As soon as it was announced that hospitality businesses should collect contact details when reopening, the topic of marketing to track and trace customers was a major point of contention. It’s uncharted territory for everyone and not something that was factored in when GDPR was created.
Many specialists have issued warnings about using track and trace contact details to market to customers visiting hospitality venues. And while such warnings are warranted, they were issued very early on and didn’t take into consideration exactly how customer data would be collected.
So we’re going to try and provide some clarity in the foggy area of whether you can market to customers who provide their details for track and trace.
In Short
YES, it’s possible to market to track and trace customers, with certain measures in place.
It all comes down to empowering customers to make the choice. That’s what GDPR is ultimately all about – giving people more control over their personal information and its use.
Breaking It Down
If your method of data collection and storage for track and trace gives the customer no option to manage, update or easily opt-in or out of communications then it’s a no go. A basic pen and paper or spreadsheet collection method would fall into this category.
When it comes to digital track and trace systems, it’s pretty much the same story. When a customer provides contact details, such as by scanning a QR code and filling in a form, are they given the choice to receive marketing information? Can they update their own information and opt-out at any time? If the answer is no to any these then once again it’s not possible to use their details beyond track and trace.
This is the risk with many of the newly developed apps that launched within days of the reopening guidelines being published. They’ve only been designed to do track and trace in terms of capture and compliance. There’s no way to layer the marketing option on top.
And that’s why we can say that it is possible to market to them. At Stampede our system is set up to handle all the GDPR requirements for data collection.
Our Track and Trace system explicitly asks if customers want to join the mailing list or not. If they don’t give an answer, the system assumes opt-out and the customer will not be available to email. If they say yes to joining the venue’s mailing list and opt-in they can manage their data and preferences at any time.
As long at it’s in the customers’ power to choose, then there is no problem with giving them the option to join your mailing list when they sign up to Track and Trace.
Food For Thought
When the GDPR legislation was rolled out people focused more on the headaches it would cause for businesses and marketers. Over time we’ve all learned to work within it and it’s become another piece of the scenery.
But now GDPR shows itself in a new light. Where we once thought of it as restrictive, GDPR now acts as the fall-back needed to make better decisions on how we treat customer data. Without its clear rules, setting up something like Track and Trace would be far more complicated. Just look at the state-to-state situation in the USA. No hard and fast rules on data protection and collection have made a track and trace system almost impossible to set up there.
If you have more questions about marketing and track and trace then please reach out to our team.