Are you confident in your self-exclusion process?
“You must take all reasonable steps to prevent any marketing material being sent to a self-excluded customer.“
UK Gambling Commission
Undoubtedly these words from the UK Gambling Commission go without saying right? The potential damage of breaching such social responsibility codes can have a catastrophic impact to your brand. Significant fines, additional conditions imposed on your operating licence, or even a complete licence suspension. Not to mention stoking the media negativity fire directed at your industry.
Clearly there is never an intent to contact someone that you should not. No one has ever asked for a list of self-excluded customers so they can email them about the weekend’s Acca Offer… however, slip-ups happen.
Accidently mailing self-excluded contacts
You may feel you have a robust, watertight solution to ensure self-excluded customers never fall through the marketing exclusion net. Nevertheless, I am sure there is still an element of anxiety whilst hovering over that big scary Send button. Are you second-guessing your quality assurance processes and those last-minute quality checks?
If you plan on staying on the right side of the Gambling Commission, you have two days to update your marketing databases after receiving a self-exclusion notification, whilst taking all reasonable steps to prevent any marketing material being sent to them in the meantime. Do you have complete confidence in your process, or does the very mention of self-exclusion trigger that bead of anxiety perspiration?
The ideal situation would be that on receiving a self-exclusion notification, in a single click and within a blink of an eye, all downstream solutions are updated, reflecting the most up-to-date state of play possible. Customer accounts are closed, funds are returned, counselling and support services information offered, and all marketing activity is withdrawn. Stand down, serenity restored.
Regrettably, an idealistic situation rarely exists. On receiving a self-exclusion notification, a chain reaction is triggered, but to what level of robustness and confidence?
Some common reasons for self-excluded customers falling through the marketing exclusion net are:
- Data latency – how many interfaces does the data have to pass through before reaching all customer engagement points? You may be in a position where you have a single vendor omnichannel marketing solution, at which point removing a single record becomes a simpler exercise (in theory). More often the case, you have ended up with multiple solutions implemented over time. Potentially a coordinating device, a central repository for data, the system of record. Then supplement that with specialised products, for specific customer engagement activity. At which point you have a wider challenge, updating that central repository is one thing – but how quickly can you ensure all the supplement products have recognised the exclusion?
- Manual work arounds – we have all faced unexpected difficulties late in the campaign delivery lifecycle. Perhaps we find out that something we were hoping to do is much more complex than anticipated, or a key interface in the process is not performing. The marketing is time sensitive and is anticipated to drive significant revenue. Manual intervention could resolve the issue – so do we jeopardise quality assurance in favour of getting something deployed? Often the pressures involved in getting something out the door results in these types of decisions being made without a thorough analysis of the potential impact. If a decision is made to bypass a system and manually intervene, are you confident that you fully understand the impact this might have?
- Procedure not followed – If only the procedure had been followed then the issue would never have happened. Possibly yes, if the documented way to perform the task was not followed, then the cap fits (wear it). But what test do you give the procedure to check clarity? Is the assessment completed by a knowledgeable person, or do you ensure someone unfamiliar with the task tests? Clarity to one person is confusion to another. When developing procedures do you acknowledge that some people have 10 plus years of experience, but others have only 6-months?
- Recycling old customer lists – There are situations where single-use customer lists are consumed within a marketing campaign. Potentially in relation to point two mentioned above, or simply form part of your standard business practice to fulfil marketing activity. Either way you are introducing a static list of customers into your marketing ecosystem, and with that risk of being consumed again in error. When a static list is introduced, what do you have in place to ensure they are either removed or refreshed after their intended use?
Now you may feel you are taking all reasonable steps to prevent any marketing material being sent to a self-excluded customer. And I am in no doubt that you are. But do any of the common reasons for failings mentioned inspire you to take further action?
- Could you be utilizing automated suppression capabilities within your marketing solutions, for example applying APIs (read our blog on APIs) to update databases and suppressions lists in near real-time?
- Are all interfaces which form part of your marketing solution and the role they play understood?
- Will you appraise your quality assurance and quality checking process and procedure?
- Do you regularly audit your marketing solution to ensure all redundant data is removed?
Fixing holes in your marketing exclusion net can feel like a never-ending task, but awareness of what can be achieved with the technology you have, combined with regular evaluation of your process will always give you the competitive edge.
If you would like to discuss how Purple Square could help you with your self-exclusion process, please do get in touch.