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Ofgem's junk mail database - what can possible go wrong?

21st June 2017

moneysavingexpert.com has reported that the Ofgem is having some issues with its junk mail database project.

To refresh your memory, early last year the Competition and Markets Authority looked into how households can be encouraged to switch energy supplier and get off a standard variable tariff. They reckoned it would be a good idea to force energy companies to hand over the personal details of 'Disengaged Domestic Customers' so that rival energy companies can send them junk mail offers.

Ofgem, which is supposed to roll out the database, has been very quiet about the project and the above-mentioned article doesn't reveal the source of the information*. Of course, they also didn't want to talk to St Lewis – instead they gave him a canned statement:

"We are committed to developing a remedy that works for consumers and encourages greater consumer engagement. We propose implementing a database remedy when we are sure it is secure, protects customer’s data privacy and benefits consumers.

"We have decided to continue testing variants of the disengaged customer database remedy and therefore we are deferring the April 2018 target national rollout date originally set by the Competition and Markets Authority."

My guess is that the problems Ofgem has encountered aren't technical issues. Collecting and sharing personal data with a small cartel of energy companies isn't exactly difficult. There are much harder nuts to crack for Ofgem. To start with, households are supposed to be able to protect their personal data by opting out. How this opt-out scheme would work is unclear – presumably Ofgem would need to send every 'Disengaged Domestic Customer' a junk mail letter to let them know that their personal details will be made available to every energy company in the country and that these companies will use the data to send them special offers unless you jump through some hoops. I doubt that will go down well with the recipients.

Next, there's the issue of how the data will be used. The energy companies aren't allowed to add the 'Disengaged Domestic Customers' to their existing junk mail databases – instead they should dispose of the Ofgem data after an unspecified period of time. That's like putting a child in a sweet shop and telling it that it can't have any sweeties. You know how children howl when you tell them that they can't have something they feel entitled to? That's exactly how marketeers react when you tell them they can't exploit a free personal data treasure trove.

Thirdly, the Competition and Markets Authority has decided that energy companies shouldn't overwhelm 'Disengaged Domestic Customers' with junk mail offers. They reckon people will appreciate unsolicited offers but at the same time they feel people might get pissed off if they get too many of them. This is where the data sharing becomes creepy. It not only means that all the energy companies will know who has been contacted when and by whom but also what the response was. Perhaps more importantly, the Competition and Markets Authority hasn't revealed what it considers a reasonable amount of junk mail offers. The Direct Marketing Association will no doubt have explained to Ofgem that 99.99% of households can hardly contain their excitement when the postman arrives, while sensible people like Bill Hicks argue that marketeers should kill themselves.

And that leads me to the final 'challenge'. What the Competition and Markets Authority and Ofgem see as 'Disengaged Domestic Customers' might in fact simply be 'customers', or even 'people'. The use of ludicrous marketing terms such as 'Disengaged Domestic Customers' suggests that it has never occurred to them that there are might be genuine reasons why people have decided not to switch energy supplier. Perhaps they're with a smaller supplier such as Ecotricity and quite happy with the service they receive. Perhaps they're willing to avoid the hassle of switching to a different supplier by paying a little bit more. Perhaps they feel the whole switching exercise is idiotic (why don't companies simple make sure their customers are on the most suitable tariff?). Perhaps they feel that the energy market is corrupt and that responding to junk mail offers only legitimises its existence. In other words, it wouldn't surprise me if Ofgem has delayed the roll out of the data sharing party because it has found that the response rate to the junk mail offers is abysmal.

As per usual, I've sent a Freedom of Information request to Ofgem to find out more. The request for information will probably be rejected in the name of strong and stable government in the national interest but I'll keep you posted anyway.

* I fucking hate websites that refuse to link to their sources. Even major online newspapers and the Beeb nowadays won't let readers easily get information from the horse's mouth. It's bad journalism as the sources are often specialists blogs that contain much more detailed information then these fucking websites are willing to publish. How did journalists get shouted down by fucking PR and SEO professionals? How can newspapers complain about 'fake news' when they themselves don't enable readers to verify their own sources?

Last updated: 
21st June 2017
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