Think first – what do I need to achieve the goal?

Today I got yet another email from “Karen”, a subscription promotions robot at a large international industry publishing company, Information Week. The email (and I get them every few weeks) invites me to sign up for a free subscription to their print magazine because I’ve subscribed to one or more of their email newsletters.

The invite reads:

As a valued InformationWeek newsletter subscriber, you’ve been selected to apply for a complimentary subscription to InformationWeek magazine – the source for unique editorial and in-depth analysis for the leading business technology buyers. Others pay for this must-have publication but if you take a few minutes to apply and qualify now, you will NEVER be billed.

Now I LOVE dead tree publishing. I like being able to read things that won’t need to be plugged in if I leave them down and walk away for an hour. And I LOVE industry publications becasue I can clip the good bits and recycle the rest. More than that, as a small business owner, I abso-fricking-lutely ADORE anything that is free.

So, today I decided I’d actually try to enrol for the subscription. Note that there is nothing in the invitation that tells me that the offer is restricted in any way. When I click through, I spend 5 minutes filling out the form only to find out from the “COUNTRY” drop down on the form that I can’t get the offer if I live outside the USA or Canada, frankly I wind up being a little bit peeved.

When you go to their website in fairness the restriction is mentioned – so why not in the EMAIL!!

So, what happened here?

Well, I’m guessing that Information Week have pulled data about their email list subscribers to market products to them. I can’t remember if the subscription to the newsletters I get actually had a field to capture my country. I tend to give only the minimum necessary data to achieve my objective when signing up for things on-line. I’d dearly like to take a look at the forms again, but Information Week gives this error when I try to access their newsletter subscription pages or their Information Alert subscriptions today.

So, I must hypothesise that either:

1. I gave Information Week the data that I live in Ireland and they have chosen to ignore that when generating an email campagin
2. I didn’t give Information week the information because I didn’t want to and they are pulling records where “Country” is NULL as well as “is in (‘USA’,’Canada’).
3. Information Week never asked the question in the first place and don’t actually know where I live but thought they’d email me any way.

Either way, this is a #datafail because Information Week is making decisions on incorrect information, incomplete information, or information that they could never possibly have. Certainly I don’t feel “valued” in any meaningful way as they’ve managed to waste my time.

In the context of EU Data Protection rules, the concept of “Adequate, Relevant, and not Excessive” applies here, and is a useful benchmark for organisations assessing their planning around data and its use regardless of where they are based.

The EU rules basically mean that, for a given specified purpose, the information you are processing must be enough to achieve that goal, relevant to that goal, and not more than you would need to be processing to achieve that goal. This is a similar concept to the HIPAA rule around “minimum necessary data for a given purpose”.

So, if we assume that Information Week’s goal is to secure print subscribers in North America (US/Canada), what information woudl they need to have to target that? Well, at a minimum, knowing what current subscribers are resident in the US or Canada might be helpful and relevant.

Would having a list of subscribers without that data be helpful? Probably not. It would not be adequate to achieve the purpose. So, at the very least, a big health warning would need to be placed around the potential conversion rates from that marketing campaign.

Even more fundamentally – if there is a restriction on the offer, INCLUDE THAT FACT IN THE EMAIL!!

When advising clients I always suggest that they think about the objectives for which they are processing data, in particular personal data but not limited to that. If they have enough data (ignoring other quality issues for a moment) to achieve that objective then they should proceed, if not they need to reassess their objective and either abandon the processing (saving money in the process by not doing work that cannot achieve value) or change the goal to something they can achieve with what they have.

In the context of Personal Data, the mantra to clients is “if you don’t have enough information to do the thing you told people you would do, then you need to either figure out how to get the missing 20% or dump what you have because it invites regulatory penalties for breaches of the Data Protection rules and incurs costs storing, securing and managing an asset that will never be able to move to the ‘Apply/Add Value’ stage of the Asset Life Cycle.

As for Information Week… the fact that I’ve managed to fill a post about Information Strategy based on the irritation their email caused me just about makes up for the 10 minutes of my time they cost me earlier today.

Just about.