BPA Worldwide Blog

BPA requires recording of teleservices calls beginning January 2008

By Glenn Hansen, President and CEO, BPA Worldwide

I look forward to receiving your comments.  To send one, click on COMMENTS at the end of this blog.  I will review all comments before posting.  If you wish to remain anonymous in the posting, please so indicate in your comment, but of course, this blog will be more robust if we all identify ourselves.

I have created this blog to foster an open dialog on the matter of recording solicitations by telephone of requests to receive magazines.  I have added information below posted on our web site to start the discussion.  Please write back and present your issues and questions so that we may make sure all points of view are heard and considered.

Prospectively, I envision that BPA will use blogs for dialog on circulation audit rules we are considering.  I would also like your point of view on this.

Pardon the length of this introductory BLOG, but I thought all the information necessary to start a fully informed discussion.

On Wednesday September 13th, I presented to the American Business Media Circulation Committee on this subject.  That presentation will be added to and then presented as a free webinar.

Here now is the text to set this up:

At its meeting in December 2005, BPA Worldwide’s Board of Directors passed a rule that will make recording for outbound business publication circulation telemarketing efforts mandatory as of January 1, 2008.

The Board vote was the culmination of extensive discussion of all potential benefits and “downsides” among all of BPA’s worldwide committees and advisory boards comprising media owner, advertiser and advertising agency representatives, as well as the Telemarketing Managers’ Advisory Committee.

Several critical realities drove the ultimate decision:

Fact: B-to-B publications are more reliant than ever on telemarketing as a circulation source. Indeed, telemarketing has eclipsed written sources, to become the number-one source of B-to-B publication personal direct request subscriptions. According to the latest American Business Media Circulation Committee analysis of Paragraph 3B circulation statement data, for 2004, telemarketing accounted for 26.9% of total circulation across audited publications, versus written sources’ 24.6%.

Fact: Advertisers and media buyers are more focused than ever on accountability and demonstrating hard return on investment for their advertising dollars.

Fact: Over the years, the advertising community has not been receptive to publisher proposals to allow telemarketed subscriptions to be incorporated with “written direct request” for purposes of reporting on the circulation statement. Thus far, advertisers/media buyers have continued to affirm that they want the disclosure assurance of having telemarketing broken out as a separate source. However, key advertiser and media buyer executives on BPA’s Board and advisory committees have indicated that universal outbound recording will represent an important step in providing the quality control assurance that they would require as a prerequisite to approving a revised reporting format in which written, telemarketing and, potentially, Internet/email are consolidated.

Fact: Alarming increases in identity theft and concern about potential misuse of personal information are creating growing resistance to requests for such information, including the “Personal Identifier,” or “PI” request that must be asked, in the absence of recording, to provide auditors with a method of verifying requests. (Under BPA rules already in effect, the PI question need not be asked if a call is recorded.)

Result: The media owner, advertiser and agency executives on the BPA Board concurred that, taken together, these facts point to the need for action that will safeguard and enhance the viability and status of the telemarketing source for the years ahead, and that outbound recording represents the most effective and efficient means to this end.

I believe the growing importance of telemarketing as a source is precisely the reason that media owners and media buyers on BPA’s Board ultimately voted to take the necessary steps to ensure that the value of the circulation generated by telemarketing is beyond question, as far as advertisers and media buyers are concerned. Recognizing advertisers’ greatly heightened emphasis on accountability, these executives—as well as the leading telemarketers who comprise BPA’s Teleservices Advisory Committee—determined that it is in the best interests of the industry to be able to demonstrate beyond any doubt that telemarketing is a source that deserves to stand head-to-head with written and Internet sources.

Concerns about potential increases in telemarketing costs continue to be a major point of discussion. Media owners are more focused than ever on controlling and reducing operational costs wherever possible, and publishers’ ROI is always a critical component in shaping BPA policies. 

I do keep in mind that BPA is, after all, an industry service organization that is governed by its members and their respective needs.

But I also believe that media owners understand the need to safeguard their interests for the longer term—including their ability to compete effectively for advertising dollars in an increasingly challenging marketplace. This is why a number of the leading B-to-B media companies have for some time voluntarily made recording capability an internal, corporate prerequisite for using any telemarketing vendor.

After reviewing the facts, most media owners supported recording not only because of the accountability factor, but because there is no basis for assuming that costs will rise as a result of recording, when all is said and done.

Looking at the full picture, I believe that the advantages that come with recording—including the ability to maximize the yield and efficiency of calls, as well as reduce some auditing cost factors—will over time counterbalance, and outweigh, any short-term additional costs.

Specifically, outbound recording enables the following operational advantages:

• Gathering of multiple personal requests—either directly from recipients or from recipients’ assistants—for the same publication in a single call. This is true today: Existing BPA rules allow such multiple requests, as long as the calls are recorded.
• Foregoing the necessity to ask existing and prospective subscribers the “Personal Identifier” question. Importantly, many leading telemarketers who already record calls report that, today, asking the PI question is more likely to depress response (i.e., cause business professionals to end a call, or “drop off”) than disclosing that the call is being recorded. These telemarketers point out that, whereas personal questions are viewed with increasing suspicion, people are increasingly accustomed to being informed that a call is being recorded for customer service or other reasons. Again, the BPA rules already in effect allow those who record to forego the PI question.
• Decreased auditing confirmations, resulting in lower costs for this component of the circulation audit. In most cases, recording enables BPA to significantly reduce the number of calls made to subscribers by BPA staff for the purpose of verifying a subscription’s requested status. The number of calls required for statistical verification are directly reflected in an individual publisher’s cost per audit.
• Significantly enhanced potential for gaining the advertising community’s approval for reporting telemarketing, along with written and Internet/email, in a consolidated format. Again, the enhanced quality control assurance made possible by universal outbound recording is a critical step in this direction, in the minds of many in the B-to-B advertising/media buying community.

Additional important facts about outbound recording and the steps being taken to ensure that the industry can comply as seamlessly and cost-effectively as possible:

• Ample time has been provided for compliance. We have built in two years to enable member publishers to work with their telemarketers or prepare their in-house telemarketing operations.
• Recording software and equipment technology continues to become cheaper and faster. Telemarketers and publishers who record confirm that this factor has been an important factor in enabling them to implement recording.
• The rules will appropriately reflect practical considerations. For example, a reasonable reporting tolerance level will be incorporated for subscribers who refuse to be recorded, and it has been established that mandatory recording will not apply to subscription requests/requalifications garnered through inbound, subscriber-initiated calls.
• We are actively engaged in working with publishers and vendors to ensure that they have reasonable, cost-efficient means of complying with outbound recording. Based on research by BPA’s Teleservices Advisory Committee and other advisory committees, BPA is developing a detailed, practical guide to all specifics associated with outbound recording, including compliance with state and international recording disclosure requirements; information on available, cost-efficient recording technology; and test-based recommendations for minimizing costs and maximizing response. This guide will be distributed to all BPA members in the B-to-B arena, including media owners and associate members (telemarketers, fulfillment bureaus, etc.). It will also be made available to the industry in general via posting on BPA’s Web site, bpaww.com.
• BPA will support outbound recording with a variety of member education, outreach, and customer service initiatives. BPA is committed to providing all members with the educational and customer support services they will need to implement recording. In addition to BPA’s Guide to Outbound Telemarketing Recording, BPA will offer free Webinars and live educational programs. Members will be apprised on an ongoing basis of all recording rules/policy developments, and offered insights/advice from media owners and telemarketers regarding specific steps that can be taken to minimize costs and maximize results/efficiencies.

Click here to see the actual rule amendments in their entirety.  Rule amendments

Click on COMMENTS below to submit an opinion.  All opinions will be reviewed before posting.  If you wish to be anonymous in the posting, so indicate in your comments.

Magazine Seller Will Pay More Than $7 Million, Banned from Telemarketing for Five Years

Check out this web site for the above news.

http://www.ftc.gov/opa/2006/09/prochnow.htm

Distribution Agreements

I have created this blog to foster an open dialog on the matter of distribution agreements being required for all bulk circulation.

Copies distributed in bulk (2 or more copies) to a location for redistribution (take-away) or on-site use (public place) must be documented by the obvious printing invoice to prove manufacture and shipping receipt to prove sending to the location, but also the not so obvious “DISTRIBUTION AGREEMENT”.

This agreement states that the location will receive a specified number of copies (no limits) at a stated frequency and what the location will do with the copies.  These agreements must be with each location and not a central point of command as in a chain/franchise environment for all locations.  Further, the agreement must be renewed at least once every three years.  It is an opt-in agreement, not an opt-out agreement.  Agreements must be on hand for 95% of the recipients and 95% of the copies. This requirement has been in place at BPA for more than a decade.  See BPA rule C7.19 in the BPA Consumer Media Rules.

Why?  Well, frankly, advertisers have been burned by bulk distribution that never occurred. Copies were received at locations and then trashed or placed in storage never seeing the light of day.  Advertisers asked BPA to add a level of assurance that locations acknowledge that they are willing to receive copies and will place them for consumption.

We have been discussing the value and practicality of this rule in committee discussions this year.  I believe that rather than require an opt-in once every three years from 95% of the locations (and 95% of the copies), an opt-out on an annual basis is the more effective way to proceed. 

If opt-out is the process to put forward to the Board, it is my opinion that media buyers may not be comfortable with the control of the opt-out returns in the hands of the publishers or their agents.  There may be a perceived lack of independence with the party controlling the returns opting out. 

For this reason I recommend that the opt-out communication process be under BPA’s control (or another independent third party) and BPA be the direct recipient of any opt-out returns.  In this way, BPA can control the opportunity for locations to respond and be recorded in a database for use in subsequent audits.  Of course all responses will be provided to the participating publisher. 

If this change is accepted, I envision BPA’s confirmations staff providing a service to the industry by conducting opt-out communication with public place locations.  For agents, BPA can consolidate databases at BPA and conduct one mailing rather than have each agent conduct separate mailings.  This should save the industry expense.  Further, confirmations by BPA audit staff would no longer be required at the time of audit, saving cost for the publisher.

Prospectively, the public place dB at BPA would be maintained by BPA with annual additions by agents and publishers.  The identity of all locations opting out of receiving magazines in general, or specific titles, would be transmitted to the agents and publishers for suppression in their own dBs.  At the time of audit, a selection of locations from any one magazine can be checked by our electronic audit staff to the opt-out dB thus verifying each agent and publisher is in compliance.

I want to know what you think.  Click COMMENT below and let me know.  Let others know of the blog so that we can have a meaningful dialog.

Subscription Agent Compliance Audits

I have created this blog to foster an open dialog on the matter of subscription agents submitting for an audit of their compliance with MPA guidelines. 

Do agents need to be compliance audited?

I submit that most, if not all, do.  My reasons follow, but I want your opinion.  Hit COMMENT below and let’s get a discussion going.

Agents are vendors to the industry.  I believe that as consumer marketers shop for services, they do so wanting assurances that the product or service they are going to buy is of a professional quality, one that they would want attached to their brand.

No consumer sets out to buy a shoddy service or product.  However, just like most consumers, these marketers do not have the time to invest in proper due diligence to determine that what they think they are buying is actually delivered.  Nor can they invest the time to fully understand the inner workings of any vendor’s business.

I suggest that the MPA created guidelines to help consumer marketers be better informed buyers.  Challenge:  no one has been checking if agents comply with the MPA Guidelines.

Enter the demise of stamp sheets and the increase in alternative methods to acquire subscribers, including the use of the Internet and commodity pricing of subs.  These alternate methods are complex and require document trails to substantiate their legitimacy.

Some agents have their “ducks in a row” such that an audit of their processes is efficient.  Others may not be as organized and very inefficient, and yet others may be involved in programs that contravene audit rules and regulations. Don’t consumer marketers need to know this?

P.S.  A side benefit from auditing at the source of the transaction should be reduced auditing at the publishers office and fulfillment house.

Let me know your thoughts.