A few weeks ago my wife took advantage of a good sales promotion - a copy of Elle magazine for just one pound. She saw it via that most conventional of channels, a coupon ad in the London commuter newspaper Metro. It was clearly a popular offer as she had to go through eight of the copies lying around in her train carriage before finding one where the coupon had not already been torn out.
It is a classic way to gain trial by new readers and at the same time to build a database of prospects. Publishers have deployed the discounted sample copy for decades and it still works. But there is another practice that has been going on for just as long and which this coupon also demonstrated - poor data collection.
To begin with, the data capture elements on the coupon were not designed with any view to making collection of the information easy. There was no standardised address structure in the design or any prompt for a postcode, just a single dotted line. Neither was it made clear whether any of the elements were mandatory in order to take advantage of the offer.
That is no bad thing - consumers should not always be required to provide data that has no real relevance to the promotion. At the same time it is important to be clear about the value exchange. If you are providing a four pound saving on a desirable magazine, it is reasonable to request some data specifics.
In this case, the coupon requested email address and mobile phone number. For future promotional marketing (and to increase the potential resale value of this data) that makes perfect sense. Many consumers in the target market would probably be perfectly at ease giving the publisher this information.
If only the coupon had provided any explanation as to why this data was needed, that is. No such detail was contained in the limited small print, despite the provisions of the Data Protection Directive about limiting data to what is required for the purpose.
Worse yet, this promotion failed the most important test - it lacked any consent request. Under the provisions of the Privacy in Electronic Communications Regulations, use of an email address or phone number require a specific opt-in. This coupon did not provide any box in which to provide that, nor any kind of privacy notice or data protection explanation.
As a result, either National Magazines has no intention of using the data captured from these coupons or it risks breaching PECR the moment it contacts those who redeemed. Claiming that using the coupon to get a copy implies consent will not wash. This is a shame, given the good track record this publisher generally has around its use of data for marketing.
More likely the problem is down to whatever promotional marketing agency put this offer together. For as long as I have written about data and direct marketing there has been a knowledge gap in this sector around how to handle personal information. Coupon design tends to be poor, privacy notices missing and, even worse, data left uncaptured and often disposed of insecurely.
Individual consumers may not be that worried in the moment where they get a cheap magazine in return for a completed coupon. But any marketer using this approach to build product trial, usage and consumer data has to give data capture the attention it not only deserves, but requires by law.