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Out of the compliance ghetto – into the fire?

Posted on: Thursday 10th of April 2014

Slowly but surely, personal data – how organisations collect it and use it – is becoming a brand issue. Whether its press articles highlighting practices which surprise and dismay consumers and citizens, or the pressure of forthcoming EU data protection legislation, organisations are realising that personal data can no longer be relegated as a ‘back office’ issue, something that works silently and invisibly in the background with no one, except a few dedicated experts, paying much attention to it.

Typical of the changing mood are these comments from Unilever’s global privacy officer Steve Wright.  Speaking at a recent conference he said that “growing the trust relationship comes back to consent and transparency, which are key to enabling businesses to do more with customer data”.

Chris Combemale, executive director of the Direct Marketing Association, similarly notes that “trust and privacy are becoming key components of brand equity”.

Gear shift

For many organisations this is a bigger challenge than seems at first sight.

It requires a mindset shift from compliance to brand thinking. To see the dangers of not getting this right consider the unfortunate tale of MP Maria Miller who came across as knowing everything about what’s inside or outside the rules and nothing about broader public perceptions about honesty and openness.

It requires multiple operational changes. What we say about personal data needs to be included within communications strategies. Terms and conditions need to be revisited, not only for their detailed content but also for their presentation. Day to day practices need to be considered not only from a narrow compliance point of view but from a broader brand trust point of view.

It may even require a sacrifice of income. Selling data on to third parties may generate additional profit in the short term but if it damages the brand longer term, is it worth it?

All of this means there are now many more cooks in the personal data kitchen, each one of them bringing their own special perspective – and, probably, many initial differences of opinion and priority. The more cooks there are, the greater the danger of spoiling the broth – which is why personal data issues are rising so rapidly up organisational hierarchies to become a C-suite issue. Many things need to be thought through. Carefully. Many different activities need to be coordinated.

Still only half the story

Welcome and overdue as this shift is from ‘compliance ghetto’ to ‘brand issue’, there’s a risk that newly emerging strategies around personal data still miss the point.

Unilever’s Steve Wright hits the nail on the head when he says building trust around personal data is “key to enabling businesses to do more with customer data”.  The question, however, is to do what with customer data?

The dominant mindset right now is that it’s all about permission – earning customers’ consent to collect and use data … “to do what we’ve always done”.  It’s an attempt to maintain the status quo when, in reality, the very reason why personal data became a brand issue in the first place is because the ground is shifting in more fundamental ways.

When push comes to shove, customer data can be used to do two things.

1. help organisations collecting the data to manage their affairs better
2. help individuals whose data it is to manage their affairs better.

A positive opportunity

Organisations that focus solely on point 1) are missing the real significance of today’s trends. Slowly but surely, people – consumers, citizens – and policy makers and regulators and the media and entrepreneurs and investors and some large organisations themselves are realising that personal data has as much potential use-value to individuals as it has to organisations.

This is an opportunity to use data in new ways, to do new things, to create new services and new dimensions of value. It’s where trusted data sharing and innovation and growth join at the hip.

So: by all means make personal data a brand issue. As we said, that’s long overdue and a challenge in its own right. But in the process ask not only ‘what values does the brand stand for’ (e.g. openness and honesty) but what value does the brand stand for? Is it just more of the same? (In which case, are we undertaking all this activity only to still lose competitive edge?) Or is it a new dimension of value – a means to genuine strategic, competitive advantage?