dma advice: guidelines for controlled lead generation activity · 2018. 8. 1. · dma advice:...

DMA advice: Guidelines for controlled lead generation activity August 2018Published by The DMA Contact Centres Council

DMA ADVICE: GUIDELINES FOR CONTROLLED LEAD GENERATION ACTIVITY 2018

COPYRIGHT: THE DMA (UK) LTD 20181

ContentsAcknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Statement of requirements - Provision of marketing leads . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Out of Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

The purchasing process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Onboarding process and due dilligence. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7Umbrella contract . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Documented batch purchasing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Taking delivery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Calling the leads . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Feeding back through the supply chain . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Evidencing consent . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Auditing consent . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Complaint handling and consent withdrawal. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Refunds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Service objectives and measurement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Base service key performance indicators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Audit outcomes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Waste rate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Redundants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Returns/refunds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Example file formats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Conclusion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

About the DMA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Copyright and disclaimer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20



The DMA wishes to thank the DMA Contact Centre Council and in particular Dave Clark, NTT Fundraising, for their contribution to these guidelines.

Acknowledgements



The purpose of this document is to lay out some of the most important aspects to consider when looking to source third party marketing leads for use within a telemarketing campaign.

It looks predominantly at the processes and structures that you can implement in order to allow you to gain control of your supply chain. It does not go into great detail around the specific nature of compliance. There are plenty of resources and guidelines on the DMA’s website https://dma.org.uk/gdpr. There is also further guidance and information available on the ICO’s website https://ico.org.uk/.

This is very much a practical procedure that lays out a basic structure that should allow for you to engage with a series of lead generation providers to control and manage their supply to your business in a way that allows you to be confident that you have the necessary oversight and structures to control what they are providing.

You can find out more information here.

Statement of requirements- Provision of marketing leads



1. To provide a set of guidelines to be considered when purchasing leads from third party introducers for use within unsolicited direct marketing activity predominantly focused on the needs of the contact centre environment

2. To allow the reader to take maximum advantage of the number and variety of providers operating in the lead generation space when negotiating around price and quality

3. To ensure that the environment is one that encourages and promotes high quality vendors whilst minimising the likelihood of unqualified or rogue providers putting contact centre organisations at risk

4. To provide a standard way of assessing lead quality across multiple channels and vendors and defining a clear set of rules under which contractual negotiations can occur in a meaningful way

5. To engineer an environment where providers can be held to account for the leads they supply both from an operational and contractual point of view

6. To define a mechanism for feedback to the supply chain so that lead quality and quantity can be improved whilst also ensuring that the necessary information is returned to the original data controller with regards to responsibilities to the consumer

Scope



1. This document does not attempt to interpret or define any of the regulations around marketing. There is significant advice available from both the DMA and the ICO with regards to the regulations.

2. There is nothing in this document that should be interpreted with regards to what is a fair price or return on investment

3. No real coverage of industry specific details or requirements. This is designed to be an initial overview of what to consider.

Out of Scope



The purchasing processIn order to ensure that you are purchasing leads in the most appropriate way for your business, it is essential that you recognise it for what it actually is. It is not simply a process of pouring data into a hopper, nor is it a dark art or a commodity purchase. It is in fact an outsourcer management process.

The regulations that we operate under make it very clear that the act of acquiring leads is not simply that of buying units; it is a process around ensuring that your brand values and business requirements are upheld by a third party acting on your behalf. In the case of a business conducting unsolicited marketing activity it is likely to be one of the most significant outsourcing exercises in your business. You need to ensure that you are treating it as such.

As a critical procurement process, it is essential that there is sufficient oversight to ensure that the product that is being purchased meets the standards required for the activity you are carrying out.

The three primary concerns are:

1. Commercials Activity carried out within the context of lead generation needs to meet a commercial objective. You must ensure that the activity is profitable and sustainable at the volumes necessary to service your needs. You also need to ensure that your organisation is not dependent on too few suppliers/partners and that you are in control when it comes to adjusting the supply.

2. Compliance Given that the controller is responsible for the activity carried out by third parties in their name, it is essential that the compliance needs of this component are as carefully considered as possible. Providers are not supplying widgets to your business, they are acting as agents on your behalf; you need to engage with them and manage them as such. If you review the ICO’s enforcements there are a great many judgements where organisations sourced data without being aware of its legality and found that they, as the data controller, were exposed to regulatory intervention.

3. Demographic Given that every product or service marketed or sold via a direct approach is tailored for a specific audience group, appropriate demographic profiling is essential in managing a profitable campaign. It is also important to note that the more effectively this is done, the less likely people are to perceive the interaction as a nuisance and as such the risk of complaints falls. Also, with demographics comes exclusions: if you do not want to target specific groups then you need to ensure your lead generation partners do not canvas them in the first place.

Overview

In order to ensure that it is possible to assess and report on these three components, it is essential that the entire process of purchasing and receiving leads is carried out within the context of a repeatable and sustainable process, ensuring that all aspects are covered off every time.

It requires that the organisation recognises that this is no longer a commodity purchase and is in fact an ongoing and rolling engagement with a partner organisation that is responsible for managing your brand on your behalf.



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It is recommended that multiple providers are used that specialise over the various channels and mechanisms that exist in the lead generation space. This allows you to constantly and effectively monitor the campaign, measuring each to a set standard of KPIs and if one is performing at 10% and one is performing at 2% you can move and adjust the supply accordingly. It is not sensible to purchase large volumes of leads from a single supplier at the start of a campaign as this eliminates any opportunities for adjusting supply and getting the maximum performance from your supply chain.

It is also important not to become dependent on a single supplier in case there are compliance issues with a particular provider. If that is the case and you have multiple providers, adjusting supply to eliminate the risk is easy, if you only have a few providers then your business will be affected and it may be much harder to close down said supplies without impacting your commercials or running a compliance risk for an extended period as you seek alternatives.

All suppliers have the same pressures on their margins that everyone in business has and as such it is often the case that they will hope to be able to deliver a higher volume of leads than they can comfortably do. This usually results in a drop-in conversion rates and an increase in redundancy as the additional leads have been supplied by stretching their operation.

By having multiple suppliers and adjusting the different volumes based on the KPIs, it is possible to arrive at a point where the optimum volume for commercial benefit is available from multiple suppliers gaining much stronger margins on the campaign as a whole.

The higher the conversion rate the better the targeting and it usually follows that the number of complaints or pre-complaint outcomes are also reduced as the lead generation has been carried out correctly, and as such the audience is one where the offering has real relevance.

Onboarding process and due dilligence

Given how many providers there are in the market and the vast range of services, channels and quality available, it is essential that you create a standardised process for onboarding and assessing organisations in an appropriate way:

• Check out their ICO reference number and make sure they are registered correctly

• Check out the ICO’s enforcement website to see if they have appeared

• Ask for client references and check them out

• Check them out on Companies House or their country’s equivalent

• Confirm that the supplier has the certifications that they claim to have

• Check that they are members of any organisations they claim to be members of

• Confirm the CLIs used and the brand names used

• Check the scripts, webpages messaging that is used and ensure you are satisfied they are compliant

• Check out the unsubscribe, opt-out or consent withdrawal mechanisms and confirm you are satisfied they are compliant

• Ensure that they have a credible email address – do you want to risk your company reputation on [email protected]?

• Ensure that that they have a website registered with a credible domain

Order a standard volume of data relevant to the scale of your operation, spend more than usual scrutinising the various elements, is the redundancy levels acceptable, how much was waste, were the commercials correct, do several consent audits and satisfy yourself that the actual delivery of the leads matches the contractual agreement.

Check out the opt-out mechanisms and confirm that the complaint handling mechanisms work.



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Umbrella contract

Make sure that they indemnify you for the quality and legality of the leads they provide.

Although this may not protect you from a fine, it does show whether a company has faith that it is providing legal leads or not. Also ensure that they carry the appropriate indemnity insurance so that in the event of a problem you know that any financial impacts can be covered.

Given that the activity carried out by any third party is being done within your name, you need to ensure that you have sufficient auditing rights with regards to how they carry out their activity. Within the contract ensure that you set adequate rules around how often and the process through which you can audit the supply.

Ensure that the contract sets some very stringent rules around evidence requests, the timeframes over which the information will be received, what information will be provided and how will it be returned.

Clear rules around how DNC (Do Not Call List) requests are fed back, handled and how vulnerable consumers are identified will be managed. Ensure that all of your purchases are covered by the contract and it surpasses the terms and conditions on any invoices or documentation from the suppliers.

Documented batch purchasing

As well as ensuring that you have a single over-arching contract defining the environment, it is recommended that for each individual batch of leads that you purchase you lay out any of the specific rules around that particular tranche.

The question as it is expected to appear, the refundable outcomes, the nature of prospects that you are expecting to be focused on or excluded from, the price and the delivery schedule are some of the ideas.

Standard purchase orders will normally suffice for this activity, it is also useful when taking delivery to be able to track back to the actual source batch where the lead came from and can provide an effective framework in discussing performance with suppliers.

Taking delivery

When records are received into the business it is highly advisable to confirm what has been delivered against the particular expectations, from a volume, compliance and consumer type approach.

Check that no records are duplicated and that the same consumer numbers are not against several records. Screen against any DNC (Do Not Call List) lists that you have. Always screen against the TPS register, even if the consumers have provided consent: the percentage on the TPS register is usually quite a strong indicator of how consistent the leads are.

This is less about a specific number and more about looking at trends over time. If there are sudden changes to the mix of data etc, you should, as the controller, satisfy yourself that you understand why and are happy with the reason.

Also, for data where there is a stipulation that only those not on the TPS register should be accepted it is necessary to check. Leads should always be received via a secure mechanism. We would recommend that this mechanism is controlled by the controller not the data provider.

In other words, you dictate in your contract how the leads are to be delivered and control the access to the secure mechanism - otherwise you will be relying on external data cleaning policies out of your control.

Calling the leads

Once the leads are loaded as calling is carried out, certain outcomes will start to evolve, and it is important - especially with newer suppliers - to maintain a level of vigilance on outcomes that are potential indicators of compliance concerns.



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Think, for example: are too many records asking “where did you get my information” even though the consumer was supposed to have done the survey yesterday?

Track and monitor these pre-complaint outcomes and ensure that if there is an issue you have only contacted a limited set of consumers before pausing/cancelling batches.

Listen to agent feedback with regards to the consumers. If they are flagging lots of older consumers when the order states young families or vice versa, do not ignore them.

Do not forget that you are responsible for the leads that you are calling, although you may be able to seek financial compensation from the suppliers if your contracts are robust enough. Remember: it will still be your brand that appears on the ICO enforcement website.

Feeding back through the supply chain

Many people may disagree with this section and it is really up to the individual companies as to whether they feel it is appropriate to provide feedback to the lead generator.

We would always recommend feeding back some high-level statistics.

The process of lead generation is not a one-way street, it is important that certain outcomes are fed back to the supply chain on a regular and consistent basis, for example DNC requests or vulnerable consumers should be notified to the data controller so that they can be dealt with appropriately.

Information is provided that will allow for both the contact centre and the lead provider to have mutual visibility of the performance of a campaign.

It is assumed that this will be achieved by providing a return file. It is recommended that this is done on a weekly basis and contains all of the outcome codes with regards to the activity that has occurred in the previous week.

This will not only allow for the return reconciliation process to be streamlined, but this information could be used by the provider to better target and focus on the particular streams of prospects that are working most effectively within their overall supply.

Example service objectives can be found in the service objectives and measurements section of this guide.

Evidencing consent

It is essential that both the date of consent and the consent type/channel should be included within the delivery file containing the records (An example is in the example file format section of this guide).

Also within the purchase order the wording of the question, script or mechanism for capturing consent has been clearly documented. However there are times when you will be required to produce evidence of this consent.

You will require something tangible that clearly evidences that the consumer gave consent for the activity. Call recordings, screen captures and IP address data are some of the types of evidence. As the data controller it is likely that you will be asked for the evidence, and will then need to go back to your supply chain and request the necessary information from those organisations engaged in your lead generation activity.

This is why it is essential that a very clear set of rules are laid out in contracts around the responses and critically the timeframes around responding to such requests. There are two components that are required.

Firstly, evidence that they did, indeed, carry out your instructions and asked/presented the correct question/script. Secondly, that they followed the mechanism established within the due diligence for how they gained the consent necessary in the first place.

This varies according to the type of leads you are sourcing.



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Auditing consent

If there is a problem with your consent, it would be much wiser to identify this during your own internal processes rather than as a result of a request from the TPS or ICO.

In order to ensure that if you are asked for consent you have a reasonable level of comfort, it is recommended that you audit the supply chain’s consent records.

On a regular basis and at a level that matches the volumes being sent it is as simple as requesting evidence for specific records and recording the outcomes.

This will allow you to show evidence that you do indeed audit your consent providers, but also it will allow you to pick up issues proactively rather than as a result of a regulatory request.

Ensure that within your contract there is a commitment to allow for auditing and an agreement as to the regularity etc. Once you have that commitment in your contract then it is simply a matter of requesting the consent evidence for specific URNs and recording the results of the audit.

These organisations are working on your behalf, under your brand, and so there really should be no reason why this can’t be carried out effectively. As the data controller is accountable under the law, it is essential that you have complete visibility of the supply chain. At the end of the day these organisations are selling you consent and if they are not comfortable allowing you these audit rights, how well can you trust the consent if you come to rely on it to protect you from regulatory involvement?

It is suggested that looking at the outcome codes against the various batches of data and selecting URNs from those where behaviour has changed.

For example, if you have a supply of leads that normally has a 5% wrong number rate and it suddenly rises to 12%, then look to request a few from there. If there is a new supplier, perhaps request more regular audits in the short term.

Always make sure that you audit all of your suppliers on a regular basis, do not assume anything.

It is your brand.

Complaint handling and consent withdrawal.

It is essential that complaints and other such matters are dealt with in a consistent manner, and it is essential that the providers ensure that they effectively deal with complaints in a legal and compliant way.

All of those organisations within the lead generation supply chain will be responsible for handling complaints andoften if they have an effective complaint mechanism then more serious regulatory involvement will be avoided.

Ensure that:

• Does your provider have a contact telephone number that works?

• Does your provider have a contact email address that is responded to on a regular basis?

• Do they have appropriate opt-out mechanisms on their activity. Is it compliant?

• Do they treat consumers with the same care that your main brand would?

• Do they provide feedback to you with regards to other opt-out/complaints coming in to them.

If they do not, you have to ask yourself whether this is because the data you have been supplied with is perfect with no consumer complaints ever or that they do not have an effective complaint handling mechanism.

Test it regularly, ensure that they answer the phone/email correctly and determine if their level of customer care is satisfactory for your needs.



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Refunds

A key component with regards to controlling the supply chain is to get a clear and easily auditable refund process for all leads that are simply no use or are not legal.

All suppliers will encounter issues with regards to duplications, wrong numbers among others and it is vital when constructing the contractual environment that the supply chain takes this risk and not the purchaser.

It will encourage the implementation of controls that minimize these issues at source and improve the overall experience for all organizations operating in this industry.

It is reasonable that your supply chain would want to audit and review these, particularly early in a relationship or if a big spike occurred.

You need to ensure that your own internal auditing of caller behavior is robust. Allow a two-way dialogue to occur and arrive at a balance with the supply chain so that everyone is focused on providing high quality compliant leads.

Service objectives and measurements section details some standard outcomes that should be included in any refund and return policy. Industry specific returns can be included above and beyond these specific ones.



This section suggests some of the key metrics through which the success of the contract will be measured.

Again, this is based on the assumption that all information relevant to the provider’s success at achieving the target metrics is made available in a consistent fashion.

Stability in the performance of the leads will be achieved over an extended period if the feedback loop is operated in an efficient way and that it is seen as a benefit for both parties.

It is recommended that weekly catchups take place and trends/oddities and spikes in both performance and complaints/ pre-complaints are addressed together.

Base service key performance indicators

In order to measure the success of this campaign it is essential that the key operational KPIs are clearly defined and all parties are aware of what is trying to be achieved.

It is no good to chastise a supplier for not hitting a KPI if they were unaware of your expectations.

These also provide useful early warnings around issues that can cause complaints.

KPIs are provided with a target and an acceptable threshold so that operational norms can be established. Consistent under performance against limits could trigger a breach of contract event or claw back, depending on the nature of your specific contracts.

The limit does allow for flexibility without compromising your ability to use the contract if necessary.

OperationalKPI Description Target LimitConversion Rate This is the number of

successful outcomes against the decision maker contacts (DMC)

X% X*0.75%

Redundant Rate The number of outcomes where a DMC was impossible to make

X% X*1.2%

Waste Rate The number of leads purchased that were unable to be loaded into the dialer

X% X*1.5%

Delivery Volumes The number of leads delivered per week should not vary from the plan by more than 10% per week

X% X*1.5%

Service objectives andmeasurement



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QualityKPI Description Target LimitAverage Deal Value The average value of a

successful call, depending on the campaign this may be number of products, size of deal etc.

PO PO

Eligibility How effectively has the provider matched the sort of consumer you are looking to talk with

PO PO

Clawback How many deals fall through after the pitch

PO PO

Audit outcomes

Ensure that any feedback from audits carried out over the previous timeframe have been successful, a failure rate is not really practical at this point as it is a black and white issue.

If you have a poor-quality audit on a supplier, you need to ensure that you can stop supply immediately. This does not mean you have to, if a longstanding supplier has a poor audit due to a non-systemic problem with a weak caller then work with the supplier to drive your requirements.

If the issue is a systemic one, for example you find no recordings or a completely different script to the one you asked for being used or a total disregard to their consent requirements then within your contract you should be able to terminate any further supply and take the necessary action.

Waste rate

Waste is defined as leads that are delivered but are then subsequently not able to be loaded into the dialer for a number of reasons the key ones listed below:

1 Supplier Reject - Duplicate in Batch

2 Supplier Reject - Duplicate, Other Supplier

3 Supplier Reject - Duplicate, Same Supplier

4 Supplier Reject - House File

5 Supplier Reject - Bad Telephone Number

6 Supplier Reject – Bad TPS status

In order to avoid complaints and TPS related issues, in multiple campaign environments, it is recommended to avoid making calls to the same individual on more than one campaign for a set period.

Major complaints are caused when the same lead has been delivered three times to different campaigns in the call list.



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The consumer does not realise or care that there are multiple campaigns they just feel harassed. This rule is important as it reduces the risk of regulatory involvement. This rule applies to the last three months only and in the case of duplicates the first lead loaded is acceptable, all subsequent ones are deemed duplicate.

Redundants

Redundant records are defined as calls where it was impossible to make a Decision Maker Contact.

1 Gone Away

2 Wrong Number

3 Unobtainable

4 Deceased

5 Fax Number

6 Suppressed (DNC)

7 Tried max times

8 Juvenile

9 Not available in time period

Most are self-explanatory, but suppression is where we have received a request from the supporter, the provider or the client to no longer make contact with a lead.

Wrong number is where the call is answered and wrong number given, unobtainable is where the telephony system has tried the number and had three unobtainable tones in a row. “Tried Max times” is that the record needed to be retired for too many attempts and “not available in time period” is when instructions are received that a prospect is unavailable for an extended period.

Returns/refunds

Under the terms of any agreement, it would be expected that the provider replace the leads that fell under certain of these outcomes as they were never going to yield a decision maker contact.

These should be defined as a standard in any overall contract, with any exceptions detailed on a purchase order provided for a particular tranche.

Suggested ones include:

1 Supplier Reject - Duplicate in batch

2 Supplier Reject – Duplicate, same supplier

3 Supplier Reject - Bad telephone number

4 Supplier Reject – Duplicate, other supplier

5 Supplier Reject – House file

6 Gone away

7 Wrong number

8 Unobtainable

9 Deceased

10 Fax number

11 Suppressed (DNC)

12 Juvenile



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Although there is a clear commercial benefit in doing this, the key reason is one of compliance, if you are receiving data from what you think is a recently carried out survey and the record appears to be a wrong number – what timeframe was it between the survey and your call? How was the original lead captured and confirmed?

Calls to wrong numbers can still generate complaints and are a compliance risk. Making them refundable drives the supply chain to minimise them.

In order to allow for commercial practicalities, expect that return outcomes will be refunded if they are completed with a return outcome, within 28 days from the date loaded otherwise the supply chain will be held to account for items that are moving outside of its control.

A specific note should be made with regards to the Supplier Reject – Duplicate Other Supplier. Lead generators are not likely to be held to account for an occasional duplicate with a different supplier in your lead generation activity.

The concern comes when certain providers have a clash over a significant block of data. You need to understand whether they are sourcing data from the same place or are trading data amongst themselves. This is a business risk that you must understand.

We would recommend including a level of accepted run rate duplication and protect yourself from being charged for the same consumers in a really short time frame.



Example file formatsIt is essential for the ease of operation that the recipient of the leads receives records in a standard form from all suppliers. This allows for the ease of action, but also standardisation leads to compliance.

An example file format is presented below, however, it is essential that an organisation ensures that its own needs are provided for in this format.

Let the supplier do the work and then you do not have your IT team having to load different file formats each week. Ensure that there is a URL present as this will allow for discussions and file matching to occur without the use of personal data - particularly when dealing with returns.

Standardising the process for delivery also allows for security to be ubiquitous, something that is key to ensuring prospects are protected appropriately.

Delivery file formatColumn Format Description

URN Text Unique Identifier

Source Text The source/lead type

Title Text The Title of the person (Mr, Mrs, Miss, Dr etc)

First Name Text The first name

Last Name Text The last name

Address Line 1 Text

Address Line 2 Text

Address Line 3 Text

Town Text

County Text

Postcode Text

TelNo1 Text Correctly formatted telephone number with leading zero, leave blank if not available



Email Address Text

Consent Date dd/mm/yyyy The date when consent was obtained



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Consent Channel Char This is the channel from where the consent was obtained

Date of Birth dd/mm/yyyy Leave blank if not captured

Gender Char M for male F for female

On TPS Flag Char 1 if on the TPS register, 0 if not on the register, leave blank if unknown.

In order to support the suppliers in achieving your needs, a return file should be provided via the same secure means as the original delivery was delivered containing the URN and outcome code of the leads completed in the previous week.

By using the URL you are not risking further personal data exposure.

Return file formatColumn Format Description

URN Text Unique Identifier

Source Text The source/lead type

Outcome Code Text A code that matches with the standard outcomes stated above



The purpose of this document was to look at lead sourcing from a process rather than a regulatory point of view. One of the areas that GDPR focuses on is documentation and evidencing of compliance, ensuring that you have gone through the procurement process for direct marketing leads and standardised and documented the processes within that component of your marketing activity is vital. Know your sources, know your process, know your KPIs and ensure that they are implemented in a consistent and sustainable way.

Maintaining a broad spread of data sources and ensuring that your organisation is not dependant on a single provider will allow you to have the power to enforce and drive both compliance and performance into the system.

If you are a controller looking to outsource any form of unsolicited marketing to an outsourcer or agency, it is essential that you understand and constantly review the mechanisms and processes that underpin the buying process within the third party. You are ultimately responsible. Process driven organisations that can clearly demonstrate transparency across their entire lead sourcing should give you confidence in their approach. Adhoc list purchasing should really flag concerns as should obtuse financial transactions within the supply chain.

Ensure that you have effective KPIs across all of the sources that you are buying from and that they are providing standard measurements across all of the various supplies. Do not obsess over the headline KPIs. If you only review your lead performance on conversion rate and do not assess things like waste, redundancy, attrition and compliance you will get a significantly weaker performance overall than you may percieve from the reporting. Consistency is the greatest tool in driving down complaints, a standard repeatable process for sourcing and reporting on marketing leads will be one of the most influencial steps in securing that consistency.

For more information or additional details please email [email protected]

Conclusion



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Published by The Direct Marketing Association (UK) Ltd Copyright © Direct Marketing Association. All rights reserved. www.dma.org.uk

About the DMA



DMA advice: Guidelines for controlled lead generation activity is published by The Direct Marketing Association (UK) Ltd Copyright ©Direct Marketing Association. All rights reserved. No part of this publication may be reproduced, copied or transmitted in any form or by any means, or stored in a retrieval system of any nature, without the prior permission of the DMA (UK) Ltd except as permitted by the provisions of the Copyright, Designs and Patents Act 1988 and related legislation. Application for permission to reproduce all or part of the Copyright material shall be made to the DMA (UK) Ltd, DMA House, 70 Margaret Street, London, W1W 8SS.

Although the greatest care has been taken in the preparation and compilation of DMA advice: Guidelines for controlled lead generation activity, no liability or responsibility of any kind (to extent permitted by law), including responsibility for negligence is accepted by the DMA, its servants or agents. All information gathered is believed correct at August 2018. All corrections should be sent to the DMA for future editions.

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