Corporate governance of trade consents and opt-outs
Challenge
A multinational energy sectorwith a complex group of companies and multiple brands, needed to centrally control all of the consents to commercial communications and the advertising exclusions of its customers and potential customers.
The operational and regulatory context was particularly demanding:
- Various internal platforms and relationship channels (webs, apps, private areas, call centres, face-to-face points, digital campaigns, etc.), each collecting consent at different times.
- Need to support million registrations per yearwith very high peaks during large commercial campaigns.
- Obligation to see advertising exclusion systems (Adigital - official Robinson List, and services such as Stop Publicidad) before launching communications, in order to comply with RGPD, LOPDGDD and LSSI.
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Structural problem: there was no single file per personbut multiple fragmented records by society, channel and time, which made it difficult:
- Demonstrate diligence in consent management.
- Respond in a secure and traceable manner to a regulator's request.
The organisation needed a solution capable of:
- Centralise the corporate consent master.
- Unify all the information of the same person, even if it came from different companies and platforms.
- Automatically generate and maintain whitelists and blacklistsThe use of a combination of own consents and external opt-out lists.
Approach
ECIX Tech deployed a joint architecture based on eConsent and eRobinsondesigned to operate as the corporate core governance of trade consents and opt-outs.
The approach was articulated in four pillars:
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Centralisation of the consent master (eConsent)
- Implementation of eConsent as a corporate repository of consents, integrated via APIs with the group's main platforms.
- Definition of a corporate consent catalogue (marketing, data transfer, channels, profiling, post-contractual, etc.) common to all companies.
- Design of a model of single file per personIt is capable of grouping together collections made by different companies, on different platforms and at different times, while maintaining the entire history.
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Omni-channel integration and high processing capacity
- Integration of the consent gateway in the main points of contact (websites, apps, private areas, contracting processes and specific campaigns).
- Optimisation of infrastructure to support million registrations per yearwith the capacity to absorb massive collection peaks during commercial campaigns without degrading service.
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Whitelisting and blacklisting automation (eRobinson)
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Use of eRobinson as an engine for the generation of:
- White listsContacts with valid consent or appropriate legal basis for marketing communications.
- Blacklists and exclusion lists: automatic integration and contrast with Adigital (Robinson List) and Stop Publicidad as complementary layers of exclusion.
- Consolidation of all this information so that each campaign and each external provider could verify, automatically and in near real time, whether a contact was eligible or ineligible to receive commercial communications.
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Use of eRobinson as an engine for the generation of:
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Traceability and due diligence
- Generation and custody of electronic evidence of each consent (date, channel, accepted text, IP, etc.).
- Recording of all inclusion/exclusion decisions and consultations with external lists, in order to be able to demonstrate due diligence with the supervisory authority.
Results
The combination of eConsent and eRobinsonintegrated into the energy group's technological ecosystem, enabled:
- Having a single, consolidated file per personThe consent forms, unifying consents granted in different companies, platforms and at different times, with complete history and fine traceability.
- Centralising the governance of the consent masterwhile maintaining local integration with the systems of each company and channel.
- Automating the generation of whitelists and blacklists for commercial campaigns, combining:
- Consolidated internal consents.
- Enquiries to Adigital and Stop Advertising as complementary public lists.
- Support million transactions per year and extraordinary peaks during campaigns without loss of performance, ensuring that every commercial shipment is made on a sound legal basis.
- Significantly strengthen the advocacy with the regulatorby being able to prove:
- What consents existed, when and how they were obtained.
- What exclusions were applied and how the external lists were consulted.
