.
George Kidd, Chief Commissioner of the DM Commission, said: “This has been quite a year for anyone and everyone involved in the marketing data lifecycle. The GDPR has put direct marketing in the spotlight as never before. The question now is ‘Has this made a difference?’ My sense is for most yes and for some no. Today most businesses understand the importance of their customer relationships and are conscious of the impact on their brands of not abiding by the new laws.”
Kidd continues: “Sadly, there is still a dreadful minority whose whole purpose in life seems to be to ‘spam and scam’, who misrepresent themselves, mislead those they target and have no regard for the law, except perhaps if the changes really do expose them to tougher action. The GDPR should give state regulators the power to focus on those organisations that spam and scam by intent.”
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