Keywords: GDPR, CASL, Consent, suppression, additional field
Managing, storing and using Consent using InterAction and Vuture
There is no single, correct way to manage Consent received from your contacts but this article first addresses two quite different possibilities which you may find helpful, and then makes further suggestions for possible courses of action.
1. LexisNexis recommends using a Quarantine Folder
How:
- Create a new folder called Quarantine.
- Put all your contacts that need consent into it.
- Add several Additional Fields to the folder. For example –
- Consent Received Yes / No
- Date Consent Last Updated
- Consent Notes
As Consent is received, ensure that these fields are updated.
Using FDAs, review the folder nightly. Use FDAs to remove anybody (who has current consent) from the Quarantine folder. Before removing a contact from the folder, add an Activity which says Consented and the date.
In InterAction, when you are setting up a mailing list to send an email, first run a search which says “find anyone in this folder who is also in the Quarantine folder and remove them from the mailing”.
Advantages:
You decide who goes in to the Quarantine folder. Non-EU contacts need not go in, for example. LexisNexis recommend this method, so they will support it.
Disadvantages: You have to remember to run the search identified above, each time you create a new mailing. Alternatively, instead of running the search, you could add the folder ID of the Quarantine to the list of folders which Vuture suppresses automatically, via your Account Manager. Anyone in that folder would then not receive the mailing, automatically.
2. Use Global Additional Fields
A Global additional field can only be set up in the Administrator client of InterAction. However, once set up it can be seen across the whole system, including from within any mailing list.
How:
- Access the Admin client.
- Create a series of Global additional fields such as Consent Received Yes/No, Date Consent Last Updated, Consent Notes, possibly also Consent not Required.
- As Consent is received, ensure that these fields are updated. If you add the Global field view to your Vuture instance you can then pull these fields forward onto Forms to ask for Consent and update responses directly into IA.
As you create mailings in the future you should first filter out contacts with no valid consent (if they require consent). Alternatively you could suppress anyone with no valid consent automatically. You would do this by creating in InterAction a new Folder Dependency Analyser which searches the Consent additional fields every night, and moves anyone with the Global field of "Consent = No" into your suppression folder (usually called Send No Marketing).
Advantages:
Global additional fields can be viewed across InterAction, not just in a mailing list. This could also possibly be seen as a disadvantage by some? You could create a web Profile which shows the Consent status of contacts and displays that status in the web client.
Another advantage is there is no need to add an Activity to the contact, since the Additional Field value will stay on the contact record.
Disadvantages:
In InterAction you will need to do a Search to remove people who haven’t yet consented, or, in Vuture, add a filter to all mailings to filter out those who need to have consented but who have not yet done so. Or alternatively, you need to write and run a Folder Dependency Analyser to find and move people into Send No Marketing on a regular basis.
Further Suggestions
There are other options available to you for managing the recording, storage and checking of Consent to E-Mail, depending on the CRM database you are using. This note addresses just InterAction users.
Suppression Folders
For InterAction clients of Vuture, you will currently already have some suppression folders such as Send No Mailings. This suggestion uses folders in the opposite way – the contact must be in the new folder in order to receive any mailings:
- Create a new folder called “Consent Received”.
- In that folder create an Additional Field to record Date Consent Received. Put contacts into that folder when you get consent from them, and check that folder before sending out any mailing. In other words, when searching for clients to mail, you could add another criterion which would be “And Contact is Linked into in Folder Consent Received”.
Consent Suppression based on an Additional Field Value
When sending email to InterAction contacts you can suppress mailings based on the value of a consent additional field.
This is useful for regions with strict anti-spam laws (such as CASL in Canada) which require all contacts to have provided explicit consent before they can be mailed.
This is a system configuration setting for each InterAction instance you have connected to Vuture and can be found at:
"Admin.System.InterAction.Consent Suppression Additional Field Id" and
"Admin.System.InterAction.Consent Suppression Additional Field Value"
Once set every InterAction mailing will check the value of this additional field and only send to contacts who have the matching value that you set.
Please contact Vuture Support or your Account Manager if you would like to use this functionality.
Global Additional Field
You could create a global additional field to record the consent received, with the date. However, Vuture does not check additional fields as part of its pre-mailing checks. You would therefore need to also create an FDA to check the additional field regularly and move contacts into the Consent Received folder. You would then need to check the Consent Received folder before mailing.
One Click Snippet
For those of you who have purchased the One Click Registration snippet, you could use this option to record Consent on a contact in a list.
- Create a new folder or list called Consent Received
- In that folder create an Additional Field to record Consent Received – Yes/No.
- Link a set of One Click buttons to the Consent Received list. A single button could be used, if you have one on its own. If you only have a pair you could use them as “I Consent” and “I Do Not Consent”.
Preference Manager
Preference Manager is a bespoke web application which has the same look and feel as your web site. It allows your clients and contacts to log in securely at any time and update their personal details and preferences. Fully integrated with Vuture it then manages all suppressions for you.
Ask your Account Manager for further details on the Preference Manager.
New Contacts on your InterAction – managing the future
The suggestions above have dealt with existing contacts on your database. However, new people will be added all the time and you will need a process in place to manage them.
As new contacts come onto the database they could be added immediately to a new folder (called something like “Newly Added Contacts”). A recurring trigger can be set up to examine this folder daily and send an email saying something like:
“Welcome to our database. We would like to send you information about our firm, thought leadership pieces and updates on our industry. However, we only want to send you what you want to hear so please click here to update your preferences.”
The email could link to your Preferences Form, or it could contain One Click buttons.
Contact Support at LexisNexis if you have questions on setting up folders, additional fields or FDAs.