Neil Davey is the managing editor of MyCustomer. An experienced business journalist and editor, Neil has worked on a variety of newspapers, magazines and websites over the past 20 years, including Internet Works, CXO magazine and Business Management. He joined MyCustomer in 2007.
There's no mention of pseudonymous data there, however.
My understanding is that personal data that has been pseudonymised can fall within the scope of the GDPR
depending on whether the party holding it has access to the key, plus how difficult it is to attribute the
pseudonym to a particular individual.
Hi Michael, I've found nothing more on this to date. I will update here if I find/hear anything that contradicts my original response, though. Thanks Michael.
Thanks for your query. My understanding here is that the organisation should be clear in its privacy terms/statement how it will use customer data, and as part of this it should confirm if it will retain a record of deletion (which may include an email address). Similarly, it should be stated if an unsubscribe from a newsletter is recorded and retained.
But even these records of deletion should probably be deleted after a certain amount of time.
I will try to look into this further and should I find anything more to this, I'll post here.
It's a good question, Phil. I'll look into this for you to try and get some clarity on this. I *believe* that you only need to confirm that that their request for erasure has been complied with, rather than provide them with all the information you held on them, as you would need to do if you received a subject access request (https://ico.org.uk/for-organisations/guide-to-the-general-data-protectio...).
In short, it appears that you can keep some details, in order to prove that a transaction/relationship existed. The example being that you may need to keep some customer details (i.e. their order details) in event that there could be a complaint that you need to deal with.
Yes there are some similarities in terms the overall roles that have been highlighted - this is because the author of the original piece (Cara Olson) also contributed to the MyC article, as well as providing guidance in addition to the quotes included.
There are probably pros and cons with either model, and ultimately the most appropriate fit will depend on the specific requirements of the organisation in question.
Hi, it's referring to service channels - so depending on what channels are utilised by an org, this could be anything from live agents, to chatbots, to self-service, to the multitude of social platforms.
My answers
Hi Umran,
The ICO's recommendations on this can be found here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protectio...
There's no mention of pseudonymous data there, however.
My understanding is that personal data that has been pseudonymised can fall within the scope of the GDPR
depending on whether the party holding it has access to the key, plus how difficult it is to attribute the
pseudonym to a particular individual.
The ICO's official line on pseudonymised data can be found here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protectio...
Thanks
Hi Michael, I've found nothing more on this to date. I will update here if I find/hear anything that contradicts my original response, though. Thanks Michael.
Hi Michael,
Thanks for your query. My understanding here is that the organisation should be clear in its privacy terms/statement how it will use customer data, and as part of this it should confirm if it will retain a record of deletion (which may include an email address). Similarly, it should be stated if an unsubscribe from a newsletter is recorded and retained.
But even these records of deletion should probably be deleted after a certain amount of time.
I will try to look into this further and should I find anything more to this, I'll post here.
It's a good question, Phil. I'll look into this for you to try and get some clarity on this. I *believe* that you only need to confirm that that their request for erasure has been complied with, rather than provide them with all the information you held on them, as you would need to do if you received a subject access request (https://ico.org.uk/for-organisations/guide-to-the-general-data-protectio...).
Hi Nick, your query should be answered here:
https://ico.org.uk/for-organisations/guide-to-data-protection/principle-...
In short, it appears that you can keep some details, in order to prove that a transaction/relationship existed. The example being that you may need to keep some customer details (i.e. their order details) in event that there could be a complaint that you need to deal with.
Thanks for your message.
Yes there are some similarities in terms the overall roles that have been highlighted - this is because the author of the original piece (Cara Olson) also contributed to the MyC article, as well as providing guidance in addition to the quotes included.
That's a great question, Shery.
There are a few schools of thought on this.
Some models suggest that the role of CMT replaces the CMO - it's effectively a CMO with bells on:
https://www.mycustomer.com/marketing/technology/why-brands-must-embrace-...
Alternatively, other models suggest that rather than replacing the CMO, the role should be swapped into the organisation in place of the CTO:
https://www.mycustomer.com/marketing/technology/is-a-chief-marketing-tec...
There are probably pros and cons with either model, and ultimately the most appropriate fit will depend on the specific requirements of the organisation in question.
Hi Jeff, I believe this is the original article: https://www.ama.org/publications/MarketingNews/Pages/3-ways-market-resea...
I've added the link to the above piece now as well.
Thanks.
You can find further advice on building a customer journey map in this series: https://www.mycustomer.com/content/the-complete-guide-to-customer-journe...
Thx
Hi, it's referring to service channels - so depending on what channels are utilised by an org, this could be anything from live agents, to chatbots, to self-service, to the multitude of social platforms.