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Jun 13, 2002

Exclusive: Consumer Reports' Advice on Email Marketing, Spam and Privacy

SUMMARY: Pity the marketers at Consumer Reports because, as they work for the most famous consumer advocacy non-profit in the US, they have to be holier-than-thou when it comes to adhering to privacy and anti-spam regulations with their marketing. At the same time, they are required to get really fabulous email marketing response rates, because there's no money to waste and Consumer Reports depends almost utterly on campaign responses to survive. (They do not accept any advertising.) We interviewed their leading online marketer to learn how they get great response rates, best practices in coordinating with customer service, and what landmines...
It is not easy being an email marketer for Consumers Union because everyone expects you to be perfect about privacy. Oh please get a really high response rate too because the organization is supported by its sales to consumers.

How does this venerable 66-year old institution balance consumer's email concerns with its sales goals?

We contacted Marketing Director Michelle Rutkowski who is responsible for (now 800,000+) subscription sales to the Union's site, as well as for advising the Union's other direct response marketers on how to use email.

Here's Rutkowski's advice for other email marketers:

-> Copywriting for email versus direct mail

Rutkowski says, "We have a certain reputation and style. People expect us to speak to them in a certain voice. We try to translate that across media. But, there are subtle differences."

She suggests you keep email copywriting much shorter and to the point than direct mail letters, which often do better the longer you make them. That does not mean you can not still offer the same depth of content, but instead of jamming it into a long email, use hotlinks to offer readers the chance to dive for more details when they want to.

Yes, this means your email links should not all go to the same place. It also means you need to track click and conversion responses from each link, both in terms of position on page and topic.

Fascinatingly, Rutkowski says links to deeper content generally end up pulling higher paid conversions than straight offer links in the same email do. Which means classic long, deep content works for email; it is just broken up differently than it would be in print.

-> Subject line copywriting is more and more difficult

Subject lines that might work great as outer envelope teaser copy, or that may have pulled great responses for your email campaigns in the past, may not work anymore.

Why? Spam overload.

Consumers are looking for a reason to delete your email without opening it as they clean their in-box. If your subject line uses words or phrases such as 'Great Offer!' that a spammer might use, then your opt-in message will often be deleted as well.

Rutkowski also warns, "Certain people set up their email inbox to filter out words like 'Free' and 'Offer' automatically. To get your message to the recipient, you need to avoid being filtered. Don't set off the bells and whistles that this is junk mail or this is a virus. That's a concern people have."

While 'cutesy' subject lines may work for some marketers, Rutkowski says she's tested a wide variety of subject line tones and the ones that work best for her are "really straight forward" subject lines that clearly, honestly, and without hype, spell out what's in the email.

-> "From" lines are critical too

Should your email broadcast message appear to be "from" a single person or from your brand name? Rutkowski says she and other Consumers Union marketers have debated and tested this. Their findings: The from line should be a recognizable brand.

Rutkowski explains, "Realistically, if you send an email from some name they're not familiar with, people are going to potentially think it's spam and just delete it. People are very cautious. Our consumers are very smart, savvy people and are concerned about privacy issues and who's sending an email."

(Note: if you are having a third party send a message to their list on your behalf, as occurs in any permission-based rental situation, generally the "from" line should be the recognizable brand name the recipient gave permission to, and not your brand.)

-> Do not forget to polish your text-only version

If you are sending HTML emails, it is easy to get swept up in making your graphics perfect and forget entirely about the version of the email text-only recipients will see.

Rutkowski advises, "You need to take a look at it, where it breaks, where it wraps. You can control that depending on how you prepare your file and your vendor's requirements."

She also strongly advises you view a test message in AOL-version, "weird stuff happens that you can't really explain."

Plus, Rutkowski notes that just because people can receive an HTML version of your message doesn't mean they want to. In fact some people just prefer text, some for the smaller file size, some for the look of it. Your customer service department needs to be able to flag customers who want text-only for future

-> Is renting lists ok?

Rutkowski has nothing against renting lists per se. In fact she has rented a few herself.

However she only rents double opt-in lists, and she does not accept a list broker's word for it. She explains, "We always make sure to verify that any list is double opt-in. We'll go to the site and go through the opt-in process to see what it's like." She adds, "We're Consumer Reports -- we *have* to do the right thing!"

Rutkowski also notes she has heard that some consumers are using free Yahoo and Hotmail accounts as rarely-gonna-read boxes to stick into online registration forms to avoid receiving promotional email in their primary accounts. "If I were buying a lot of outside email lists now, I'd probably look at what domains the names fall into, and tend to put more weight in a list with more paid domains like an AOL account they paid for versus free domains."

Just as with direct mail, Rutkowski has found that almost invariably the email lists that perform the best are selections from her own house file of past buyers.

-> Best ways to build a house file

As you might have guessed, Rutkowski is definitely uncomfortable with the idea of using an append service to tack email addresses onto the organization's postal mailing addresses.

Which is tough because Consumers Union has millions of postal mail addresses on file from current and past subscribers, buyers and donators. (You can imagine how during sales crunch time, Rutkowski must wish that append was more consumer-friendly.)

She says, "The concern is that the consumer explicitly said they are willing to get email from the particular place. The names were acquired by some other source, so if you take your list and append, those customers have not given you explicit permission. They've given someone else permission. It's a very sticky area."

"We've discussed it," she adds, "but we haven't been willing to go there. There are people who are very sensitive to this issue out there. We want to respect that."

The majority of new names that Consumers Union adds to its email house file come from two places: New online subscribers who voluntarily check an additional box during the registration process that allows Consumers Union to send email to them, and consumers who call in to order products over the phone.

The in-bound call center has been trained to spell out exactly why they are asking for an email address and what it will be used for. Plus the customer service department is able to quickly remove a customer's name from the email list whenever requested to do so.

(Note: many companies with multiple databases, email vendors, and legacy systems are unable to react quickly and thoroughly to unsubscribe and remove requests; and that can turn into a big customer relations nightmare these days.)

Although we have heard anecdotal evidence from other Web sites that consumers are less and less willing to share or opt-in their email addresses these days, Rutkowski says this has not been a problem for her so far. However, she notes, "We are in a unique position that perhaps an unknown brand or new company might be in. People don't opt-in with trepidation with us."

-> Your privacy policy is even more important than you think

Rutkowski's number one rule of collecting email opt-ins is that your privacy policy should clearly state what you will do with those email addresses, and that policy should be obviously linked to when you ask for an address, not hidden in the fine print at the bottom of the page.

She says, "We've tried to make our policy very concise and straight forward, and we strongly suggest visitors read it on the site."

While a whole bunch of legalese may please your lawyer, it does not help consumers. Make sure your policy is clear to a regular human being.

If you are a business-to-consumer organization conducting business online, your privacy policy matters more than ever these days because and the site (which is partially supported by Consumers Union) are shining a big spotlight on whose policies are good and whose are not.

To get a thumbs-up rating, you must use "opt-in" instead of "opt-out." That means no pre-checked boxes.

Go to the link at the end of this article to learn more, and see how many famous eretailers' have been rated already (hey Ticketmaster, all we can say is "ouch").

-> Why fuss about spam anyway?

Many marketers (especially those from classic direct mail backgrounds) think all this fuss about spam, privacy policies, and permission email is just going a bit overboard.

Rutkowski agrees that no matter how perfect you are, some consumer is going to be upset with you. ("We've been in business 66 years. You're always going to have one person offended by just about anything you do. You can never expect 100% of the people to be happy 100% of the time.") However, she says that now it is more important than ever to make sure you do not appear to be spamming in any of your email recipients' eyes.

One of the hardest things for traditional mailers to understand is how consumers' reactions are different to unwanted email versus unwanted postal mail.

Rutkowski says, "It's very different from direct mail. People take email very personally. If they don't want your email they have a much more strong response than if they get direct mail and just toss it in the can." Those strong responses, whether justified or not, can end up damaging your company severely as more and more consumers whistle-blow on suspected spammers.

"You have to understand the various avenues and reporting structures there are for consumers to report a potential spammer and make sure you do things to steer clear of them. You don't want to be reported as a spammer. You can be blackballed and also blocked out of mailboxes. You don't want to go there. There's no reason to go there."

It is another reason to have a heck of a straight-forward, consumer-friendly policy prominently posted throughout your site, and to triple check all lists you rent are really, truly permission-based.

All in all, if you are concerned about truly pleasing consumers for a long-term relationship, we would recommend that you consider following Rutkowski's lead.

Remember, just because your lawyer, or your email vendor, or an industry association says it ok to do something, that does not mean consumers themselves think it is ok. Consumers are the ones that both Rutkowski and your bottom line really answer to.
(to check out eratings)
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