The morning post accessing mailmark and tray savings - 25 june


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The morning post accessing mailmark and tray savings - 25 june

  1. 1. Data protection 2013 Friday 8 February #dmadata Supported by The morning post: accessing Mailmark and tray savings Wednesday 25 June 2014, Kings Place #dmapost Supported by
  2. 2. Introduction Mike Lordan, Director of external affairs, DMA #dmapost Supported by
  3. 3. 10.00am Registration 10.30am Introduction Mike Lordan, Director of external affairs, DMA 10.35am Mailmark Charles 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
  4. 4. Mailmark Charles Neilson, Head of business development – Consumer & network access, Royal Mail #dmapost Supported by
  5. 5. Royal Mail Mailmark®
  6. 6. Royal Mail Mailmark® Charles Neilson Head of Business Development, Consumer & Network Access Royal Mail
  7. 7. Mail is alive and well Royal Mail Mailmark® We’re all here today because each have a vested interest in the future of mail
  8. 8. 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®
  9. 9. 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
  10. 10. Mail means higher emotional engagement Royal Mail Mailmark® Source: RM Neuro-Insight, August 2013
  11. 11. 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®
  12. 12. 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®
  13. 13. Investment in mail innovation So Royal Mail have invested to make mail smarter… Royal Mail Mailmark®
  14. 14. 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®
  15. 15. 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®
  16. 16. 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 Sequencing Delivery Sorted Mail Wholesale & Retail eManifests Dashboard Unsorted Mail & Meter Royal Mail Mailmark® Royal Mail Mailmark®
  17. 17. 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®
  18. 18. Royal Mail Mailmark® Mailmark™ Analytics
  19. 19. Mailmark™ Analytics Royal Mail Mailmark® Predicted Delivery
  20. 20. Mailmark™ Analytics Royal Mail Mailmark®
  21. 21. Mailmark™ Analytics Royal Mail Mailmark®
  22. 22.  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?
  23. 23.  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
  24. 24.  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
  25. 25. Royal Mail Mailmark® Mailmark® Proportionate Adjustments
  26. 26. 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…
  27. 27. 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
  28. 28. 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
  29. 29. 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
  30. 30. Royal Mail Mailmark® Mailmark™ - the future
  31. 31. 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
  32. 32.  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
  33. 33. 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
  34. 34.  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 Royal Mail Mailmark® How do you get involved?
  35. 35. Royal Mail Mailmark®
  36. 36. DSA perspective Jennifer Rufus, Head of product development, TNT Post UK #dmapost Supported by
  37. 37. Mailmark update: an operators perspective
  38. 38. 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…
  39. 39. 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
  40. 40. 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
  41. 41. Mailing house perspective Peter Stockton, Mail solutions director, Communisis #dmapost Supported by
  42. 42. Communsis & Mailmark ‘the mailing house perspective’ June 2014
  43. 43. 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
  44. 44. 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
  45. 45. 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
  46. 46. 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!
  47. 47. Questions Charles Neilson, Royal Mail Jennifer Rufus, TNT Post UK Peter Stockton, Communisis #dmapost Supported by
  48. 48. Refreshment break #dmapost Supported by
  49. 49. 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
  50. 50. Letters in trays David Dale, Head of product design, Royal Mail #dmapost Supported by
  51. 51. Could you save money by posting mail in trays? David Dale Head of Product Design
  52. 52. • 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?
  53. 53. • 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?
  54. 54. 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 54 s 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.
  55. 55. 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
  56. 56. 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
  57. 57. …has not changed •No changes to the rules about tray labels, weights etc •Specifications for bags/bundles and trays are unchanged •More details at 57 The technical stuff
  58. 58. 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
  59. 59. 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
  60. 60. For more information 60 • Ask your mailing house • Ask your usual Royal Mail contact • has contact details for ordering trays, and technical information about tray fills
  61. 61. DSA perspective Dean Ryan, Head of implementation, TNT Post UK #dmapost Supported by
  62. 62. Mail in Trays DSA Perspective
  63. 63. 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
  64. 64. 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
  65. 65. 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
  66. 66. 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
  67. 67. 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
  68. 68. Mailing house perspective Alistair Ezzy, Sales director, GI Solutions Group #dmapost Supported by
  69. 69. Trayed Mail Presentation How it affects the mailing house
  70. 70. 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
  71. 71. Why tray?
  72. 72. 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
  73. 73. Operational Difficulties – consumable storage
  74. 74. Operator Differences • TNT minimum tray fill 175 – will reduce with agreement • TNT require all trayed work to be 8 way segged
  75. 75. 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
  76. 76. Environmental Impact  Shrink Wrap  Increased transport - consumables in & collection out  Sustainability of pallets Vs longevity of magnums/cages
  77. 77. Forecasting Danijel Karadza, Network access account director, Royal Mail #dmapost Supported by
  78. 78. Importance of Forecasting in Delivering Excellent Customer Service and Network Efficiencies Dan Karadza Network Access Account Director DMA Postal Event 25th June 2014
  79. 79. Agenda • Forecasting matters • Forecasting requirement • Latest developments • What you can do to get involved and improve forecasting
  80. 80. 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
  81. 81. 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
  82. 82. 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
  83. 83. 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
  84. 84. 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
  85. 85. 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
  86. 86. 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
  87. 87. Questions David Dale, Royal Mail Dean Ryan, TNT Post UK Alistair Ezzy, GI Solutions Group Danijel Karadza, Royal Mail Alex Walsh, DMA #dmapost Supported by
  88. 88. TNT Delivery Andrew Goddard, Commercial director, TNT Post UK #dmapost Supported by
  90. 90. 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
  91. 91. 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
  92. 92. 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
  94. 94. 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.
  95. 95. A Mailing House View E2E 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
  96. 96. The changes that need to take place... New E2E Indicia Production of .SEC file 2D Tracking barcode A Mailing House View What is our Specification
  97. 97. A Mailing House View Indicia • TNT would prefer all E2E Mail to be collected with a compliant E2E Indicia on. • E2E Indicia to be applied
  98. 98. A Mailing House View SEC File - Software • TNT Sort Software creates the SEC File • E2E batching. • 2D Barcode Population • Software Update Notifications
  99. 99. A Mailing House View Barcodes • 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..
  100. 100. Overlay of overall benefits to the industry Data Print Enveloping Despatch Receipt Depot Sort to Delivery Unit DU Sort and Delivery Management Information
  101. 101. 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
  102. 102. Data protection legislation changes – implications for mailing houses Janine Paterson, Solicitor, DMA #dmapost Supported by
  103. 103. 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
  104. 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
  105. 105. 3 areas of concern • Explicit consent required • An end to profiling? • Data processors jointly responsible for data
  106. 106. 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
  107. 107. 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
  108. 108. 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
  109. 109. 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
  110. 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
  111. 111. 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
  112. 112. DMA lobbying toolkit
  113. 113. Contacts Janine Paterson, Solicitor & Legal Manager T - 020 7291 3356 Legal Advice Helpline
  114. 114. MPS John Mitchison, Head of preference services, DMA #dmapost Supported by
  115. 115. 0years 5years 10years 15years 20years 25years
  116. 116. 5.9 million Names and addresses
  117. 117. 14,000New names and addresses
  118. 118. Conclusion and thanks Mike Lordan, Director of external affairs, DMA #dmapost Supported by