The RNLI is being forced to re-evaluate and possibly “unpick” some of the decisions it made around opt-in communications, due to updated guidance and advice on GDPR.
Speaking at a GDPR briefing organised by Civil Society Media in London last week, Tim Willett, head of fundraising strategy at the RNLI, said that the organisation made its decision to move to opt-in before any advice or guidance had been made available regarding incoming General Data Protection Regulation. As a result, said Willett, the organisation made some decisions regarding opt-in that it may have to now “unpick”.
“We don’t know all the answers about GDPR, we went early on consent, got that out of the way, but there’s a lot of work still to do on GDPR. Actually if you’re doing it all at once, there’s real benefits to that. We’re having to unpick stuff we’ve already done on opt-in because of what we’re now doing around GDPR.”
The RNLI first announced that it would only be contacting people who had opted-in to hearing from the charity in October 2015. At the time, the charity said the move would potentially cost it £35.6m worth of lost income over a five-year period.
'Tied a couple of big rocks around our ankles'
Willett said that, while early returns from its first few campaigns under opt-in have had better than expected results, the charity’s decision to move to opt-in so early had effectively “tied a couple of big rocks around our ankles”. He said in hindsight, the charity perhaps would have done things differently.
“The ICO and Fundraising Regulator advice on GDPR came out a bit too late for us. We’d already made all of our decisions by then, which is a problem for us,” said Willett. “If I’m being reflective, looking back with a bit of hindsight, we probably tied a couple of big rocks around our ankles that perhaps we wouldn’t have done if we’d known what the guidance was going to be at the time.
“There are things we’ve done that we now need to revisit, and say actually ‘well, we guessed at that. We don’t even know if that’s going to be compliant come next year.’ So we’re going to have to start looking at some of that stuff.”
Willet said that the RNLI faces “the same challenges” when it comes to GDPR as the rest of the sector and said that moving to opt-in ahead of time doesn’t mean the charity “have all the answers” or “a perfect solution” when it comes to GDPR.