There is still some debate as to whether companies will need to re-optin all their
data. The use of the Legitimate Interest clause confuses the issue as to whether
other forms of consent are required. The other issue to consider is that under
PECR there is still a requirement to demonstrate that a legal opt-in was collected.
This leads to the conclusion that most companies will need to complete some
sort of re-optin process.
We have run a few trials recently to gauge which re-optin incentives work best.
So here are our top tips:
1. Massive discount offer – local company advertises a huge discount offer to
previous customers. Recognisable brand – genuine offer – local
customers. Got a huge response and 27% percentage re-optin using a
SMS campaign.
2. Voucher deal – customers offered a discount voucher in return for their
re-optin. National company – recognised brand – good discount. Got a
15% re-optin response using a SMS campaign.
3. Intercept offer – web based company included the re-optin request as
part of their standard login but also offers a skip option. Offer rewards for
completed opt-ins. Campaign is ongoing and difficult to calculate but
little negative feedback.
4. Email incentives – sent email offering free credit on re-optin. Response
was disappointing with only 2% conversion rate.
5. No offer – simply asked subjects to re-optin due to changes to data
protection regulations. Email campaign – recognised brand – sent to own
customers only. 1% response – however email campaign open rate and
click rate was low.
This is not scientific and uses a limited customer set but looks like incentivised
re-optin works best when presented at the customers web site. However, I think
any sort of re-optin campaign is going to be tricky to manage. Companies should
start now!
Good luck all.