What's the point of a regulator?

An article in Third Sector magazine - http://bit.ly/2wAqnoj - suggested that the Information Commissioner bears some responsibility for the fundraising sector's focus on consent - and lack of focus on legitimate interest - as a lawful basis for processing.

Many readers agreed, with the exception of some data protection professionals, who suggested that the fault lies with the fundraising community’s failure to listen to advice that didn’t suit their purposes.

So does the regulator have any responsibility for advising practitioners? Absolutely. Here’s why:

1.      Data protection regulations are complex. They need to be interpreted, so that practitioners understand the practical implications. That's why data protection consultants have a business. Not all charities can afford to hire professionals to help them make sense of the rules, so a regulator who promotes compliance rather than just enforcing it is welcome.

2.      Charities have in the past been led by authorities to understand that a more lenient interpretation of the regulations would be applied to their activities. There’s no doubt that this no longer is the case. Nonetheless, it’s in everyone’s interests for the regulator to help organisations to interpret, understand and apply the regulations in the current environment.

3.      The ICO’s blog provides guidance to “bust some of the myths that have developed around the General Data Protection Regulation” - http://bit.ly/2i7Bwat. If the regulator has no responsibility to explain, why has she done so? And given that she has done so, the question of why it has taken so long is still valid. Had guidance been published earlier, there would be no need to bust myths now.

4.      The Third Sector article did not suggest that the regulator was solely responsible, just that she is partly at fault. Ultimately, organisations themselves are responsible for complying with the law. This responsibility, and the responsibility of regulators to inform, advise and support them, are not mutually exclusive.

It would be uncharitable to suggest that the only people who don't think the regulator has a responsibility to explain are those who make their living from explaining. I don't question the motivation for their point of view, but the sector is confused and beleaguered. To suggest that the responsibility for that rests solely with fundraisers and not at all with the regulator is even more uncharitable.

A dream job or a chance of life?

In a moment of barely-disguised conceit, Tristram Hunt described his decision to resign as an MP as “a wonderful moment for the Victoria and Albert Museum”. Not such a wonderful moment for those of his constituents who, less than two years ago, thought they had an agreement with Mr Hunt: that they would give him their vote, and he would represent them for five years.

And not such a wonderful moment for the taxpayer, given that, according to Cabinet Office reports, the average cost of a Parliamentary by-election in England and Wales is more than £230,000. Since the last general election there have been five parliamentary by-elections that were brought about by resignations (rather than the death of an MP): two because of policy differences, two in order to take up alternative elected positions and one because David Cameron decided that if he couldn’t captain the ship he would abandon it. The resignation of Jamie Reed as MP for Copeland, to take up a job at Sellafield, and Tristram Hunt’s “dream job” at the V&A, take the bill for by-elections caused by resignations to around £1.6 million. The mayoral elections in Greater Manchester and Liverpool are almost certain to add to this number.

As any football fan will tell you, if a manager leaves a club before the end of his contract, the club will demand compensation, either from him or from his new employer. Morally at least, MPs who promised to represent their constituents for five years and who choose not to see out their term have breached their contract with the electorate.

Back in the real world of what politicians patronisingly describe as ‘ordinary people’, a petition and fundraising campaign introduced me to the story of Sasha, a young mother whose leukaemia has relapsed after a stem cell transplant. According to the charity Anthony Nolan, around 20 people a year need a second transplant for blood cancer or a blood disorder that has relapsed following an initial stem cell transplant. Such transplants have been deemed unaffordable by NHS England, despite the fact that a 2015 study suggested a one in three chance of these patients surviving for five years. Sasha must now raise the money to fund private treatment, to have that chance. The cost of a stem cell transplant procedure to the NHS? Between £50,000 and 120,000. So if the average cost is around £85,000, the annual cost for 20 ‘unaffordable’ transplants is around £1.7million.

If our shared society cannot afford £1.7 million to save six lives a year, how can we afford £1.6 million so that seven MPs can move to their ‘dream job’?

Can someone please explain that to me? Much more importantly, can someone explain it to Sasha?

The challenge facing fundraising

What are we going to do?

Much has been written about the challenge facing fundraising: about regulation, permission, respect, putting the supporter at the heart of fundraising strategies, building a new kind of supporter relationship.

As if it was not already hard enough to raise funds to support charities’ programmes, fundraisers can expect a new regulator, new regulations, increased scrutiny, more empowered supporters. But the question that remains unanswered, despite all the words that have been written on the subject, is: how can charities respond to the challenge of the new fundraising world? In real, practical terms, what are we going to do?

Chasing numbers

The problem is that we’ve grown accustomed to chasing numbers. We’re driven by volumes, ROI, retention rates and average value. The vision of a better world, and the mantra that our causes are best served by putting the supporter at the heart of our strategies, can become obscured by the stark figures on the monthly report. We have to chase the numbers, don’t we?

“Visionary companies pursue a cluster of objectives, of which money is only one - and not necessarily the primary one. Yes, they seek profits, but they’re equally guided by a core ideology - core values and sense of purpose beyond just making money. Yet paradoxically, the visionary companies make more money than the purely profit driven companies”

Built to last: successful habits of visionary companies: Collins & Porras

In his book: ‘Obliquity: why our goals are best achieved indirectly’, economist John Kay quotes many examples of companies that succeeded because they focused on their core purpose - making the best aeroplanes, medicines, computers - and of companies that failed because they chased the numbers: profit, shareholder value.

Of course, our ‘making money’ is ‘raising money’. So does this suggest that we should no longer focus on raising money? And if that were to be the case, what should we focus on?

The vision and the mechanics

Of course no-one would deny that fundraisers’ ultimate purpose is to raise money. But perhaps raising money - sustainably increasing supporter value in the long term - is best achieved indirectly.

Ask anyone who works for a charity to describe the organisation’s purpose, its values and why it is important, and there’s a good chance they would give a compelling, passionate and authentic account. But put them in front of the tools of their trade and the transaction takes over: processing a donation, writing a campaign brief, signing off a script.

As fundraisers, our equivalent of ‘the best aeroplanes and medicines’ is ‘the best supporter relationships’. To define that in a way that differentiates one charity from another, we have to look behind the mechanics of targeting, contact strategy and supporter care, important though they are, and explore how each organisation’s values are reflected in the supporter experiences that it creates.

What’s the point of values?

At the recent Public Administration and Constitutional Affairs parliamentary select committee hearing, fundraising chief executives acknowledged that their organisations’ values had not always been reflected in their fundraising practices.

The question that all fundraising leaders must answer is: how can we address this challenge in a way that will be meaningful for supporters?  

You can take tactical steps such as reviewing communications and equipping people to tell stories in supporter care encounters, but you need to go further, creating a strategy and structure that drives behaviours that reflect your values.

So what can we do?

There are two priorities:

Authenticity: find ways of expressing your charity’s values through every contact with your supporters, in a way that feels natural to the organisation and the supporter. And ensure that you do this consistently, through every proactive communication and every responsive encounter.

The best supporter relationships: make a long term commitment to creating the best supporter relationships as the first priority, above every other demand that the organisation makes of its fundraisers.

How can you achieve this? There are a number of things you can do. You can define how your charity’s brand values should be reflected in fundraising communications and contacts. You can review all of your communications and touchpoints, to question how well they tell your compelling story. You can redefine supporter journeys in the context of the ‘best supporter relationship’ priority. You can revise your KPIs, so that you measure authenticity, brand consistency and relationship quality, and not just financial targets.

There is no single solution to the challenge: there are many steps you must take. It is a major commitment: to change the way you define success; to believe that this will lead to better outcomes for the supporter, the organisation and its beneficiaries; to devise and implement practical changes.

But today the need for action, not just words, has never been greater.

Emergency fundraising: four essentials

Much of my work over the last year has been in the world of retail, famous for being fast-moving, dynamic, immediately responsive to changes in market conditions. Not for retailers the gentle pace of fundraising, the measured diet of monthly gifts and quarterly updates.

Until, that is, there is an earthquake.

Little more than a dozen hours after the first shock hit Nepal, the first appeal arrived in my inbox. Through the weekend, charities and their agencies were at work, belying the slow moving stereotype.

Over the years I have found my way onto many a charity database, as a supporter, business partner or interested observer. Checking email and text messages in the two days since news broke from Nepal led me to an unscientific survey of emergency appeals:

UNICEF were first, the only organisation to make its appeal to me on the same day as the news broke, followed on Sunday by Christian Aid and British Red Cross (the latter by text message).

Appeals from SCIAF (Scottish Catholic International Aid Fund) and Tearfund arrived during Monday.

I make no claim that my survey is comprehensive: the fact that I did not hear from a charity does not suggest that they were not equally active, equally responsive to the need. But I was struck by what I found:

1. Speed matters: it is possible to launch an appeal within 12 hours of the need arising, seven days a week: this is the new benchmark.

2. A clear ask: UNICEF were very clear: "we urgently need you to send a gift of £35 to help the children of Nepal". Others were less prescriptive, perhaps deliberately so: "give what you can". Perhaps surprisingly, Christian Aid were more blunt: "donate today". Some donation pages had gift amount prompts ranging from £10 to £115. No doubt prompt levels have been tried and tested and are different for different supporter bases, but the importance of a clear ask is indisputable.
 
3. Make it meaningful: Tearfund and UNICEF made it very clear what each prompted amount could help them achieve, giving a clear sense of the tangible impact of each donation.

4. Once may not be enough: media planners know that they have to give their audience multiple opportunities to see their message in order for it to have the desired impact. UNICEF have adopted a similar approach, emailing two further and increasingly urgent messages in the 48 hours since their original appeal.

If this simple exercise has reminded us of some fundraising essentials, it does not detract from the most important point: organisations are doing vital work to respond to emergencies in Nepal and elsewhere, and they need our support to enable them to do so. They are playing their part: now it's our turn.

Small data: big mistake

A two-night stay in Oxford, with free return rail travel: how does that sound? Enticing, perhaps, except to those who live near Oxford and tackle the daily challenge of travelling into and out of the city of steaming tyres. Or the daily commuters who compete for prime locations on Oxford station platform, dreaming of securing a seat for the crawl to the capital.

Despite the allure of two nights in a converted prison, the lead offer in 'Escape', First Great Western's e-newsletter, was hardly compelling for someone like me, who could escape to the Malmaison on foot. Surely they must know where I live? I decided to investigate.

First Great Western asks new users of its online booking engine to register with their name, mobile phone number, email address and postcode. Of these, only the name and email address are mandatory.

If the postcode were a required field, they would know that their other current competition, to win a luxury break in Cornwall, would be more attractive to those of us who long to escape from Oxford's integrated transport system.

How many would drop out of the ticket purchase process if postcode were a required field? And who would object to providing their postcode if, having agreed to receive an e-newsletter, it would result in more relevant offers?

Even without a postcode, an examination of the departure station for most of the tickets I have purchased online would deliver an insight into whether I would rather escape to or from Oxford if, that is, the e-newsletter is segmented (please, @FGW, don't tell me you send the same newsletter to everyone).

Big data may be the latest buzz. But one very small piece of data, combined with intelligence and common sense, could make a big difference to the relevance of your communications to your customers, and their willingness to engage - or escape - with your brand.

Customer experience excellence: you find it in the most unexpected places

Ask any customer management practitioner to name the brands that are true leaders in customer experience excellence and the response generally will include a roll of honour of the usual suspects: Amazon; First Direct; a new addition: Olympic and Paralympic Games Makers. One organisation that you won’t find at the top of the ‘most admired customer experience’ league is Her Majesty’s Police. Perhaps that should change.

Not long ago I contacted the police 101 non-emergency number. Dialling 101 from anywhere in England and Wales allows citizens to make contact with their local police force, in my case the Thames Valley Police. My experience was a master class in customer experience essentials:

The first voice I heard was that of Chief Constable Sara Thornton, delivering a recorded call opening message. My first impression: that the leader of this organisation was committed to delivering a good experience to her customers, even those with very basic enquiries. I was asked to choose one of three options, each of which was clearly described: I was left in no doubt which button to press.

The second voice asked how they could help. The police representative took time to listen to my story and understand what I needed from her. Occasionally she asked for clarification but initially at least, she allowed me to feel in control of the conversation. She provided answers to my questions and took a note of information that she needed for her records. More importantly she empathised, and gave me the impression that her organisation was there to support me. Finally, she gave me a reference number and let me know I could contact them again if I needed further assistance.

What does this experience tell us?

• Find a way of demonstrating to your customers that delivering a great customer experience is important to everyone in your organisation, including the chief executive or chief constable.
• Interactive voice response (IVR) can be useful and even welcome if the list of options is short and it leads to a more relevant conversation.
• Start with your customer’s agenda: you will want to capture information about them, but let them talk first.
• Take time to listen to your customers, to find out how they feel and what they really need from you: a longer conversation may be more efficient than average handle time statistics might suggest.
• Once your customer feels comfortable talking with you, they will be more prepared to give you the information you need to drive your future relationship.
• At the end of every interaction, confirm the next steps, and what the customer can expect to happen next.

A simple, straightforward, excellent experience that reminded me of some of the customer experience fundamentals.

I guess you could call it Customer Experience 101.

Happy Birthday, Allan!

Just after 8 pm on my birthday, this email landed in my inbox:

Hi Allan,

Here's to another year of happy travels. When you're out celebrating in Newbury you may like to hint to your friends that one of our top offers below would make a great gift. Or make this the year you visit that must-see destination (check out our favourites for the coming months).

Best wishes,

The Opodo team

Those ‘top offers’ included a three night city break in New York for £526, a flight to Dubai for £312 and an attractively priced 3-star hotel room in Bangkok for £16 (leaving me only with the challenge of working out which friend would pay for my £473 flight).

Opodo gathered some information from me when I booked a flight with them. And they are determined to use it. They know three things about me: that one of my names is Allan, the date of my birthday, and that I used to live near Newbury. They have decided that, as a result, they have a relationship with me.

If Opodo did in fact have a relationship with me, they would know this:

• No-one who knows me calls me Allan 
• I live near to Oxford 
• None of my friends would buy me a flight ticket or a night in a hotel in Bangkok for a present

We have to accept that mass marketers live in a world of personalised rather than personal relationships. But rather than trying to make our communications seem relevant, we should focus on making them actually relevant, by looking beyond the obvious.

On the face of it, Opodo know very little about me. In fact they know much more. They know my age/lifestage. They know that I booked a flight to a European destination, for two adults and a child. They know that I did not book a hotel, or anything else. They know it’s more than two years since I bought anything from them, that they have sent me emails at least twice a month since then, that I open them only when they feature a competition and click through almost never. All of this tells them much more about my propensity to buy from them than my birthday. Their challenge is not to remember to wish me many happy returns, but to find a way of tempting me to come back to them. And e-marketing gives them the flexibility to tailor their proposition, not just the way it is communicated.

Accurate, updated customer and prospect data may appear to be the solution to the problem, but it’s not the whole story. Knowing your customers’ names and birthdays may help to put the finishing touches to your communication, but it won’t guarantee relevance. So when you’re planning your next targeted campaign, don’t ask ‘what personal information are we using in this communication?’ Ask ‘what information are we not using, and how can we start to exploit it effectively?’

Make your message personalised and your customers might open it. Make it relevant and there’s a good chance they will buy.