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Moya Greene: uncontrollable and potentially open to abuse

24th August 2013

A constituent of Gareth Johnson MP has kindly forwarded me a letter from Moya Greene. The constituent wanted to know whether or not Royal Mail might consider replacing the Door-to-Door Opt-Out with a sticker scheme. In her letter, Moya explains why respecting 'No Junk Mail' stickers isn't on Royal Mail's agenda.

It shouldn't surprise you that Royal Mail won't consider changing its junk mail policy. It's no secret that the junk mail industry as a whole is horrified by the idea of people putting anti-junk mail signs on their door. This was demonstrated quite nicely in August 2010, when Defra tried to discuss appropriately worded 'no junk mail' stickers as part of a voluntary producer responsibility deal between the department and the industry; Defra was quickly told where they could stick their stickers.

What we didn't know, until today, was why the junk mail industry gets so upset about sticker schemes. Over the years I've asked Royal Mail a couple of times why the company instructs postmen to ignore anti-junk mail signs but I never got a response. As mentioned, Defra didn't get an explanation either; they were simply told to get lost (which they duly did). It's somewhat surprising, then, that Moya Greene Herself responded to the letter from Gareth Johnson's constituent.

Revealed - why Royal Mail gets upset about 'No Junk Mail' stickers

Moya's letter cites two reasons why Royal Mail is not able to acknowledge the unofficial 'no junk mail' stickers on some letterboxes:

  1. Royal Mail is not in a position to determine what a particular consumer considers 'junk mail'. One person may object to advertising material from mortgage lenders, but appreciate offers from their local supermarket, whilst their neighbour may have a completely different view. This has to be an informed choice by the consumer, not a carte blanche decision by Royal Mail, which is why we offer the formal 'opt out' service. By signing up to this service, consumers are aware of all the material they will no longer receive.
  2. A number of public services, including both central and local government, make use of the Royal Mail Door to Door service to distribute public information and election materials. Our research tells us that most people want to receive this type of literature but observing an unofficial 'no junk mail' sticker could easily deprive them of this opportunity. Again, one person's 'junk' is another person's information.

Moya's letter concludes that Royal Mail takes its obligations very seriously but that it has no plans to introduce a scheme which would be informal, uncontrollable and potentially open to abuse.

The Canadian experience

Moya's arguments are invalid and she fails to address the many problems with the company's Door-to-Door Opt-Out (see the Guide for a tirade). Before setting out the case against Royal Mail's position, though, I should point out that Moya's response fails to mention something much more significant; her previous job.

Much more significant? Hell yes! From May 2005 to May 2010 Moya was Chief Executive of Canada Post. And guess what… Canada Post doesn't operate an opt-out scheme for unsolicited leaflets and the company has a long established policy of respecting letterbox stickers. Canadians who want to stop unsolicited leaflets don't need to ask for a paper opt-out form; nor do they have to wait six weeks before the postman stops delivering leaflets. Instead, they're allowed to put a sticker on their letter box. Canada's Post's junk mail policy is explained in two simple paragraphs on its web site:

To stop receiving unaddressed advertisements such as coupons, flyers and newspapers, free magazines, catalogues, and municipal service notices (e.g. schedule of snow removal, changes in garbage pickup, etc.), place a note in or on your mailbox stating that you do not wish to receive Unaddressed Admail.

The only unaddressed materials that we will continue to deliver are some community newspapers, as well as mailings from the House of Commons, provincial chief electoral officers, municipal electoral offices and Elections Canada.

You can see where this is going. Canada Post's policy is easy to understand, easy to administer and appears to work well. Royal Mail's policy is difficult to understand, a nightmare to administer and appears to be dysfunctional. Yet, Moya is arguing that sticker schemes are uncontrollable and potentially open to abuse. Clearly, something can't be reconciled here. Moya has been telling porkies; either to the good people of Canada, or to us Brits.

Logic is a wonderful thing

I reckon it's fairly obvious that it's us Brits who got Moya's porkies. Let's look at her first argument again and establish how valid it is:

Royal Mail is not in a position to determine what a particular consumer considers 'junk mail'. One person may object to advertising material from mortgage lenders, but appreciate offers from their local supermarket, whilst their neighbour may have a completely different view. This has to be an informed choice by the consumer, not a carte blanche decision by Royal Mail, which is why we offer the formal 'opt out' service. By signing up to this service, consumers are aware of all the material they will no longer receive.

The statement that Royal Mail isn't in a position to determine what you consider to be 'junk mail' is true. It's also misleading. All Moya is saying is that Royal Mail, or the self-regulating junk mail industry in general, doesn't have a definition of 'junk mail'. Moya could change this today! Royal Mail could adopt the same definition used by Canada Post (she never objected to it when she was in charge of the company). It would mean that all the vague warnings about stopping unsolicited leaflets could finally be deleted from Royal Mail's web site and replaced by a text similar to the one used on the Canada Post web site. Slapping a sticker on your door would stop all unaddressed mail items distributed by Royal Mail, perhaps with the except of some non-commercial mail items.

Similarly, Moya's statement that stopping junk mail has to be an informed choice is both true and misleading. The reason why people who put a 'No Junk Mail' sign on their door aren't making an informed decision isn't because different people define 'junk mail' differently. Rather, the reason is that Royal Mail has so far failed to come up with a definition of 'junk mail'. If only the likes of the Royal Mail and the Direct Marketing Association could tell us how they define unsolicited, unaddressed advertising mail they could abolish the Door-to-Door Opt-Out. Moya's suggestion that the opt-out scheme ensures that people make an informed choice about stopping junk mail is complete and utter nonsense.

The second statement merely repeats all the above in a slightly different way:

A number of public services, including both central and local government, make use of the Royal Mail Door to Door service to distribute public information and election materials. Our research tells us that most people want to receive this type of literature but observing an unofficial 'no junk mail' sticker could easily deprive them of this opportunity. Again, one person's 'junk' is another person's information.

That's right, Royal Mail's research shows that most people do want to receive non-commercial information and don't want to receive commercial leaflets. How is this stopping Moya from endorsing a sticker scheme? She could do exactly the same as she did when she ran Canada Post; respect letterbox stickers and tell people that their postie will still deliver the odd non-commercial, unaddressed mail item. Or, if that's too difficult for Royal Mail they could follow the example of TNT Post in the Netherlands. In Holland, letterbox stickers will simply stop all unaddressed mail items, whether they're commercial or non-commercial. It's really not that difficult to set up a sticker scheme. Just explain to people what the rules are and they'll make a decision about whether or not they want to put a sticker on their door.

A blue print for Moya

In a funny way, every argument mentioned in the letter to Gareth Johnson MP is an argument in favour of scrapping the Door-to-Door Opt-Out and respecting 'No Junk Mail' stickers. I'm really not sure on the basis of what logic Moya arrives at the conclusion that sticker schemes are necessarily informal, uncontrollable and potentially open to abuse. Is she saying that she presided over a scheme that was uncontrollable and potentially open to abuse while she was the Chief Executive at Canada Post?

I suggest Royal Mail adopts the same definition of 'unaddressed advertising mail' as Canada Post. A 'No Junk Mail' sticker on your door will prevent all unaddressed mail, with the exception of some clearly non-commercial mail items, such as leaflets from central government and information about elections. To make up for the porkies Royal Mail could give the sticker scheme a boost by producing it's own sticker. I designed one for them a while ago, based on the company's Neighbours Not Trusted sticker. I wouldn't mind them using the design, even if it would kill of me own sticker business.

Last updated: 
24th August 2013