The Annual Report’s central section is a series of case studies. This format is a godsend to the annual report compiler who knows he can’t put out a 15 page report.
Most of them have been anonymised. However, a few have left the relevant party’s names in. Whether this is because the story is better that way, or as an oblique form of commentary is impossible to tell.
I received a number of complaints against Stein Travel about the marketing of a Stein
Travel/MBNA credit card. It transpired that Stein Travel had provided all the relevant
contact data of its customers to MBNA.
When my staff enquired about this, Stein Travel
were of the opinion that they were compliant with
the Data Protection Acts in conducting their
campaign. On their booking form under the heading
of Data Protection it is stated that ‘The information
that we use is for fulfilling our contract as a tour
operator/holiday provider. We may from time to
time, make your information available to companies
within our group.’
As MBNA was not a company within the group and
as marketing a credit card is not the same as
marketing a holiday, it was held that consent from
customers should have been obtained prior to the
marketing of the Stein Travel/MBNA credit card.
When this was brought to Stein Travel’s attention,
they initiated an immediate cessation to the
campaign and undertook to review their entire
procedures relating to storing and processing data
and their marketing practices where promotional
partners are involved.
The case illustrates the importance of being
clear about marketing practices – a credit card,
even a co-branded one, is not considered by me
to be a product or service similar to the
principal business. In these circumstances, the
onus is on the travel agent to ensure that
consent is given for this type of direct
marketing.
As I say, there are a number of case studies. They’re all about a page long, and if you have the inclination I’d recommend a browse through them to see the kinds of things people can get up to.