Combating data loss after GDPR implementation

For Andrew Devine, director at Beaver Travel, the idea of purchasing a database was recommended by an acquaintance.

“The company we used was called First Data. We drove down to Basildon and met the team and they seemed to fit the bill. They have some well-known companies on their books, so we knew we could trust them.”

Beaver Travel drew up a set of guidelines for First Data to target households that spend more than £20,000 a year on holidays.

“We also told them the areas that we’d like to mailshot to and gave them a catchment zone. We ended up with more than 10,000 names. We also placed a couple of mystery shopper addresses in the catchment area to make sure they were getting the right literature out, which I’d recommend agents do.”

Unlike Travel Designers, Beaver Travel opted for First Data to send out marketing materials on its behalf.

“We paid £2.30 for three mail-outs, which worked out at £23,000 for 10,000 households. As a result of our efforts, we obtained 22 new clients. It may seem that we didn’t get a good return, but we ended up making more than £1,500 in commission from each of the resulting bookings.”

Devine says Beaver looked at its catchment area and realised that potential clients would prefer paper marketing materials rather than emails. He says that agents who are supplying traditional door-drop materials must ensure they are both eye-catching and informative.

“When it lands on a client’s doormat, the last thing they want is 10,000 words telling them how fantastic you are – they just won’t read it. Mail-out two and three have to follow up from the first too, so there is no point in sending something completely different. It’s got to have continuity.”

For agencies on a modest budget, Devine recommends trailing a smaller number of people before increasing the size of the catchment area.

“Also make sure you have a non-disclosure agreement (NDA) if you’re mailing potential new clients yourself. You have to make sure you’re not liable if something goes wrong.”

Farina Azam, partner at Travlaw, offers legal advice to consider when purchasing a database from a third party.

“You would want warranties from the seller [of the database] that the data they are sending is GDPR compliant and that they have obtained consent from the customer.

“When buying in databases, it’s only worthwhile contacting those customers for marketing purposes if [the travel agency] was named at the time of obtaining consent from the customer. The travel agent will have to be named as a third party to whom the customer consents that their data is passed on to.

“Where data is brought in by a third party, the only way to contact people going forward under GDPR is if you can argue legitimate interest or compliance.

“It comes down to how agencies want to be able to contact the customer moving forward. Because they are not existing customers, they’ve only got two options, really: they rely on explicit consent or they rely on legitimate interest – ie, they have a legitimate interest to be able to market to these customers.

“However, they will not be able to argue legitimate interest when they want to email the customer because there are specific rules that apply to email and text marketing under the Privacy and Electronic Communications Regulations.”

Find out more about the Privacy and Electronic Communications Regulations at ico.org.uk/fororganisations/guide-to-pecr