the morning post accessing mailmark and tray savings - 25 june

Data protection 2013

Friday 8 February

#dmadata

Supported by

The morning post: accessing Mailmark and tray savingsWednesday 25 June 2014, Kings Place#dmapost

Supported by

Introduction

Mike Lordan, Director of external affairs, DMA

#dmapost

Supported by

10.00am Registration

10.30am Introduction

Mike Lordan, Director of external affairs, DMA

10.35am MailmarkCharles Neilson, Head of business development – Consumer & network access, Royal Mail

11.00am DSA perspective

Jennifer Rufus, Head of product development, TNT Post UK

11.10am Mailing house perspective

Peter Stockton, Mail solutions director, Communisis

11.20am Questions

Charles Neilson, Royal Mail

Jennifer Rufus, TNT Post UK

Peter Stockton, Communisis

11.35am Refreshment Break

Agenda

Supported by

Mailmark

Charles Neilson, Head of business development –Consumer & network access, Royal Mail

#dmapost

Supported by

Royal Mail Mailmark®

Royal Mail Mailmark®

Charles Neilson

Head of Business Development, Consumer & Network Access

Royal Mail

Mail is alive and well

Royal Mail Mailmark®

We’re all here today because each have a vested

interest in the future of mail

Mail is alive and well

People pay attention to their post

People still prefer to receive paper bank statements (44% of

British residents say their financial records would be incomplete without them)

14% of people in the UK have never used the internet

17% of households do not have internet access

- Insight Exchange, 2011

- ONS, 2013

Royal Mail Mailmark®

Mail plays a distinct role

Royal Mail Mailmark®

Bills or statements

Loyalty rewards

Confirmation or follow up messages

Issues or complaints

Information from companies not used before

Other products and services

Welcome packs

Reminders

Brochures and catalogues

News and updates

Promotions and offers

Preference for Mail vs Email (absolute: % prefer mail vs % prefer email)

Source: Quadrangle 2013: S4Q2A/B, How do you prefer to hear from new companies / companies you have used before, for...? Base: Total, n=1000

Mail means higher emotional engagement

Royal Mail Mailmark®Source: RM Neuro-Insight, August 2013

Mail needs to prove itself

Mail is a premium product

It’s a tangible product

Other mediums have metrics

Mail needs to stay relevant in the 21st century

Royal Mail Mailmark®

What our customers want from mail

Our customers want insightful reporting

They want to see where their mail is in the supply chain

They want to know more accurately when it’s going to

land

They want to know if there are any problems

They want to have oversight of the whole process

And of course they want all of that with the best value

Royal Mail bulk mail product

Royal Mail Mailmark®

Investment in mail innovation

So Royal Mail have invested

to make mail smarter…

Royal Mail Mailmark®

Investment in mail innovation

We have already upgraded our reporting systems and

invested in Letters Automation

And now are investing a further £70M to make mail

work smarter for our customers

Mailing Houses, customers and our industry colleagues

have also worked to support the capability

So together we can promote mail a modern and integral

part of the media mix

We can introduce the future of mail...

Royal Mail Mailmark®

I am here...

Barcode

A new barcode standard for machine readable Business, Advertising and Publishing Mail

Technology

Sorting machines that read the new barcode and collect mail data.

Reporting

A Mail Analytics platform that reports on volume, compliance, day of arrival and overall performance of consignments.

Royal Mail Mailmark®

Royal Mail Mailmark®

What happens to mail?

Sending

Customer Outward

Mail Centre

Outward Sort

Track Event

Royal Mail

network

performance

Royal Mail

delivery

performance

Predicted

delivery

performance

Delivery Batch

Track Event

Walk Sequence

Track Event

Inward

Mail Centre

Delivery

SequencingDelivery

Sorted Mail

Wholesale& Retail

eManifests

Dashboard

Unsorted

Mail &

Meter

Royal Mail Mailmark®

Royal Mail Mailmark®

Mailmark™ gives you confidence

Consignment level tracking

Supply chain visibility

Transparency of Royal Mail performance

Audit trail

Predicted delivery day

Item level error reporting

Best value product

Royal Mail Mailmark®

Royal Mail Mailmark®

Mailmark™

Analytics

Mailmark™ Analytics

Royal Mail Mailmark®

Predicted Delivery

Mailmark™ Analytics

Royal Mail Mailmark®

Mailmark™ Analytics

Royal Mail Mailmark®

Reporting gives us insight

These insights help us operationally

Big benefits for our customers too … you can

use the new insight to improve mail and data

quality

Royal Mail Mailmark®

Reporting – what have we learned?

Read rate of items more than

97%

Predicted delivery consistently

high and exceeding service

performance targets

Across Wholesale, 1c, 2c, E =

More than 98%

Royal Mail Mailmark®

Reporting – headline figures

We have been able to identify which customer mail items

fail to meet specification

We let the customer know, so they can look into any

problems with the production of their mail

Some issues already identified and resolved include:

→ Incorrect barcode type

→ Out of date look-up files – consistently missorting

→ Bad address data – accidentally mailing

internationally

→ Barcode zone infringement – pre-MailmarkTM this would have been a tap out reversion

Royal Mail Mailmark®

Reporting – how we’ve helped customers

Royal Mail Mailmark®

Mailmark®

Proportionate

Adjustments

Royal Mail Mailmark®

Before MailmarkTM…

We based all of our checks on sampling

We sampled a small percentage of a mailing

And on the basis of that sample, we made an

assessment on the mailing’s compliance with the

product specification

If the sample showed errors we’d then revert all or

part of the mailing…

Royal Mail Mailmark®

We are moving to a new world

Where we no longer rely on manual sampling

Where our checks take place ‘in-process’ via

automation

Where we can pinpoint individual items that have

errors such as the wrong format or class

And where we make an adjustment or charge only for

the element of the mailing that is wrong

Royal Mail Mailmark®

The MailmarkTM option is for highly machinable mail

MailmarkTM option retains the current 90% Postcode &

DPS accuracy requirement for Business, Advertising and

Publishing mail

Customers will only be charged for proportion in error

below this threshold - e.g. a 89% postcode inaccuracy

would mean a 1% charge

The 90% threshold will be reviewed for March 2015

And … if the chargeable amount is < £10 per eManifest -

we won’t make a charge

Royal Mail Mailmark®

With the MailmarkTM Adjustments Framework

We will tell you when

something is wrong

We will help you get it

right next time

Any charges will be clear

and proportional

29

Royal Mail Mailmark®

Mailmark™

- the future

Benefits to customers:

Improving the quality of mail across the board

Supply chain visibility

Benefits of Analytics

A collaborative market approach:

Using MailmarkTM technology to improve data quality and

improve processing

Using MailmarkTM technology to support mail volumes

Committed to working with you to build on Analytics over

time

Royal Mail Mailmark®

MailmarkTM technology – in summary

We believe that by working together we can bring

90% of bulk mail volume onto Mailmark™ by

2016

Providing benefits to both the industry and all of

our customers

All the while improving mail quality and relevance

Royal Mail Mailmark®

MailmarkTM technology – vision for the future

Package of measures to encourage customer adoption:

Continued collaboration on reporting

Two additional bespoke report writers approved

Input from customers, SMP, WAG, DMA and others

Review of Mech Specification Option availability

CBC/OCR retained until at least 2016

Pricing differential between Mailmark and CBC

Prices announced at April 2015 Tariff

Plan migration early to be ready to benefit

Royal Mail Mailmark®

MailmarkTM technology – vision for the future

Contact your Access Operator, Mailing Agent or

Royal Mail Account Manager to review the

benefits of Mailmark™ for your business

Contact me! I’m always happy to talk to our

customers

charles.neilson@royalmail.com

www.royalmail.com/mailmark

Royal Mail Mailmark®

How do you get involved?

Royal Mail Mailmark®

DSA perspective

Jennifer Rufus, Head of product development, TNT Post UK

#dmapost

Supported by

Mailmark update: an operators perspective

Where are we now ?

• Live with both presorted and unsorted from March 2014

• Current volumes processed and Handed over to Royal Mail is 1, 138, 691 items to date

• Working in a collaborative way with RM Mailmark team to develop and improve offering as we move forward

• 99.85% successful read rate of mail handed over to Royal Mail so far…

What has been good….

• Positive approach between both Royal Mail and TNT Post

• Ability to influence change as we have been an early adoptor from the beginning and the only DSA operator to be live with both unsorted and presorted mail

• Seems to be more and more engagement from customers and mailing houses but not a lot of doing….

• Spec should make it easier for customers to achieve lowest level pricing

• Our analysis so far shows that the surcharges will not impact us in the same way as current reversions policy

Potential Challenges still….Customer Take on process- Unclear but we are working to address this

- Inertia from DSA customers to interact directly with Royal Mail Retail team could be stifling the progress to take up Mailmark

Surcharges- Unclear as to what this really means for customers, the data in the portal still has

glitches

- Could open up a lot of queries as reporting is against the emanifest and DSA customers are billed against bag manifest so the 2 could never match!

- Internal challenges for reconciling against the Royal Mail bill for Mailmark

Pricing Differential- A lot of customers/mailing houses waiting until price differential kicks in

- We do not want everyone to wait until next April to take this up as both TNT Post and Royal Mail could struggle to support

- Need to encourage mailing houses to start developing now to be live before next April to take full advantage of price change

Mailing house perspective

Peter Stockton, Mail solutions director, Communisis

#dmapost

Supported by

Communsis & Mailmark‘the mailing house perspective’June 2014

Mailmark – Our View

Mailmark is the exciting future of Mail – put simply Mailmark will

enable intelligent mail and that can only be good news for us all

Mailmark uses a smarter barcode which Royal Mails sortation

equipment reads to track individual mail packs

It has required investment in terms of software development, but

with the large amounts of Transactional mail our sites handle it was

considered to be an investment for the future

It is clear that technology has been an enabler for many industries

and it is good to see so much innovation in the postal market,

particularly in the area of Barcodes.

It’s a good news story that we have fully embraced

Mailmark – Our Journey

The choice of Barcode needs careful consideration with clients for

both mail piece look and the customer data requirements.

Producing various examples supports this decision

Presentation of mail – two different streams, taking longer in terms

of production time

Upload of E-manifest – more time consuming and onerous for us to

ensure any batches are correct on the E-manifest prior to upload

We’ve had a few teething issues, which through working with Royal

Mail have been speedily resolved, we have to continue to manage

the Clients expectations

We managed an exercise where a Proof of Concept document was

provided to our client demonstrating its success

Mailmark – The positives

Predicted delivery date – Improves customer processes e.g. it

enables clients to staff call centres etc. more effectively

Mailmark will potentially be the ‘Best Value’ Machineable product

going forward

For the first time our customers can get accurate reporting on what

is happening to their mail. Its not just what it reads but also what it

doesn’t that’s interesting

Future upgrades will enhance the product even further in particular

in the areas of returned mail and confirmation of delivery

It has been important to us that Royal Mail have understood our

processes which has enabled us to work together to achieve a single

solution

Mailmark Future

In our experience it has been successful project so far,

creating transparency throughout the process. This

has shown to be a true partnership with Royal Mail and

the end client.

Our advice would be ‘Embrace this New

Technology’ to promote better mail for

all our customers!

Questions

Charles Neilson, Royal MailJennifer Rufus, TNT Post UKPeter Stockton, Communisis

#dmapost

Supported by

Refreshment break

#dmapost

Supported by

11.55am Letters in trays

David Dale, Head of product design, Royal Mail

12.10pm DSA perspective

Dean Ryan, Head of implementation, TNT Post UK

12.20pm Mailing house perspective

Alistair Ezzy, Sales director, GI Solutions Group

12.30pm Forecasting

Danijel Karadza, Network access account director, Royal Mail

12.40pm Questions

David Dale, Royal Mail

Dean Ryan, TNT Post UK

Alistair Ezzy, GI Solutions Group

Danijel Karadza, Royal Mail

Alex Walsh, DMA

12.55pm TNT delivery network

Andrew Goddard, Commercial director, TNT Post UK

1.15pm Data protection legislation changes – implications for mailing houses

Janine Paterson, Solicitor, DMA

1.25pm MPS

John Mitchison, Head of preference services, DMA

1.30pm Conclusion and thanks

Mike Lordan, Director of external affairs, DMA

1.30pm Lunch and networking

Agenda

Supported by

Letters in trays

David Dale, Head of product design, Royal Mail

#dmapost

Supported by

Could you save money by posting mail in trays?

David Dale Head of Product Design

• Before 31st March

Sorted mailings could use bags/bundles or trays

Royal Mail Wholesale gave a tray discount

No discount for Royal Mail Retail customers

• From 31st March

Sorted mailings can use bags/bundles or trays

Royal Mail (Retail and Wholesale) give tray discounts

Discounts increased

52

What’s changed?

• Customers wrap and strappex bundles of mail, and tie up

bags - in line with Royal Mail’s specifications for bags

• Royal Mail cuts open all the plastic wrapping and the

strappex and bag ties, and places the mail into trays

53

Why offer a discount?

Advantages of trays

Royal Mail opens bags and bundles for all sorted mailings* to transfer the mail to trays

Mail in trays is typically in better condition as it travels through the mail pipeline

On average this mail is sorted more readily and has fewer quality issues

Barcoded mail has better read rates

• Bags must be tied

• Mail must be bundled

• Bags give less protection

• Trays do not need ties

• No need to bundles

• Trays protect mail

• Lower prices

54s There are presentation requirements – see the rest of this presentation and the Containerisation section of

our User Guide. * Excluding Parcels, A3 Parcels and Large Letters over 10mm in thickness.

Savings on Letters

0.2pPer item

Excludes VAT

Effective 31st March 2014

55

£2Per thousand items

40pPer bag or tray, based on 200

items per container

Savings on Large Letters

0.3pPer item

Excludes VAT

Effective 31st March 2014

56

£3Per thousand items

15pPer bag or tray,

based on 50 items per container

…has not changed

•No changes to the rules about tray labels, weights etc

•Specifications for bags/bundles and trays are unchanged

•More details at www.royalmail.com/traysavings

57

The technical stuff

What could possibly go wrong?

58

• Care is needed when changing over to use trays

requires advance planning eg tray labels are different

• Tray Supplies

operating smoothly since 31st March; trays ordered as per bags

•Logistics and storage can be affected

‘…concerned about the internal logistics challenges and workload of

using trays over bags (cages, consumables) etc…’

‘…limitation was under the roof storage of trays, floor space

around production lines…’

• Exceptions (some items not permitted in trays)

parcels, items over 10mm etc – check the details at

www.royalmail.com/traysavings

What happens next?

59

• Royal Mail’s aim is to convert all the mail that can

reasonably be trayed (currently c40% for Retail)

• There will always be exceptions

• Customer take up and technical issues will be reviewed

autumn 2014

• Longer term aim to improve our standard trays (reduce

weight and improve ‘nestability’)

• Tray savings £value will be reviewed as part of general

price changes, along with other discounts

For more information

60

• Ask your mailing house

• Ask your usual Royal Mail contact

• www.royalmail.com/traysavings has contact details for

ordering trays, and technical information about tray fills

DSA perspective

Dean Ryan, Head of implementation, TNT Post UK

#dmapost

Supported by

Mail in TraysDSA Perspective

When does it work?

• Presentation in trays can and does work in certain

circumstances

• Low sort transactional mailings

• Some Low sort high volume 1 piece Large Letter mailings

• Regionalised large volume High sort mailings

• If minimum tray fills can be achieved

• 175 Letters

• 50 Large Letters

When does it not work?

• There are circumstances when it does not work

from a TNT Post perspective

• High Sort mailings

• Low volume mailings

• Large Letter mailings

• Mailings where minimum tray fill cannot be achieved

Operational Impact Moving all Low sort mail to trays

• TNT Post already handover mail in trays• Circa 20% of all Low sort mail

• All of our consolidated Mail

• Moving air around network is costly• Ave tray fill Letters - 14% lower

• Increased pressure on consumables• Ave Items per York – Bags – 5357

• Ave Items per York – Trays – 4683 – 13% lower

• Extra 66,000 Yorks per year

• Increased magnums required – circa 15,000

• Storage space – Trays take up more space than bags

• More Trays & Yorks = more Processing, Consumable and transport costs

Commercial Impact

• Increased costs to process all Letter 70 =13%

• Additional cost of consumables

• Increase in transport costs• More Vehicles

• More Routes

• Current discounts offered do not reflect cost to Carriers to process

• Current discount of 0.2p not sufficient to cover cost of change

Way Forward

• TNT Post are generally supportive of presentation in Trays

• Need to continue to work with MH’s and RM to find best solutions

• Use of different consumables – pallets for example.

• Consolidation of mailings

• Large Letter mailings to be assessed and negotiated on an Individual basis – Volume & Weight dependant

• Discounts must reflect real cost of processing in trays

Mailing house perspective

Alistair Ezzy, Sales director, GI Solutions Group

#dmapost

Supported by

Trayed Mail Presentation

How it affects the mailing

house

Why tray?

• Provides clients with postage saving (0.2p letters, 0.3p large

letters)

• Items are received at Royal Mail in a clean and undamaged

manner

• Reduces manual handling

• Reduces labour

Why tray?

Operational Difficulties

• Increased storage

• Less items per container

• Pallets cannot be stacked as efficiently

• Increased pallet movement

• Increase in logistics/collections

• Difficult to accurately calculate tray fill with physical constraints

• Operational differences between suppliers

• No clear identifier on originator of consumables so monitoring consumable levels for

each provider is difficult

• Tray supply through DSA challenging

Operational Difficulties –

consumable storage

Operator Differences

• TNT minimum tray fill 175 – will reduce with agreement

• TNT require all trayed work to be 8 way segged

Operator Differences

UK Mail require client to have a tray arrangement in place

Mailing profiles and average and minimum tray fills are applied to the arrangement

Surcharges apply where minimums are not met (this is averaged over the mailing) approx. costs 9p per tray

Environmental Impact

Shrink Wrap

Increased transport - consumables in & collection out

Sustainability of pallets Vs longevity of magnums/cages

Forecasting

Danijel Karadza, Network access account director, Royal Mail

#dmapost

Supported by

Importance of Forecasting in Delivering Excellent Customer Service and Network

Efficiencies

Dan Karadza

Network Access Account Director

DMA Postal Event

25th June 2014

Agenda

• Forecasting matters

• Forecasting requirement

• Latest developments

• What you can do to get involved and improve forecasting

Accurate forecasting really matters

• Absolutely critical in enabling Royal Mail Operations to

resource effectively so that it can process and deliver your

and your customer’s mail successfully and to the expected

service standard

• Accurate forecasting leads to a more cost efficient

operation which enables Royal Mail to maintain low

postage prices

• Accurate forecasting enables a more cost efficient

operation along the end to end pipeline

What is new in forecasting?

• Firstly, there has always been a contractual requirement to provide an

accurate forecast and this has not changed.

• During the Autumn 2012 consultation on the future terms of access, customers

acknowledged a need for accurate forecasting and asked for more time to

improve internal processes to support provision of improved accuracy

• The requirement is :

• Provide a 7 day rolling forecast on each working day by Inward Mail

Centre with an estimated breakdown between machinable and manual

items

• Provide a 24 hour forecast by 10am of the items you expect to hand over

on the following working day at each Inward Mail Centre with a breakdown

between machinable and manual items

• Royal Mail has always had the option to not accept or hold mail that is in any

excess volumes above forecast tolerance

• Royal Mail has always had the right to surcharge in cases where actual

volumes handed over are below the forecast tolerance (1000 letters or large

letters or 15% of the number notified in the forecast)

• What has changed is that the surcharge has simply been defined

What is new in forecasting?

• In February 2013, we issued guidance on when the

surcharges would apply:

• if the forecast is out of tolerance but there is no

operational impact at Mail Centre level on a given day

then no surcharge would be raised. If there is an

impact, the contractual terms would apply

• However, even if there was an operational impact, we

would not raise a surcharge if a customer is involved in

a programme of improvement with a deployment date

within a reasonable timescale

• No surcharges were applied in 13/14 in order to provide

sufficient time to customers to improve forecasting

accuracy and deploy their plans

The industry has worked together to improve forecasting

• Royal Mail has worked individually with many of its customers over the past 12

months

• As well as working with individual Access customers, Royal Mail also set up the

Forecasting Working Group with industry representatives from WAG, MPAG

and DMA to:

• share good practice

• develop ideas as a industry

• agree how we move forward together

• This combined activity has resulted in notable forecasting improvements and a

brand new trial

• The 4pm reforecasting approach is beginning to show improvements

• Gradual learning process has led to mutual understanding and consistent

improvements

• The industry is investing to improve forecasting accuracy

Manual large letters are the real pain point of poor forecasting

• From the 1st May 2014, we will apply surcharges in line with the

Contract if forecasts are inaccurate but only in the following situation:

• there is an inaccuracy of manual Large Letter items of >15% per

Mail Centre and,

• the Mail Centre confirms the impact of underforecast

• The surcharge, is £26 per Mail Centre per format. The surcharge will

only be applied if both of the above occur.

• No surcharges have been raised yet:

• We are putting a process in place to confirm operational impact to

customers via the daily client report

• We continue to work with the Forecasting Working Group to keep

everyone informed

Forecasting is getting better and we look forward to further progress

• Understand your own accuracy and forecasting processes

• Talk to us or your industry representatives if you want to join the

forecasting trial

• Work with your customers and suppliers to raise awareness and make

improvements

• Further meetings of the Forecasting Working Group are planned in

September

• Forecasting is on the monthly operational agenda with all our

customers

• If 4pm forecasting trial continues to improve, Royal Mail hopes to

release the data for operational use

• Senior Royal Mail Operations Directors also part of the Forecasting

Working Group

• mutual acknowledgment of forecasting challenges in the market as well as how

critical forecasting is to Royal Mail Operations

• pragmatic approach on surcharging

Summary

• Achieving accurate forecasting has industry wide benefits:

• delivers our customers’ promise

• helps to maintain low postage prices

• creates certainty by reducing incidents which could lead

to increased cost or performance below expectations

which

• helps to keep our customers using mail

Questions

David Dale, Royal MailDean Ryan, TNT Post UKAlistair Ezzy, GI Solutions GroupDanijel Karadza, Royal MailAlex Walsh, DMA

#dmapost

Supported by

TNT Delivery

Andrew Goddard, Commercial director, TNT Post UK

#dmapost

Supported by

CHANGING THE FACE OF MAIL

Content

• Overview – Journey so far

• Our People

• A mailing house view

• E2E versus DSA – Key Differences

• What is our specification

• Indicia

• Software

• Barcodes

• E2E Benefits

Our Journey So Far

April 2012

November 2013

February 2014

March 2014

South West & Central London

Greater Manchester

North West London

Liverpool

545k Households

11 Delivery Units

1000 Posties

667k Households

12 Delivery Units

700 Posties

399k Households

5 Delivery Units

400 Posties

370k Households

6 Delivery Units

500 Posties

Our Journey so far

Over 2500+ new jobs created throughout UK

We deliver mail to over 2 million UK households

34 Delivery Units in London, Manchester &

Liverpool

TNT Posties delivered in excess of 100m items

Our PeopleAwakening Aspiration

Creating Skills For Life

SELF CONFIDENCELOCAL COMMUNITY

GSCE TRAINING TEAMWORKCOMPUTER SKILLS

MANAGEMENT SKILLS

Our people

A short E2E Postie video showing various posties from different backgrounds, what they did before TNT Post and how TNT Post has changed their working/personal life.

http://www.tntpost.co.uk/tnt-posties

A Mailing House ViewE2E v DSA

• Deliveries for E2E made by TNT Posties

• E2E provides tracking to the end delivery point

• Delivery SLA 2-3 days

• E2E Indicia is required instead of DSA indicia.

• Manifest required for end delivery point tracking – auto generated by TNT sort software.

• 2D Barcode required within envelope window for end delivery point tracking

The changes that need to take place...

New E2E Indicia

Production of .SEC file

2D Tracking barcode

A Mailing House ViewWhat is our Specification

A Mailing House ViewIndicia

• TNT would prefer all E2E Mail to be collected with a

compliant E2E Indicia on.

• E2E Indicia to be applied

A Mailing House ViewSEC File - Software

• TNT Sort Software creates the SEC File

• E2E batching.

• 2D Barcode Population

• Software Update Notifications

A Mailing House ViewBarcodes

• TNT Post are flexible on which 2D Barcodes are used, if we are able

to read test samples then we are happy to approve.

• Maximum of 90 characters in the 2D Barcode of which the first 45

characters are reserved for Royal Mail use.

• TNT Post do not define where our 20 characters including #

characters are placed within the remaining 45 spare characters..

Overlay of overall benefits

to the industry

Data Print Enveloping Despatch

Receipt DepotSort to

Delivery Unit

DU Sort and

Delivery

Management

Information

E2E Benefits

1. Tracking from despatch to doorstep delivery

2. Lower cost alternative to DSA for customers

3. Additional discounts for mailing houses meeting the

E2E specification

4. Transparency of performance

5. Real competition in final mile delivery

Data protection legislation changes – implications for mailing houses

Janine Paterson, Solicitor, DMA

#dmapost

Supported by

EU data protection reform timeline

• Jan 2012 -first draft Data Protection Regulation ("DPR")

• December 2012-amendments suggested by the Rapporteur of EC Committee on Civil Liberties, Justice and Home Affairs ("LIBE Report")

• February – May 2013 – Reported that 4000 amendments tabled

• May 2013- partial "compromise" draft from Justice and Home Affairs Ministers ( "CD" )

• October 2013 -LIBE voted on amendments

• October 2013 – Heads of Government meeting

• December 2013 – Inconclusive Justice and Home Affairs Ministers meeting

104

EU data protection reform timeline

• Jan 2014 Civil servants working group meetings continue

• Mar 2014 Inconclusive Justice and Home Affairs Ministers meeting

• Mar 2014 MEPs adopted LIBE report

• May 2014 European Parliament elections

• June 2014 Next Justice and Home Affairs Ministers Meeting

• Nov 2014 New European Justice Commissioner and other Commissioners take office

• Dec 2014 Justice and Home Affairs Ministers agree position

• 2015 Regulation is passed in Brussels

• 2017 Implemented into UK law

3 areas of concern

• Explicit consent required

• An end to profiling?

• Data processors jointly responsible for data

Consent

Consent: Current Position Consent: Proposed Position

- Freely given, specific, informed indication of the data subject’s wishes

- Explicit consent required for sensitive personal data only

-Freely given, specific, informed and explicit indication of data subject’s wishes

-Given either by a statement or a clear affirmative action

- Data controller / data subject relationship to be taken into account

- Burden of proof on controller to demonstrate consent

Explicit consent

• Move from opt-out to opt-in – need explicit consent to send any message, exception existing customers

• Need review language used at point of data collection to ensure that consent is explicit /opt-in

• Think about how you will deal with existing databases –may be unusable

Profiling – a thing of the past?

• No collection of data without explicit consent • No targeted marketing at specific consumer profiles –

less targeted and more generic communication?• Currently held demographic personal data will have to be

erased

Compliance: Data Processor obligations

• Mailing houses, will be subject to these obligations, especially in respect of data security

• Review amount of data being processed, erasure policies and data retention policies – documentation to demonstrate compliance

• Review staff training in data protection.

• Appointment of a data protection officer?

• Risk- based approach to compliance and data protection impact assessments

110

Key lobbying messages

• Data is essential for economic growth

• UK has leading role in EU digital economy

• SMEs particularly affected

• Transparent and responsible use of data is a vital business practice

• In industry’s interests to handle data with care

• Self-regulation has valid role to play

• Regulation will not stop bad players

Key lobbying messages

• The proposed regulation is bad for consumers

• Would damage users’ online experience

• Danger of tick-box culture & unrealistic expectations

• Need a proportionate data regime that recognises that not all data is the same

• Personal data, sensitive data, anonymous/pseudonymous data

• Different levels of protection required

DMA lobbying toolkitwww.dma.org.uk

Contacts

Janine Paterson,Solicitor & Legal Manager T - 020 7291 3356janine.paterson@dma.org.uk

Legal Advice Helplinelegaladvice@dma.org.uk

MPS

John Mitchison, Head of preference services, DMA

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Conclusion and thanks

Mike Lordan, Director of external affairs, DMA

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