8/10/2018 Updating Customer Records in the Group/The Connection With GDPR Following the flurry of activity back in May as businesses and organisations struggled to understand and implement GDPR (General Data Protection Regulation) compliant processes, it seems that very little has been mentioned of it since. This doesn’t mean, of course, that the legislation has “gone away” or no longer matters. It’s still here and it does matter. Despite this apparent “calm after the storm”, we still believe that there is work to do in the group with regard to GDPR, and highlight below a new process to assist with this. One of the key areas of GDPR is the empowerment of customers to manage/amend their data and preferences held by companies that they have contacted and/or purchased from in the past – such as the Platinum Group. In other words, we have to make it easy for customers to change their data records and their preferences (held on our databases) as things change in their lives. How Can We Make This Easy For Our Customers? In our current digital marketing activities (such as email campaigns), we are now providing links to online webpages for customers to update their records, communication preferences or to tell us that they no longer wish to receive communications from us at all. If a customer completes and submits their information via this method, their details automatically pass to the Direct Marketing team, who will update the record accordingly. Though we’re still evolving this process, the channel of communication is clear, recorded and considered GDPR compliant. But, there are other scenarios that we must seek to avoid. Example Scenarios To Avoid (These are fictional scenarios, not actual events, but have the possibility of happening) Scenario 1 Two years ago, when Mr Smith purchased a vehicle from Platinum Nissan in Trowbridge, we collected personal information from him at that time, which was then added to our customer database. Mr Smith then had a change of circumstance, whereby he secured a new job based elsewhere in the area, and decided to relocate to be closer to his job. As he’s a well organised person, Mr Smith contacted the local businesses with whom he’s had past relationship including us at Platinum Nissan Trowbridge, the supplier of his vehicle. Because his only contact with the Platinum Group was via the dealership he purchased his vehicle from (i.e. Platinum Nissan Trowbridge), he decided to phone the branch to provide his new details. As he still wished to receive our communications, his aim was simply to inform us of his new address. The team member who answered the phone took Mr Smith’s details on a notepad and then failed to pass his new address to the Direct Marketing Department. The result was that we failed to comply with Mr Smith’s request to change his address, and continued to send marketing to his old address. As Mr Smith was no longer receiving any of our marketing and communications, we were vulnerable to losing him as a customer to a competitor thereafter. We never saw him visit us again. Scenario 2: Mr Jones decides to purchase a new Toyota from Platinum Toyota in Bath. Though he is suffering from a health problem, he is optimistic about his prospects of recovery, but after a year of treatment, he sadly passes away. Soon after his death, his wife sets about sorting out his affairs, and contacts the companies who send marketing to him, as she finds it upsetting to receive items addressed to him. She decides to phone Platinum Toyota in Bath, to ask that her late husband is removed from the database. Though a team member at the dealership takes the message, they don’t inform the Direct Marketing Department and we continue to send marketing to Mr Jones, further upsetting his wife. This happens not once but four times, until we amend the record on our database that Mr Jones has passed away, following receipt of a letter of complaint from Mrs Jones. Mrs Jones subsequently decides not to return to Platinum as a result. Scenario 3: Mr Williams has been a customer of Platinum Vauxhall in Frome for a number of years, but he has always been irritated by receiving marketing materials from ourselves and other businesses, which he finds annoying and intrusive. The publicity surrounding GDPR was of interest to Mr Williams, who read up extensively about it; the new legislation would give him an opportunity to “push back” against the companies sending him the unwanted marketing. He subsequently contacted Platinum Vauxhall in Frome and demanded that we remove him from our database, but as in Scenarios 1 & 2, the message to do this was not passed on to Direct Marketing resulting in us continuing to send him marketing. Mr Williams was incensed about this, so he contacted the GDPR regulatory body (the ICO) who decided to launch an investigation into the Platinum Group focusing on our processes for ensuring GDPR principles are upheld. This was a very time consuming process for the company who were given a warning about future conduct. In addition, we also lost Mr Williams as a customer, who was very vocal on social media about the group’s lack of adherence to GDPR, thus encouraging other complainants to approach the regulator (the ICO). Other Scenarios: The above scenarios are examples of the types of things that can happen, and there may be other similar scenarios that could end with a similar result, including investigations by the ICO potentially resulting in fines. How Can We Avoid These Scenarios – An Enhanced Process As you can see from the “scenarios”, the area in which we’re most vulnerable is when a customer contacts one of our branches (usually the one they’ve visited as a customer) requesting a change of personal details or removal from the database, and that request not being passed to and therefore not completed by the Direct Marketing Department. In order to help with this, we have therefore developed a new internal process that features a capture form for all team members to use, but especially useful for those who are customer facing. The process works as follows;
If a customer wishes to be removed from our database, it is worth ensuring that they realise what they’ll miss out on by doing it. Here are a couple of sentences which may help to explain the customer benefits of remaining on our database; Sales There are many great reasons for us to stay in touch, including all the latest new car model releases and information, latest special offers, invitations to events & dates for the diary. Aftersales An important part of our aftersales communication with you includes timely reminders for your servicing and MOT test, service plans, special offers and any outstanding recalls on your vehicle. In addition, we will shortly be introducing a dedicated page on the Platinum Motor Group website where a customer can input their own information and submit it to us – we will send a short memo on this when it’s complete. For a more detailed company policy on GDPR, please visit your company intranet Platinum Info Central (www.platinuminfocentral.com), where our full GDPR policy can be found in the Company Handbook Area – see Section 3 (Employment). There’s also a GDPR resource area containing memos, news and other items.
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