Friday, 27 April 2018

We need to talk about 'Repermissioning Emails' before it's too late!

Repermissioning is where:

"brands seek to gain new marketing consent from their database because they believe their existing consent may fall foul of the new definition of lawful consent under GDPR."


Repermissionsing wasn't even a thing a few months ago and now consumers are being bombarded with emails (can you see the irony here?) asking them to re-opt-in to brand marketing communications they think they're already opted in to.

Confused? Yes, you should be because marketers are in a terrible pickle about what to do and what not to do under GDPR consent guidelines.

This lack of absolute clarity has resulted in a plethora of marketing jargon being spewed at unsuspecting customers through the power of email. 15 of the best and baddest examples of repermission emails are brilliantly put together by Ben Davis @herrhuld 

I am sure this is an unintended consequence of GDPR and the ICO's interpretations in creating a catch 22 where brands ask for permission to send emails in an email they have permission to send. The intricacies about why this could be necessary is lost on consumers who haven't the foggiest idea what it's all about.

Here are five examples of why marketers feel a repermissioning email must be sent:

  • 3rd party consent - gained through a 3rd party where you are unsure that consent was unambiguous and freely given.
  • Non-explicit consent - the style, wording, channel and reason for opt-in is not explicit enough for a consumer to make an informed decision
  • Bundled consent - gained through an opt-in which was used for non-marketing purposes where the consumer could be unaware of resulting marketing communications
  • Old consent - by it's very nature, people may have forgotten if they consented and it may be difficult for either the brand or the customer to prove either way.
  • Legitimate interest consent - whereas before this would be a common sense judgement now under GDPR, legitimate interest is a test that must be passed before you can market to customers fairly using legitimate interest as your opt-in statement. 

The worry is that as this problem is primarily a marketers one, consumers will fail to respond in the numbers necessary (think 5-10% response) which means repermissioning (unless absolutely necessary, see 5 examples above) is a GIGANTIC risk to any organisation that wants to continue marketing to their database.

At least 90% of 1st party data is at risk of being obsolete 

through email repermissioning


On the 25th May, many in direct marketing will be waking up the fact that they can only see 10% of their database to market to! Imagine trying to catch a ball using a single finger instead of both hands?

Therefore post repremissioning, brands need to think about ways to repopulate and grow their database quickly through...

  • Site overlay with data capture
  • Push notifications through site and app
  • Opt-in ads - via sign-up sites 

 ... to withstand the looming danger of 2018 becoming the 'annus horribilis' of data marketing.

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