Memorandum submitted by the REaD Group
plc (Waste 52)
1. The REaD Group plc welcomes this opportunity
to submit evidence to the House of Commons Environment, Food and
Rural Affairs Committee inquiry into the Department of Environment,
Food and Rural Affairs Waste Strategy for England 2007.
2. Our comments are restricted to the issue of
producer responsibility relating to the waste resulting from direct
marketing to households and businesses. We believe that better
management of information and data by public, private and voluntary
sector organisations could significantly reduce the amount of
waste caused by direct marketing without unfairly impeding legitimate
activity by commercial and charitable organisations. In particular
we highlight the role that data suppression has to play in meeting
these important objectives.
DIRECT MAIL
3. Volumes of direct mail have grown dramatically
over the last two decades. As the Waste Strategy notes, in 2005
3.4 billion items of addressed direct mail and 13 billion items
of unaddressed direct mail were sent out to UK households and
businesses. Since 2003 volumes of unaddressed mail appear to be
increasing at a rate of 1-2% a year.
4. There is no doubt that direct mail is responsible
for a significant amount of household and
commercial waste. Direct mail is estimated to account
for approximately 550,000 tonnes of the household waste stream,
which is around 4.4% of the UK's annual consumption of paper and
board. In 2003 only about 13% of direct mail was recycled.
5. Therefore, while targeted direct mail
allows firms of all sizes to advertise their products and services
to a wider customer base, it is important for companies, consumers
and the community that this is done efficiently, effectively and
with regard to the environment. More than ever, producers of direct
mail—whether they are businesses or public sector organisations—need
to ensure that they market responsibly.
6. There are today various ways in which
the problem of waste from direct mail is addressed: individual
campaigns (eg junk mail awareness), opt-out and data suppression.
Recent research by Eunomia for DEFRA has explored the approach
taken in other countries, looking at the effectiveness of bans,
levies and increases in postal duties for junk mailing as well
as mandatory measures. One of the key methods identified was data
suppression; a technique which the research suggested could be
expanded across the industry.
7. Data suppression is at the core of the
products offered by The REaD Group, allowing us to meet our commitment
to reduce the effect of the direct marketing industry on the environment.
By ensuring that direct marketing is not sent to individuals who
have moved, to the deceased, or to people who do not want to receive
certain mailings, our data suppression products make direct mailing
more efficient for companies and reduce the amount of material
being produced.
THE BENEFITS
OF DATA
SUPPRESSION
8. Data suppression is the practice of removing
out-of-date or incorrect information from the large databases
which constitute the majority of direct marketing mailing lists.
Many of the information databases held by organisations have been
developed over long periods of time and can quickly get out of
date. As a result, databases often contain the names and details
of individuals who no longer live at the listed address or who
have died. The result is that a huge proportion of mail sent out
will be addressed incorrectly, producing large amounts of waste,
blocking the postal system and causing considerable annoyance
to individuals dealing with superfluous mailings.
9. Inaccurate and out-of-date databases do not
only cause environmental waste. Misdirected direct mail can also
be sent to deceased individuals, sometimes over 10 years after
their death, causing emotional distress to bereaved families.
It can lead to instances of Impersonation of the Deceased (IOD)
fraud. If a criminal obtains a credit card application sent to
an individual who has died that means that the deceased's identity
can be stolen. The Bereavement Register was established
by The REaD Group to eliminate instances of direct marketing being
sent to deceased individuals. In this way, we have helped not
only to stop these wasteful mailings but also tackle identity
fraud and stop the emotional distress being caused to the family
members of the deceased.
EXISTING "OPT
OUT" AND
SUPPRESSION MEASURES,
AND DEFRA
TARGETS
10. Currently the Direct Marketing Association
actively promotes the Mail Preference Service (MPS), an "opt-out"
service. This service aims to stop direct marketing by enabling
consumers to have their names and home addresses in the UK removed
from the databases and lists used by the industry. Today the MPS
has over 3,200,000 subscribers. It is estimated that the MPS eliminates
around 95% of unsolicited junk mail (mail from organisations with
whom you have never had a relationship with), which amounts to
24kg a year in non opt-out households.
11. However, currently the Mail Preference Service
often fails to stop direct mail from organisations you may have
dealt with and provides no middle ground for the consumer to pick
and choose which organisations may send them information. The
MPS is only effective in so far as the individual wishes to opt-out
of all direct mailings. If the individual consents at a later
date to be on the mailing list of a desired product or service,
then it is possible for their information to be reused despite
their previous opt-out.
12. It is possible to adopt a much more
flexible approach to be developed so that individual can enjoy
the benefits of advertising, without the nuisance of junk mail.
Products such as itsmypost.com, set up by The REaD Group,
offers more choice to the individual about what direct mail they
receive, by putting the legal onus on the mailer to stop sending
direct mail.
13. Research suggests that existing data
suppression mechanisms like MPS eliminate between 7,860 and 13,100
tonnes of junk mail per annum. This figure could be significantly
increased if there was more of an effort made to remove people
who are unlikely to respond to direct marketing approaches, using
the methods we describe above.
14. However, an increase in suppression
would not help the direct marketing sector to meet the Government
target relating to the direct marketing sector, since that relates
to increasing recycling rather than reducing the volume of materials
used in the first place. This seems perverse, and is probably
unintended. We therefore call on the Committee to recommend that
the target is amended to reflect the contribution that "non-production"
can make.
CONCLUSION
15. Direct marketing is a valid and effective
way of enabling public and private sector bodies and charities
to contact a large number of people at one time. By using up-to-date
and accurate information for mailings by using the latest data
suppression techniques, as opposed to out-of date lists which
include people who no longer live at the address or who are deceased,
organisations will achieve a better success rate at the same time
as improving their environmental performance by reducing waste
production.
REaD Group plc
December 2007
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