A New Independence Day?

Photo by 7shifts on Unsplash

How to Manage the Data Requirements of the Lifting of Restrictions and Add Value for Your Customers

This post was originally published on LinkedIn.

News today (Tues 23rd June) that so many businesses in the leisure and hospitality sectors have been waiting so long for – a date when they can re-open and welcome visitors back after 3 long months. Ironically, or is that serendipitously, the date set is 4th July – famous as the date our cousin’s across the pond celebrate their independence – and this isn’t far off how many business owners will feel.

However, it isn’t total freedom. As with retailers and other businesses already reopened and trading, there is a myriad of restrictions and guidelines to follow. There are similarities to those in place in shops, including social distancing policies (though reduced to 1 metre, where appropriate), using protective screens and face coverings as well as managing numbers within a venue. There is one big difference, and that is data collection.

Can I take your order…. and your name?

Customers contact details will be required on entry to pubs, bars and restaurants, as this information will be used as part of the government’s ‘Track and Trace’ programme – but only if it is needed.

However, this does put a significant data burden on brands, as this is a huge amount of new data to collect, compile and store – and what about GDPR?! Yes, that scary-sounding acronym that kept many a marketer and business owner up a couple of years ago. How will this new data collection fit with existing policies?

I see two real challenges:

  • How to collect the data efficiently
  • How to store the data in a GDPR compliant way 

Both can eat away at your precious time, right at the time you need to be focusing on reopening and promoting your offer. However, this can also be an opportunity.

Data Collection

The easiest, quickest, and I would say safest, method of collection would be online before a customer visits your venue. This could be done at the same time as pre-booking their table at a pre-arranged timeslot. This has many benefits:

  • You have all the pertinent information together, including the date and time of the visit and their contact information
  • You can manage capacity at your venue 
  • There will be no need for your staff to fill in forms on site, further limiting face-to-face exposure and increasing focus on customer service 

We all know there is nothing worse than having to try and spell your surname (or worse personal email address you set up in your misspent youth….) out to a member of staff and it adds more stress onto the team too. Also, with restrictions on handling objects, you may not be able to offer customers the ability to fill in anything on site that they didn’t bring themselves.

I do, of course, understand that it may just not be possible to have customers pre-book their visit, and in these circumstances it is worth thinking about opportunities for guests to fill in their details via an online portal, either pre or during their visit.

This could be a simple contact form on your website that triggers an email to their account to confirm they have registered their visit. This could then be shown to a member of staff when they are served, a reliable way to know you have the required data and a more customer-focused experience.

Another option could be linked to any digital solution businesses are using for in-app or online purchases when at the venue. As another restriction is table service only, many pubs will be turning to these options to help cut down face-to-face staff time but maximise sales and speed of delivery. I explored these options in a past article but it is conceivable that many of these will need contact details inputted before service can resume and their login details can be used multiple times to track customers.

Photo by William Iven on Unsplash
Photo by William Iven on Unsplash

Data, Data everywhere!

All this collection is great, but weren’t we meant to be only holding onto data when we get implicit consent from consumers? Are we allowed to even keep this information?

Short answer, and absolutely no surprises here, you certainly can. The General Data Protection (GDPR) Act lays out a series of clauses where you can process personal data without consent. These are:

  • A contract with the individual
  • Compliance with a legal obligation: if you are required by UK or EU law 
  • Vital interests: if it’s necessary to protect someone’s life. 
  • A public task
  • Legitimate interests

Source: Information Commissioner’s Office

This all makes it pretty clear, and the requirements certainly fit into at least three of the criteria listed above. What is more important is how and where you store this data.

Remember, this is not marketing data, customers are entrusting their information with you as part of a government scheme. It is not there for you to use to keep marketing to them after their visit.

This data will have to be kept in a new, separate database to your current marketing mailing lists and should include all the information we discussed earlier.

You can, of course, prompt your customers to sign up to your marketing mailing lists, and positively encourage them, but this is when you need consent, When they do consent and sign up this data will need to go to a completely new database, there can be no bleed over between databases.

Is your head hurting? I know mine is and I’m writing this, and it can be made simpler:

  •  One database for visiting information, including contact details, kept completely isolated
  • Other databases that hold marketing information but are not linked to the entries in the database listed above

This may feel like an incredibly cautious approach. It is, I’m a cautious kind of guy, especially with GDPR, but it also takes away any potential data headaches, leaving you to focus fully on delivering brilliant customer services and getting customers into your venue.

Building Trust and Relationships

Whatever approach you take make sure you showcase it, and your data protection policies, as bold and visible on your website. Ensure that customers know what they are signing up to and why. There will, no doubt, be more advice from the government on the wording of the data collection but as long as you are honest with your customers and tell what information you are keeping, and why, they will come with you.

Once they trust you on this they may very well sign up to your mailing list, as you’re a brand they want to keep engaging with.

None of this will be easy, but it is achievable and we all have an opportunity to build stronger and deeper relationships with our customers, and that is exciting, and potentially more profitable, opportunity for us all.

Happy Independence Day, mine’s a cheeky beer… 🍺

For support on the latest guidance, advice and requirements for operating during COVID-19 please follow this link to the government’s website.

For York Businesses, please follow the link below to a really helpful booklet put together by City of York Council on how you can get your business ready and fit into the wider initiatives taking place across the city – I highly recommend it.