This month more than 5 million pieces of 'direct mail' will be sent to the deceased, according to propaganda commissioned by Millennium ADMP Ltd. It's therefore important that marketers buy the Mortascreen deceased suppression file from Millennium ADMP Ltd.
I don't think marketers will ever grow tired from commissioning junk research. Marketing is about manipulating, and presenting banal marketing exercises as 'scientific research' has unfortunately become a standard trick in the marketer's repertoire. Sadly, it works. Even though Millennium's research is 100% unverifiable there are plenty of marketing publications that have copied the company's self-congratulatory press release almost word-for-word.
Anyway, I'm jumping to conclusions; you're probably dying to know more about Millennium ADMP Ltd and deceased suppression files...
As I understand it Millennium is the company behind the Deceased Preference Service; one of two companies that produce these magical deceased suppression files. Put simply, Millennium collects the names and addresses of people who have died and sells these details to junk mailers so that they can remove people who have died from their mailing databases. Millenium's suppression file is called Mortascreen. It's competitor is the Bereavement Register (run by the Read Group Plc).
Selling dead people's personal details is Big Business and there's an increasingly fierce competition in the market for deceased suppression files. Only a couple of weeks ago the Advertising Standards Authority dealt with a complaint from the Bereavement Register against Millennium. An advert for Mortascreen had claimed that the suppression file is larger, more up to date and more reliable than any other suppression file. The claim could - surprise, surprise - not be substantiated and so the Bereavement Register's complaint was upheld. It was a welcome victory for the Bereavement Register as Millennium had won a similar complaint against the Bereavement Register only two weeks earlier. An advert for the Bereavement Register had claimed that it was the market leader for "fast accurate deceased suppression data" - another claim based on the flimsiest of evidence.
We can conclude, then, that neither Millennium nor the Bereavement Register are likely to be nominated for the 2010 Honest Marketing Award. And I reckon it's also justified to be more than just a little bit skeptical about Millennium's unverifiable research. Really, it stinks like an egg sandwich. You'd expect Millennium would have gathered by now that it shouldn't make claims that can't be substantiated, yet the only sensible thing we can say about the company's research is that it can't substantiated. To put it more bluntly: the study is cheap marketing masquerading as scientific research. The only reason why Millennium commissioned the 'study' is so that the company could urge junk mailers to buy its Mortascreen suppression file.
As mentioned, there's nothing new about this. In fact, Mortascreen is only copying the example of the Bereavement Register, which has been insulting science for many years with its claim that 80 pieces of 'direct mail' are sent to people who have died in the first twelve months following death. It was only while writing an article about junk mail and the deceased for Stop Junk Mail's Guide to Stamping Out Junk Mail recently that something struck me about the latter statistic. If it's true that the average person is sent 80 pieces of addressed junk mail in the first year following death then dead people actually receive more addressed junk mail then people who are still alive. When I contacted the Bereavement Register about this they readily admitted that the calculation had been done on the back of an envelope. To be fair to the Bereavement Register, they had taken into account various variables, such as the fact that elderly people (who make up the bulk of the deceased) are sent more junk mail than other age groups. Nevertheless, the statistic is rubbish.
Why do the Bereavement Register and Millennium exaggerate the amount of addressed junk mail that is being sent to the deceased? One explanation is that they got a commercial incentive to do so. Marketers are more likely to spend money on deceased suppression files if they perceive junk mail sent to the deceased as a serious problem. Another, more favourable explanation is that the Bereavement Register and Millennium feel so passionate about stopping junk mail sent to the deceased that they tell little porky-pies to further their cause. The latter would be an unwise but understandable marketing strategy. Every junk mailer should make a real effort to prevent its advertisements are sent to people who have died, and anything that encourages them to 'clean' their mailing databases should be welcomed.
I suspect it's mainly money that drives both companies. The dodgy marketing techniques used by Millennium and the Bereavement Register are rather sinister. To the general public they market themselves as some sort of charities helping to reduce junk mail sent to deceased loved ones but behind the scenes things aren't so hunky-dory. There's a lot of money in trading dead people's personal details, or so it seems, and both companies are quite aggressive in their quest for a greater share of the deceased market. Sadly, it's very difficult to see how all this competition benefits the 'consumer'. I mean, the Bereavement Register and Deceased Preference Service both claim to collect the details of 95% of all deceased people. You'd expect that their efforts would at least half the amount of addressed junk mail sent to deceased. Yet, their own figures suggest that they don't come anywhere near this.
Wouldn't it be better to stop treating the personal details of dead people as a commodity and set up a system that actually works? Make it a legal obligation for junk mailers to use deceased suppression files and fund the system by introducing a small levy on each and every piece of addressed junk mail and you got the whole problem of junk mail sent to the deceased sorted. When I put that point to the Bereavement Register they got rather unfriendly with me, and when they realised they couldn't win the argument they decided to simply shut up. To put them to shame, the entire correspondence I've had with the company about its suppression file is below. Suffice to say that after my last e-mail the Bereavement Register did not come up with any argument in favour of treating the personal details of the deceased as a commodity.
15 June 2010
From: Stop Junk Mail
To: The Bereavement Register
Dear Sir, Madam,
I'm writing an article about how people can stop junk mail sent to a deceased relative or friend and was wondering if you could clarify something for me.
At the moment there are three services that people can use to reduce advertising mail sent to someone who has died; the Mailing Preference Service (MPS), The Bereavement Register (TBR), and Deceased Preference Service (DPS). To some extend all three services rely on the co-operation of the senders; the MPS can only stop advertising mail if the sender is a member of the Direct Marketing Association (DMA) and the TBR and DPA can only do so if senders purchase a suppression file.
I've read on your website that TBR currently 'cleans' 75% of direct mail. My questions are about the remaining 25%, that is, about what people should do if a sender is not a member of the DMA and does not buy a deceased suppression file:
First of all, what would you advise people to do in this situation? My advice would be to contact the sender(s) directly but I also read on your website that you encourage people to forward any mail-outs received after six weeks time to your office. If the sender is not one of your clients, are you able to force the sender to take the person's details off its mailing list, or do you simply bring it to the sender's attention (perhaps hoping they will become a client)?
A relating query is: are marketers obliged to remove the details of someone who has deceased if they are asked to do so? For instance, if I write to a sender to notify them of the death of a relative and they fail to take the person's details of its mailing list, would they have breached the Data Protection Act? I suspect the answer to this query is 'no', in which case I have a supplementary question. One of TBR's 'selling points' to marketers is that buying the suppression file will "provide Data Protection Act compliance". Does this imply that a company who purchases the suppression file but fails to clean its mailing list is in breach of the Data Protection Act?
Finally, if someone has registered with all three available services and continues to receive advertising mail from a particular company, do you agree that they should contact the MPS in the first instance? The reason why I would give this advice is that the MPS has a formal complaints procedure in place (which can ultimately result in the complaint being forwarded to the Advertising Standards Authority) and because it is possible for people to find out if the item they have a complaint about should have been prevented by the MPS. (As you will be aware the DMA publishes a list with members on its website; although it is usually very difficult to find out if a mail item should have been prevented by the service there is at least a possibility in theory.)
For information, the article will appear on www.stopjunkmail.org.uk, a website aimed at giving free and independent advice on reducing unwanted mail. It's a popular website and I do get a fair amount of e-mails and telephone calls from people receiving lots of advertising mail addressed to deceased relatives; I'm keen on adding detailed (and accurate) information about this issue. Any help would be much appreciated.
Regards,
Etc.
15 June 2010
From: The Bereavement Register
To: Stop Junk Mail
Dear Mr Rijkhoff,
Thank you for your email. You make a lot of interesting points, many of which we can answer and would like to discuss with you further. It may be easier to have a chat with one of our Directors who is up on Data Protection issues and knows the best ways for consumers to protect themselves from unwanted direct mail.
[Name deleted] is our Data Development Director and will be around tomorrow. If you give me your telephone number and times you'll be around, I'll ask him to give you a ring.
Kind regards,
[Name deleted]
Head of Group Marketing
14 July 2010
From: Stop Junk Mail
To: The Bereavement Register
Hello [name deleted],
A couple of weeks ago we spoke about the TBR. I finally got round to writing the article; it can be found at www.stopjunkmail.org.uk/guide/deceased.php. Please do let me know if any of the facts are wrong. Comments on my opinions (in particular about 'statistics and marketing') are of course equally welcome.
Best regards,
Etc.
16 July 2010
From: The Bereavement Register
To: Stop Junk Mail
Dear Mr Rijkhoff,
Thank you for forwarding the link to your article.
I feel I need to draw your attention to a couple of points which are inaccurate:
The company does not regularly send press releases to local newspapers stating how many pieces of junk mail were sent to the deceased - we have not released such a press release in the past 2-3 years.
You also appear to be confusing The Bereavement Register with It's My Post. There is no charge to register with The Bereavement Register. There is a £5 charge for It's My Post which enables you to manage the post you receive by emailing Section 11 notices to direct mail companies. However there is the option to use the free postal element of this service which allows you to download and print off Section 11 letters and send by post.
The Bereavement Register is recommended by the funeral services industry, registrars, the NHS, govt departments, the police, coroners offices to name just a few. They all understand the commercial aspects of the service - but without this The Bereavement Register would not exist and neither would the benefits to the bereaved. I am concerned that your inaccurate representation of the service may mean people are less inclined to register - and the post will continue.
I would appreciate it if you could retract the false accusation made on your website. We have dealt with your enquiry professionally and promptly - providing you with access to the information you requested. It is now your responsibility to ensure you report the facts correctly and fairly without sensationalism.
Regards,
[Name deleted]
Head of Group Marketing
19 July 2010
From: Stop Junk Mail
To: The Bereavement Register
Dear Louise,
I'm sorry to hear you feel the article is not entirely accurate. Let me start by saying that, in general, the article doesn't advise or argue that people should't register with TBR. The advice is, quite clearly, that people should do four things to stop unsolicited mail sent to a deceased friend or relative: they should contact the senders directly and register with TBR, DPS and MPS. Rather than a decrease in the number of people registering with TBR I would expect an increase. The 'Guide to Stamping Out Junk Mail' didn't contain any information about how to stop unsolicited mail sent to the deceased; it now recommends registering with TBR.
Re the press releases, from what you say I understand that you don't question my concerns about the press releases that the REaD Group / TBR used to sent to local newspapers as such. Obviously I don't have much information about the TBRs marketing strategy and I wasn't aware that this type of marketing has now been abandoned (or has it only been suspended?). I have rewritten the relevant paragraph so that it's clear that this marketing strategy that was adopted in the past. I do feel that it's right and proper to still explain why I object to such marketing strategies, if only because it touches on one of the main arguments in the article (namely that deceased suppression files should not be a commodity).
Its My Post is only referred to in the context of the above mentioned press releases; I think it's sufficiently clear that the article is not about Its My Post (its not even mentioned by name). The reason for making a link to the promotion of Its My Post in the press releases is of course that it's another example of how reducing unsolicited mail is increasingly a commercial activity. That there's no charge for registering with TBR is mentioned in the first paragraph about TBR and DPS: "Registering the details of a deceased relative or friend is free".
You mention in your e-mail that TBR is recommended by many organisations. I should perhaps emphasise that the article doesn't say that TBR is all bad and that the world would be a better place if it didn't exist - far from it. Towards the end of the article I do explain that I feel it's unfortunate that TBR was set up as a commercial enterprise. My argument is that TBR would be more effective if it had been set up as (or were to be transformed to) a non-commercial service instead. That many organisations currently endorse TBR is great but it obviously doesn't counter this argument. It could well be the case that all the organisations that now recommend TBR (and presumably the DPS and MPS as well) would recommend a non-commercial service if only one existed. Your argument that the bereaved would not have an opt-out service available to them at all if TBR didn't exist is invalid for a similar reason; it's perfectly thinkable that government would have imposed a (non-commercial and obligatory) opt-out service on the industry to address this very serious problem, or that a not-for-profit organisation would have done this. In that sense TBR may even be hindering a more effective solution.
Of course, all this is not to say that people shouldn't register with any of the three existing opt-out services (and again, nowhere in the article do I raise that suggestion). What I'm suggesting is that the bereaved could get a better service than they are getting at the moment. The commercial aspect of TBR may be 'understandable', it is not therefore desirable.
To suggest that there are possible alternatives is quite different from making an "inaccurate representation" or "false accusation". I can understand that you're not happy that the article suggests that TBR may not be the best possible solution. However, it does not follow that the argument is therefore 'incorrect', 'unfair' and 'sensationalist'. The article gives clear and detailed advice to people who have been bereaved - more than is to be found on any other website, including the TBR website - and goes on to express my thoughts (presented as such) on junk mail statistics, marketing and the commercial / industry-led nature of opt-out services such as TBR.
To conclude, I am sure that, within the constraints of running the scheme commercially, TBR is genuine in its attempt to help people who have been bereaved. What I'm questioning in the article is whether or not commercial and/or industry-led opt-out schemes are the best solution for the bereaved. I don't expect us to agree on this point but am happy to consider any arguments against running opt-out services such as TBR non-commercially. The only reason that no such arguments are presented in the article is that I have not heard a single one.
Regards,
Etc.
