DTI Sales Promotion Guidelines: a proposed position on issues
DTI Sales Promo.on Guidelines: a proposed posi.on on issues Jane7e Toral August 17, 2011
Posi.on #1 • Need for integrated guideline or one Department Administra.ve Order – Too many DAOs • As it now covers no purchase required promo.ons, it is apt for name to reﬂect such change. From DTI Sales Promo.on Permit Guidelines to: – DTI Sales and Marke.ng Promo.ons Permit Guidelines – DTI Marke.ng Promo.ons Permit Guidelines – Covers both oﬄine and online • as it is now happening, oﬄine promos gets plugged online and vice-‐versa. • Add new sec.ons to describe online nature for contest, raﬄe, games, premium, redemp.on, discount.
Posi.on #2 • Recognize that individuals can run contest – Use the term “individual” rather than “bloggers” to be all encompassing. • Avoid impression of discrimina.ng or giving preferen.al treatment that may alienate other professions – whether proﬁt genera.ng or not. • Exemp.on apply to individuals should also apply to business to avoid “discrimina.on” accusa.on. – Set minimum promo prize rule on a per promo.on rather than annual • Promos where prizes is below P5000, no need for permit (whether individual or business) – However, must comply to DTI standards on promo.on process. • As there is no way for DTI being able to monitor promo spend annually. – Harder for dispute resolu.on management if main point of challenge is focused on spending.
Posi.on #3 • Data privacy – Ensure that data of consumers joining promo.ons are protected. • MOA between par.es should have clear provision on data ownership. • Terms and condi.ons of promo.on should clearly state how promo.on joiners data is used. – Iden.fy par.es who have access to contest joiners data whose aﬃlia.on is clearly stated. • Unauthorized use of promo.on joiners data can make the person and companies involved liable under DAO #8 and E-‐ Commerce Law.
Posi.on #4 • DTI Sales Promo.on Permit Process needs to be compliant with Republic Act 8792 or the E-‐ Commerce Law – Accept online applica.on. – Issue approval. – Accept online payment. – Process covered by a guideline.
Posi.on #5 • Explore self-‐regula.on – Sales Promo.on Permit and Dispute Resolu.on to be handled by recognized 3rd party consor.um associa.on in the future. (e.g. 4As, IMMAP, PRA, PANA, CUG)