Direct Mail

Dispelling the Myths of Direct Mail and Cold Lists

By March 23, 2019 5 Comments

Myth 1: ‘You must obtain consent for all data processing for all channels and all purposes!’


True or False?

Answer: False.

There are 6 legal grounds for processing.

The two valid for direct mail, they are:

  1. Consent: Processed lawfully, fairly and in a transparent manner
  2. Purpose of Legitimate interests: except where such interests are overridden by interests or rights & freedoms of the data subject


GDRP states “…The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest. The ICO (information Commission’s Office) agrees.


Legitimate Interests

Make sure you conduct a Legitimate Interest Assessment (LIA).

(Example based on a CHARITY)


  1. Identify your Legitimate interest
  • To seek funds to further your cause


  1. Determine whether the processing is NECESSARY
  • Consider DM to be proportionate


  1. Conduct Balancing Act:
  • Reasonable expectations
  • Limited data to be processed
  • Previous relationship
  • Opt-out available


  1. Document for Evidence


Legitimate Interest Considerations

  • Consent is unequivocal
  • Legitimate interests is open to interpretation

LI removes some subject rights

  • So you must take on extra responsibility for considering and protecting peoples rights and interests
    • Security
    • Data minisation
    • Retention Limits
    • Transparency


Myth 2: ‘We can’t use cold lists’.


True or false?

Answer: False. Yes, you can.

Previous case studies within the charity sector show that 50-60% of responders go onto give a 2nd donation.


Myth 3: ‘We’ll be flooded with complaints!’


True or false?

Answer: Not if you do it right.

-Ensure you are doing your diligence to ensure you are using “clean data sets”.

– Ensure Supporter Services can answer questions quickly and easily

• Original source of the list by name, and type

• Give them details of the Data Owner, so that they can stop other mailings

• Even offer to do this on their behalf

• Offer to suppress them, so that you don’t contact them again

• Tell them about the MPS, TPS and FPS

  • Current level of complaints:
  • “Where did you get my name from?”
  •  Letter returned as a “do not mail”
  •  Level of FPS registrations


Source: WPNC and Royal Mail MarketReach

For more information about how direct mail can help grow your business check out of recent blog.


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