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Appreciating the desire for a simple comprehensive opt-out scheme

23rd December 2011

I've today received a large stack of papers from Defra about the 'direct mail responsibility deal'. Late November I submitted a Freedom of Information request asking for the release of all correspondence between Defra and representatives of the direct marketing sector relating to the agreement. Although I don't seem to have receive all correspondence it's plenty of information to take in. It's good to see Freedom of Information requests aren't always rejected (I've had less luck trying to get information from Royal Mail – more about that some other time).

The papers sitting on my desk are mainly copies of e-mails and PowerPoint presentations. Defra has had various meetings with the junk mail industry – primarily with the Direct Marketing Association – but at no point did it occur to anyone sitting at the table that you're supposed to take minutes of meetings. I was actually already aware that no minutes existed as I had spoken with Defra about the responsibility deal in May this year. In fact, one of the suggestions I made at the meeting was making future discussions about the voluntary agreement more transparent. I can't see why the general public isn't allowed to know which issues are (and aren't) discussed; where different parties have different opinions; and what arguments are being put forward.

At some point I'm hoping to publish the information I've received in a more or less digestible format. For now I'll just pick out some of the more interesting stuff…

The discussions about the latest responsibility deal started in August 2010. On 17 August 2010 Simon Dawes, Policy Advisor for Defra, sent a paper with initial thoughts on areas of focus for a revised VA [ voluntary agreement, JB ]. Amongst the potential actions listed in the document were designing appropriately worded 'no junk mail' stickers and linking / merging the Your Choice Preference Scheme and Door-to-Door Opt-Out. Both were things I'd suggested in an e-mail I'd sent to Simon Dawes in June 2010.

In his response, Alex Walsh of the Direct Marketing Association stated Defra's paper appeared very useful with only a few areas that might cause some of our members concern. One of these areas must have been Defra's hint at setting up a sticker scheme; after 17 August 2010 'No Junk Mail' signs aren't mentioned anymore. Interestingly, the Environment Secretary did talk about 'No Junk Mail' signs when she announced the details of the responsibility deal on 1 November. Here's what she said:

"[This agreement also] throws down the gauntlet to those companies hand delivering brochures and fast food menus to respect 'no junk mail' signs and only deliver what people want."

To be sure, there's absolutely nothing in the final agreement about 'No Junk Mail' signs. Still, the issue hasn't been wiped off the agenda completely.

The idea to link or merge the Your Choice scheme and Door-to-Door Opt-Out received a more positive response. Matthew Neilson ('Head of Specialised Marketing' for Royal Mail), for instance, welcomed the opportunity to better understand areas of particular frustration for government and consumers and said Royal Mail's Door-to-Door team recognised it had much to learn from Defra. However, an idea to include free local newspapers in the new opt-out scheme for unaddressed mail never got anywhere. An e-mail dated 10 December 2010 mentions that the Direct Marketing Association had asked the Newspaper Society if they were interested in getting involved with the opt-out scheme and that they were reluctant (naturally, the e-mail doesn't mention why).

That the Direct Marketing Association didn't manage to persuade the Newspaper Society to get on board doesn't come as a surprise. Nowhere in the correspondence has the junk mail group anything upbeat to say about the new opt-out scheme for unaddressed junk mail. I suspect they accepted the idea on the condition that Defra would shut up about 'No Junk Mail' signs. In any case, it's clear the opt-out scheme worries the Direct Marketing Association. Here's what Alex Walsh wrote to Defra on 15 June 2011:

"As I said on the phone we would not want to have a single opt out [sic] scheme that covered [sic] both Addressed [sic] and Unaddressed Mail [sic]. Although I can appreciate the desire for a simple comprehensive scheme they are completely discrete media channels - just because you don't want addressed mail doesn't mean that you don't want unaddressed mail and vice versa. We see it exactly the same as the difference between the Telephone Preference Service and the Mailing Preference Service and if people wish to opt out of both addressed and unaddressed mail they will have to register separately for the 2 [sic] schemes.

"As I mentioned on the phone this is a matter of principle for us and I hope that doesn't become a sticking point for progressing [sic] the agreement."

Can you spot the fallacy? Yep… the reason you'll have to register twice if you want to reduce both addressed and unaddressed advertisements is that not everybody will want to stop both types of unsolicited mail.

Convinced?

Defra should maybe have pointed out that it's perfectly possible to give people the choice to register with either one of the opt-out schemes or both. This is what Junk Buster and Stay Private have been doing for some time now, and nobody has ever complained that these websites have made reducing unwanted mail too easy. But then it's obvious the Direct Marketing Assocation's real point of principle is this: they feel that opting out shouldn't be easy.

Voluntary responsibility deals are always a compromise between industry lobby groups and the Government, and Defra decided that the fact that from April 2012 householders will finally be able to sign up to opt-out schemes for unaddressed junk mail online was a decent compromise. Whether it was remains to be seen. It's not yet clear, for instance, whether or not you will actually be able to register online next year. As far as Defra is concerned that's what has been agreed but the Direct Marketing Association hasn't yet announced any details about the new opt-out process. It might be that the new website will only allow you to request an opt-out form online.

Last updated: 
23rd December 2011