Everyone's talking about it: the new General Data Protection Regulation, better known as the GDPR, comes into force on 25 May this year. And one of its main provisions? The appointment of a data protection officer. Whether or not you are obliged to appoint a DPO, the real question is knowing when to call upon them...
Is a DPO mandatory? Not necessarily...
What do the regulatory texts say? Other than public organisations, only companies whose core activities consist of regular and systematic monitoring of data subjects or processing sensitive data on a large scale are obliged to appoint a DPO. 'Regular and systematic monitoring', 'core activities' and 'large scale' are vague terms, however. This is why some work has been done to define the scope of the obligation to appoint a DPO.
We must therefore look at the number of people targeted, the volume and the scope of data categories, the duration and the geographic area of the data processing to be carried out. Some examples? A telephone operator or a bank are clearly affected, whereas an independent doctor is not in terms of managing their patients (who are not 'on a large scale'). Conversely, a hospital is also affected, as this falls under their 'core activities'.
A necessary – and independent – rare bird
More important than knowing whether your company is affected by this obligation, you must ask yourself about the overall consistency of your approach to the GDPR. You will certainly need a specialised 'conductor' who is able to take on all the tasks required of the DPO.
First instinct: you might be inclined to look internally and appoint someone already active in you company, but this choice requires having the right person available (in terms of technical and ethical competences), training them properly, but above all ensuring their independence in order to avoid any overlapping of their tasks and possible conflicts of interest. All the more so since Article 38 of the GDPR clearly specifies the independent nature of the DPO: "The controller and processor shall ensure that the data protection officer does not receive any instructions regarding the exercise of those tasks". In reality, you'll be at risk of searching for a needle in a haystack. In this context, it seems clear that the solution is better found elsewhere: outside of your company.
An external solution is a great idea
You should know that the GDPR allows this option. If the independence factor and lack of conflicts of interest are your main (and good) reasons to look externally, you could also benefit from other advantages. On the one hand, if your company is made up of several branches, you can 'share' your DPO and ensure overall consistency of your approach to the GDPR. Similarly, many SMEs could find a significant financial benefit in pooling a data representative. Indeed, a full-time DPO is certainly not necessary in most companies.
Costs at the forefront: even if taking the decision to find an external consultant is not always cheap, sourcing them externally guarantees the best visibility and control of expenses incurred. This allows you to better adapt their tasks to your needs and make 'à la carte' decisions. What's more, you may, in certain cases, be able to count on dedicated GDPR tools placed at your disposal (toolboxes, diagnostics, etc.). Among the downsides of looking externally is the lack of knowledge of the inner workings of your company. That is why it is in your best interests to include a full initial audit in the tasks assigned to the expert in order to hone their knowledge of your company environment and your internal processes.
The conversation manager: essential and permanently online
Coordinating a company's social media strategy is a task in itself. Who will you use to handle this? And what about involved customers who suddenly get too involved?
Because of social media, the role of a traditional marketing manager is evolving more and more towards being a conversation manager: someone who facilitates consumer communication. This includes communication between customers themselves and communication between the customers and the company.
Some key tasks in the conversation manager's job description are:
- Uniting and activating ‘branded fans’, as they will recommend the brand to friends and family.
- Listening to what people are saying about your company and seeking their active contribution to your products and strategy.
- Creating content worth distributing in order to encourage discussions.
- Managing these discussions.
- Ensuring your work is very customer-oriented and customer-friendly through customer care, i.e.by responding faster and providing more than what the customer is expecting.
Some companies are big enough to hire a full-time conversation manager. In other cases another employee will take on this role part-time. A third possibility is using a specialised company.
Caroline Hombroukx, conversation manager at content marketing company Head Office:
“No matter which option you go for, communication in social media must come across as personal. There is definitely a reason why large companies such as Telenet and Belgacom have created a fictitious person to deal with their customers; Charlotte and Eva respectively. The conversation manager also has to know the company and its social media strategy very well. It may therefore be an advantage if someone in the company itself takes on that role. That person is right at the source and so can distribute information, take a quick picture and post it online, etc.
This task is not for everyone. A conversation manager must have experience with social media, have fluent communication and writing style and must be empathetic, positive and solution-oriented in his or her dealings with customers. Prior training is not a luxury, because the employee must be very aware of the company's content strategy. The audience is varied and unpredictable. You have to decide time and time again whether certain content is or is not suitable for your target group. It is also not a nine-to-five job: the online world keeps on turning even at night or at the weekend."
The advantage of hiring a conversation manager from an external company is that in principle the expertise is present. In that case the challenge is to know the company to such an extent that the customer has the impression that he or she is talking to a real employee.
Getting angry is out of the question
Traditional marketing and advertising are a one-way street. If they do not work, they are a waste of money. However, they are not likely to result in angry comments. A company venturing out on Facebook, Twitter or other social media, can be sure to receive comments and reactions. Including negative ones. Caroline Hombroukx:
“On social media the consumer is suddenly right next to you banging the table. It is important to respond well to that. Getting angry yourself is out of the question. You need to respond by showing that you understand and you are taking the question or complaint seriously. Everyone following the discussion must see that the company is providing a quick answer and is trying to find a solution. If a mistake has been made, you can acknowledge this openly and honestly. You can also show the problem as something positive: as an opportunity to improve your brand, product or service. Of course you must find a suitable solution in the end. If the person sharing the complaint becomes too negative, you have to try and divert him or her to a private channel: a private message on Facebook, a direct message on Twitter, an e-mail or a phone call."
An enthusiastic, understanding response also works well if the consumer is sharing something positive about your brand, company or service. Thanking the consumer strengthens the bond between the company and the customer. Caroline Hombroukx:
"The dialogue with the target group is an opportunity to improve your product or operations through constructive criticism. Make customers feel involved. It creates a strong relationship. If you are publishing a magazine or starting a poster campaign for instance, you can let customers choose the best layout or title from three options posted on Facebook, for example. Everything that engages customers can only strengthen their commitment."
Social media dos and don'ts
- The consumer is always right (even when this isn't the case).
- Be open, honest and friendly.
- Use a personal style.
- Respond quickly to any questions or reactions.
- Stay positive and be understanding.
- Do all you can to engage your customers.
- Come up with a free gift every now and then.
- As a brand, try to avoid political topics.
Social media and e-commerce: opportunities and risks
The huge popularity of social media brings new opportunities, but has resulted in some new stumbling blocks as well. What are the most recent trends? And how should you respond to them?
Social media such as Facebook, YouTube, Twitter, Instagram, etc. seem cutting edge, but the principle is as old as the hills: word of mouth, sometimes abbreviated as WOM in marketing. Even in the heyday of the mass media, positive recommendations from neighbours, family and friends remained important to a company's success. Newspapers, magazines and television advertising were the first channel introducing a new product to consumers, but word-of-mouth turned out to play a decisive role in what matters most: consumer behaviour. Consumers shared experiences and thereby affected the behaviour of their fellow consumers. Today, more than ever, they do so through social media.
Consumers persuading consumers
Social media are the contemporary, more sophisticated and super-fast successor of old-fashioned word-of-mouth advertising. They are a catalyst. Social networks allow people to exchange views, share experiences, express their dissatisfaction, etc. more quickly than ever.
In addition, more and more consumers are opting for a "social search" over search engines such as Google to find information. They consciously do not search the entire internet, but approach their friends on Facebook or contacts on LinkedIn or Twitter. It speeds up the search and makes the result more reliable. The idea is that if X thinks it is good/nice/beautiful, we will probably think it is good/nice/beautiful too. There is also the option to ask questions and really discuss the product or service you need information about.
Consumers talk about all sorts of products (offline and online), from new detergents to new car models. And it is not just young people who are sharing their experiences about products and brands. Young and old, male or female: everyone does it. All these recommendations between consumers are worth gold.
We can illustrate this with an example: computer manufacturer Dell assumes that 25% of its customers choose their brand after it has been recommended by another user. The average purchase value per customer is about 210 dollars. Based on this amount, the value of every recommendation is estimated at 42 dollars. The more consumers Dell can convince to buy its products, the more money it makes.
However, the reverse is equally true: bad word-of-mouth advertising can have devastating effects. Particularly in this age of social media, a bad reputation does not take long to spread.
Social media in 2014
Perhaps Facebook will no longer exist in ten years' time, but it will most certainly have been replaced by something else. Social media are here to stay. It is therefore important for companies to build a good social media strategy. They can start by thinking about which channel they want to use for which content and objective. What do you need to take into account?
- Content (the message to the consumer) is still the key part, but the importance of segmentation is increasing. The audience is varied, so not all content and every channel is suitable for everyone. As a company, it is best to divide your target audience into sub-target groups. You can then choose specific content and a channel per sub-target group.
- Create real-time content: define a number of key moments in the year in advance and use these wisely. The World Cup, back to school, the summer holidays, etc. are all events that happen regularly and companies can respond to in a clever way. The trick is to find a good link between the key moment and your product. Be creative in this respect. If a school bag brand presents its content at the end of August, it will have to use an original approach to avoid coming across as predictable.
- Social media are predominantly a mobile story: most consumers are switching to smartphones and tablets. It is no coincidence that the four best-known social networks are also in the list of most popular mobile apps: Facebook, YouTube, Instagram and Twitter. In any case, your content (both on the website and on social media) will have to be mobile-friendly.
- The importance of customer care is only increasing. Consumers will now use social media more than ever to find information, ask questions and make comments.
E-commerce: the 3 steps to success
Which stages should a company that is venturing into e-commerce go through? And how do you avoid customers and employees getting stressed and frustrated in the process?
Phase 1: managing the channel conflict
When a manufacturer, distributor or importer starts selling the products they previously only sold to shops online themselves, the shops may experience that as a channel conflict. Their supplier has now become a direct competitor benefiting from low start-up costs as well as more customer convenience. But does the supplier have a choice? If the supplier does not sell online, some customers will go to a seller who does. The solution? Benny Sintobin, Manager of e-commerce specialist Frucon²:
"The channel conflict is a perception debate that is more emotional than rational. E-commerce is unavoidable, so you had better adjust. The roughest edges of the channel conflict can be smoothed out by being a ‘friendly’ online store. With that I mean that you have to approach it correctly, with empathy for the party that may be at a disadvantage. You have to be bold enough to tell the customers of your distribution channel in advance what you are planning and which rules you are going to follow. If you start up everything on the quiet, you will cause frustration and negative emotions."
And these are totally unnecessary, because the new situation can be favourable to the distributor or shop as well. The distributor's online sales channel can also refer to his customer's website or shop, for example. Benny Sintobin:
"Take a bicycle manufacturer offering bicycles to customers online, for example. The website could allow consumers to combine certain materials and colours online in order to create a personalised model. The bicycle can be sent by courier, but can also be delivered to a retailer near the customer for the customer's collection. In that case the retailer will have to be satisfied with a smaller margin and the fact that he has gained a new customer, who will come back later to buy a helmet or a bicycle bag or to have his bicycle serviced. The other members of his family will follow his example for their bicycles and accessories. That way everyone wins."
Downward price spiral
When you say channel conflict, people almost automatically think about a price war between shops competing with online sales channels offering the same products at a lower price. According to Benny Sintobin it is therefore important to put a fair, correct price on the products:
"When manufacturers engage in e-commerce themselves, they set the product's retail price. The price is there online in black and white. In that case shops can rarely afford to charge a higher price. That is why the pricing must be correct, so that shops can still earn a living.
In practice a channel conflict often causes the reverse phenomenon: it is usually not the manufacturer, but the shops starting the downward price spiral. That is in fact the biggest threat to e-commerce: the shop trying to hurt the supplier. Major players striving towards market dominance can afford to destroy their profit margins. However, smaller manufacturers and brands cannot compete in such a price war. This proves once again the importance of making good e-commerce arrangements."
Phase 2: geographical expansion
Once the channel conflict has been well and truly digested, it is time for the next phase: tapping into new markets. For larger SMEs e-commerce is often a perfect way to gain more of a market share. For example, take a Belgian brand that achieved a nice market share in Belgium by selling in retail points as well as through its own online sales channel. Perhaps the brand has developed some brand awareness abroad through a couple of shops in the capital, for example. Benny Sintobin:
"In that case it is entirely possible that some consumers abroad know the brand already, but are unable to get to the shop because of the distance. It would be very unfortunate not to take control of that potential channel yourself and to leave it to Amazon, would it not? Online your products are available to all customers. Conclusion: expansion abroad with an e-commerce channel could be the first low-hanging fruit that is therefore easy to pick."
Phase 3: reinventing your business model
The third phase in e-commerce is a leap in the dark. Company thinking is traditionally product-, market- and wholesale-oriented. Take a company manufacturing or importing pots and pans, for example. That product is part of the world of cooking and dining, but still the sales strategy traditionally focuses completely on the product. However, the online activities offer opportunities to change tack and create an entire world around the particular product. You can work with other companies in that respect: a publisher to create content about dining, a candle manufacturer, a herbs specialist, a table linens manufacturer, a supermarket offering home delivery, etc. Benny Sintobin:
"Around Valentine's day or other key moments of the year you can create content and an entire world where those pots and pans belong. In that case what you sell online becomes more of an experience than a product. The effect is further strengthened if each of the partner companies present that experience on their sites as well. That way you enter each other's customer base and target groups. And you also immediately make sure that your social media really start to work for you. Consumers will tend to like a Valentine's experience more than just a set of pots and pans. In other words, you become a "love brand" rather than just an everyday product."
3 damaging e-commerce blunders
- You fail to inform the customers of your distribution channel of your e-commerce plans and you do not agree on clear rules. Clear arrangements make good business partners.
- You fail to gain sufficient support from all your company's employees. Non-believers and sceptics are best convinced with figures and orders. And you should make sure that dreamers keep both feet on the ground: Rome was not built in a day.
- You focus on bonus systems rewarding targets in a single sales channel. Commercial employees getting a little extra for the sales figures in actual shops are not happy with rising online sales figures, even though they benefit the entire company.
Do not miss the e-commerce boat!
Belgium is rarely ever first in embracing new technologies and their commercial possibilities. The country is not exactly a pioneer in e-commerce either. Unfortunate? It is!
First of all, it is a missed commercial opportunity. What is more, Belgian businesses are at risk of falling so far behind that it will become difficult to catch up. Compared to foreign web stores, the Belgian players are small: the large online stores are usually in foreign hands. The web store names may end in ".be", but behind the scenes you will find companies based in Belgium's neighbouring countries, the UK or the US.
According to the retail federation Comeos, this is partly because Belgian e-commerce is battling foreign dominance with unequal arms. Labour costs and VAT rates are higher here, for example.
Shopping without borders
Until now it has mainly been the European and US web shops doing well. If the Chinese web shops become equally popular, Comeos fears the trend will become unstoppable. The market will be flooded with extremely cheap gadgets and electronics at bargain prices. Fakes? Perhaps. With a guarantee? Who knows. The fact is that Belgian and European web shops are already becoming nervous.
"This is not without reason," according to Benny Sintobin, who has been running his own web shop for twelve years. His company Frucon² also designs and manages online sales channels for other companies. “E-commerce is global and super local at the same time. Global, because the competition is becoming worldwide. A young man from a small village in Belgium can see a longboard by a graffiti artist in California and buy it online. Logistics models will further adjust to this globalised trade. The price war is also constantly intensifying. As a brand, you had better be ready to join this worldwide game.
Super local means that you can order a loaf, some milk and some cheese at midnight and have those products ready for you at your front door at half past six in the morning. Just like in the good old days when the milkman made home deliveries, only the note on the door for the milkman has now been replaced with an electronic order. Something like that can only be organised super locally."
Waiting is no longer an option
At the moment people are afraid of worldwide competition, but fear is a poor advisor of course. The market is gradually evolving towards more e-commerce. Nobody can stop this trend. In some sectors almost half the products are now sold online. Tourism is a classic example of a sector that has taken to the internet like a duck to water. Other sectors, like household appliances, have a more modest e-commerce share for now, but this can change quickly. Even products you may not expect to do well on the internet are being sold online more and more. Take the fashion sector, for example. Clothes involve pure emotions, and colour and fit are hugely important, and yet e-shops for clothes are doing extremely well.
Internet giant Google has even predicted that in time, 40% of B2C transactions will be online. An important part of this will involve reservations, where an order is prepared in store for collection by the consumer. Another part will be actual home delivery.
Companies have to keep up with this trend, and by that we do not just mean the multinationals. A sense of size and scale is necessary, though. According to Benny Sintobin, the calculation is a simple one:
"Imagine a company achieves a turnover of 10 million euros in a sector where 5% of sales are achieved in web shops. Let us say that the e-commerce potential of the entire sector is 10%. Then the company primarily has an e-commerce potential of 1 million euros. You also need to take into account that there will be a channel shift during the start-up phase, whether you like it or not: customers who are used to buying in an actual shop will now make some of their purchases online. It is swings and roundabouts... except if you can increase the online margin."
4 reasons why customers buy online
- 40% (!) because of the price
- 20% because of the convenience: choosing, ordering and delivery at home
- 20% because of its uniqueness: much wider choice, opportunity to personalise, etc.
- 20% because of the availability: all models, colours and sizes are (almost) always in stock