GDPR requires data quality
November 24, 2017

GDPR requires data quality, sharing survey results in the home of hampers

By Paul Laughlin

Amidst all the focus on GDPR, it’s easy to forget that GDPR requires data quality. Over a Fortnum & Mason’s breakfast, I had the chance to discuss this neglected aspect.

So much of the social media buzz around GDPR focusses on contentious topics like when you need opt-in consent. Individuals rights to opt out of profiling, be forgotten & Privacy by Design, all these GDPR topics have had their limelight.

But, ironically, in all this talk of data regulation, there is a risk that data quality is being overlooked.

Because of that risk, I’ve been delighted to partner with MyCustomer & Royal Mail Data Services (RMDS), at breakfast briefings. Over the last four years, RMDS has been surveying around 300 marketing leaders across sectors within the UK.

The results give an interesting insight into their goals, challenges and the role data plays.

‘Our survey said’, here are my highlights

With an aligned concern to raise the profile of data quality & interesting survey results to debrief, there was plenty of content. This is the second year we have joined forces for a series of breakfast briefings. Our venue this month, was the prestigious drawing room of Fortnum & Mason. Very nice.

Concerns around GDPR still pull in the crowds, so it was good to have full tables of diners join us for these events.

You can download the full version of the latest RMDS sponsored survey here (complete with graphs).

During our breakfast briefing, I highlighted a few of the interesting survey responses, from marketers:

  1. Most marketers number one challenge is finding & acquiring new customers (42%), with only 16% prioritising retaining customers. This is more concerning, when you discover the average customer churn rate is over 20%. Worse still, over 10% over marketers don’t know their churn rate – are you just pouring more into a ‘leaky bucket’?
  2. When asked which factors most impacted marketing performance (from a long list of candidates), the top answer was data quality. Not surprisingly, the quality of contact data has a huge impact on response & conversion rates. The next 3 factors all related to targeting direct marketing (segmentation & targeting, personalisation & timing). So, as all analysts know, data quality also has huge impact on the effectiveness of these models.
  3. With less than 6 months to go until GDPR enforcement, it’s not surprising that non-compliance has risen to no.1 concern. Of the other top ‘data management challenges’ cited by marketers, the next 3 are frequently cited. The issues of legacy systems, poor data quality and sourcing responsive data, all challenge most marketers in corporate life.
  4. For many marketers, one response to impending GDPR regime, is to re-permission customers or at least prospects. As we’ve stated in previous posts, it’s worth also considering other bases for holding personal data. But for those who have identified their need to re-permission, less than 50% have yet implemented their campaign. Beware being lost, in the coming tsunami of re-permissioning requests, that results in consumer fatigue/inaction.
  5. Even more worryingly, over 50% of those surveyed are at best ‘neutral’ in their confidence about being compliant by May. I recommend looking at the wealth of resources available and starting with the 6 step plan I recommended to accountants.
  6. An understandable retrenchment has happened, in planned use of 3rd party data. Given the responsiblity of data controllers to know the provenance of data & consent, many choose to only trust internal data. 42% of marketers surveyed, stated they would only use data gathered directly by themselves. I discussed how this could be a false reassurance. Without external reference data, it is very hard for most businesses to have adequate capture validation or data cleaning.
  7. On the topic of ‘dirty data‘, I provocatively asked our guests how dirty they were?! What I meant, of course, was how often they clean their data. Our survey results showed 33% lack any formal data cleaning process & only 22% clean their data daily, or more often. This is a worrying gap, when you consider how quickly data ‘decays’ due to life events & changes in contact details.
  8. Finally, to bring home the importance of this topic to marketing leaders, we asked about the function responsible for data. As I have been seeing amongst my clients, there is a move towards this sitting in marketing. So, beyond the expanded remit of marketing leaders in recent years (think technology, CRM, CX etc), now add data. For many marketing leaders, in effect, they carry the can for key data quality & GDPR compliance decisions. In our survey over 50% stated Marketing was responsible for data.

I hope those findings are of interest. The relative importance of GDPR and Data Quality have been increasing over the four years RMDS have run this survey. Do you recognise these results in your business?

GDPR requires data quality, make the case for its importance

Based on those results, I emphasised to our breakfast guests the numerous reasons to focus on data quality. Hearing survey results is one thing, but planning to act in your business is another.

One of my key points, was the need to know about Article 5 of GDPR. There, in the ‘letter of the law’ (not just a recital, or guidance on interpretation), is a responsibility on data controllers for data quality. So, the first reason that data quality needs more focus it is will be the law. Organisations holding personal data need to take reasonable steps to ensure it is accurate & up-to-date.

But beyond that explicit requirement within GDPR, several of the other responsibilities require it. Without good data quality and a Single Customer View (or means of de-duplicating your customers), you will fall foul of other rules. Most organisations with poor data quality are holding duplicate customer records, each only a partial picture.

Here are a few scenarios as to where that could cause businesses big problems:

  • One of your duplicate customer records holds a ‘no marketing permission’, the other does not. This could cause a complaint about not honouring their right to opt out of marketing. It could also be a reason for your re-permissioning campaign to inadvertently contact people for whom you do not have existing marketing permission. FlyBe & Honda have already been fined for doing that.
  • In response to a request to ‘be forgotten’, you erase one duplicate customer record, but do not identify the other. When that customer receives marketing or sees their details are still on your system, expect a complaint to the ICO.
  • When someone submits a Subject Access Request, the details you send back to them are incomplete (as you have missed duplicate record(s)). This could results in a complaint, ro rework, at the least it is already a root cause of loyal customers feeling they are not known & rewarded.
  • If you are looking to make the case for a legitimate interest basis for direct marketing existing customers, your evidence base is weaker. You may lack sufficient evidence that customers have not only historically received marketing from you, but also shown some response/interest and seen opportunity to opt-out. You want as much evidence as possible. Missing duplicate customer records can easily make active customers appear more dormant.

Plus, those are only the reasons based on GDPR requirements. As our earlier survey results showed, data quality is biggest impact on marketing performance. If you have challenging acquisition & retention targets, can you afford your campaigns to be hampered by poor data quality?

GDPR requires data quality – what are you doing about it?

At each of these well organised MyCustomer breakfast briefings, after the talk, we have equal time for round table discussions. As ever, this year’s guests raised interesting questions and shared their ‘war stories’.

What about you? Are you fighting an internal battle to invest in improving data quality? If so, I hope the detail in this post and previous series on avoiding ‘being bitten on the bum by GDPR‘ help you.

Given the sheer scale of life events and daily decay of data, what are you doing about data cleansing? Do you recognise the false economy of relying solely on internal data – if so, how are you sourcing 3rd party data for validation or enrichment?

Please share your experience and wisdom. As with GDPR compliance, I’ve yet to meet anyone who is 100% there (nor anyone who will be perfect by May). But, the bigger risk may be inaction or delay. So, let’s share practical tips pon how to get started & improve data quality as we go. I wish you well in your planning.