Monday 30 April 2018

AS soon as my routine tasks are out the way I hit the studio – there’s a lot to do today, but I don’t want it to be at the expense of the songwriting.

I continue evolving the three new tunes and record a new riff/idea before it’s time to get busy with the less fun stuff.

The GDPR legislation is the priority today. I need to look at (a) what to do about my existing mail lists and (b) how to ensure everything going forward is compliant…so some kind of plan is needed to work through it logically,

I start by making sure my mail list signup forms on my website and Facebook page are GDPR compliant…that largely means having an unchecked consent box that will be held on record by the service provider…in my case, it’s Mailchimp. The forms will add subscribers – and their consent – to a brand new list. 

I will have to encourage everyone on my mail lists to re-subscribe to the new ‘consented’ list and delete the old lists when the regulations kick in on 25 May, so my May monthly eNewsletter – which goes out tomorrow (1 May) – needs to focus on this as the initial step in my re-engagement campaign.

While my GDPR to-do list highlights the need to put a privacy policy on my website and link to it from all my forms and stuff, it’s not crucial. Yet. It can wait ’til the more immediate tasks are dealt with. The privacy policy will have to detail what info I gather, why I gather it and what I’ll do with it, underline that I don’t share with any third parties, how I’ll keep the data secure and how folks can access, update or delete their data. I do all this anyway, it’s just not in writing!

That’s quite a lot considering my very basic use of just a name and email address and it’s more in keeping with organisations that request and keep much more personal information but hey-ho..that’s gonna be the rule. 

I offer an exclusive free EP download to folks joining my mail list via a ‘free EP’ menu link and a pop-up window. These forms need an overlay asking for, and recording, consent. That bit takes me a while and I’ll need to further investigate the implications of requiring an email signup to get the free EP…the new regulations are a bit hazy and suggest in some cases the freebie can’t be conditional on someone signing up. I think, though, that, my invitation is specifically to join the mail list rather than use the free EP as a ‘lead magnet’.

Yesterday’s research told me that I didn’t need to register with the ICO (Information Commissioner’s Office)...but that need varies from individual to individual and organisation to organisation.

Looking forward, I need to work out what to do about inviting folks who buy stuff from my online store or sign up to the mail list via the clipboard at live shows. We could keep the sign up sheets, but it would be impractical to have all the info and conditions on there…and even if they did, holding a paper file of all the sheets would be a nightmare, especially if I had to find a specific name.

Until I can think of a better way, my plan is to send online customers and gig signups  a personal ‘thank you’ email and a link to electronically sign up with all the necessary consents.

My head’s kinda fried with all this, so I go out for a walk in the sunshine….and listen to a social media marketing podcast. About the GDPR stuff!

An hour or so later I’m back in the office putting together my May eNewsletter which includes my first re-engagement information. It goes out tomorrow (1 May). I’ll watch the response carefully and use it to help plan how – and how often – I send out information and reminders before the 25 May cut-off.

I may also do some advertising and put up a temporary landing page on the website.

I between times our pals Duncan and Irene drop in for a flying visit, then I make some dinner before returning to the office to get news releases written and sent out about next Monday’s (7 May) show at Broadcast in Glasgow.

That brings up another GDPR issue – media lists! I don’t store journalist and media folks’ info as the contacts change so often…there are some media lists related to my monthly eNewsletter – they’ll be picked up by the re-engagement campaign.

It’s late when I head back to the house. Betty and Joe have popped in so I have a glass of red with them and then crash.

** DISCLAIMER: nothing in this post should be taken as legal or expert advice…it’s merely an account of the measures Dave Arcari is taking in his efforts to comply with the forthcoming EU GDPR regulations

 

Saturday 28 April 2018

WE’RE UP early – Catriona’s pal Catherine is coming at 9.30am to start preparing food for this afternoon’s baby shower.

I’ve a load of work to do anyway, so clear out the house after breakfast.

Another pal arrives around midday to help Catherine, then folks arrive around 2pm.

I say hello, go back to the office and finish of some web work then head up the lochside for a walk. I suddenly remember all the GDPR data protection laws coming into force in May and start to panic a bit.

We take privacy very seriously and don’t share any of my mail list data with any thrid party. Also, we don’t keep any credit card or other data on file and really only have names and email addresses for the mailing list. I’m also able to amend all my mail list sign up forms online to that I can prove I have mail list members’ consent….and I can make everything double opt-in as a belt’n’braces measure.

Furthermore, I have no problem with putting together a privacy policy online and sending anyone who asks precisely what information we hold on them as individuals.

So that’s all good and well and I’m in agreement with  privacy and data protection, but…it seems I need to be able to prove I have consent for any EU resident on my mail list. That’s mostly OK for folks who have signed up via Mailchimp as a record of their consent will exist, but what about the folks who’ve signed up at live shows and I’ve manually added myself to the Mailchimp lists. That’s nearly 20 years worth of email list sign ups from gigs that may have to go in the bin. Nearly 20 years of hard work and meticulous attention to detail potentially down the tubes.

Some folks might argue that a simple mail out to the existing mail lists asking them to re-subscribe will solve the dilemma and that there’s no point in having anyone who doesn’t renew on the list anyway. Fine if the emails reach them. Or they spot the resubscribe email. Too busy. On holiday. Or just forget.

My mail outs have a good open rate. Well above average. I like to think that’s because folks are on the list because they want to be and opted in rather than being harvested form somewhere else and added without permission. Proving that is not so simple.

The folks that don’t open my eNewsletter are not the same folks every month…there’s a million reasons why folks open or don’t open emails. So my one or two chances to hit folks up to resubscribe may not get through to folks that actually do want to stay informed.

Moreover, it may be that any of us maintaining email lists have to register with the ICO (Information Commissioner’s Office) and pay £35 a year (£500 for larger organisations). For what? 

The ICO proudly proclaims that half a million businesses have signed up already. That’s a minimum of over £17m in revenue. Sounds like a scam to me. I’m hoping that – as a Mailchimp user – the service provider may have that taken care of, so long as we don’t maintain any copies of our mail list data.

You probably figured that I;m pretty stressed by this whole thing….making a living from music is not an easy thing to do and this kind of legislation could put some of us under.

For big corporations it’s an inconvenience and a short term drain on human resources. For the hobbyist with day job, it could be a major hassle, but it’s unlikely to threaten their livelihood.

Data protection and privacy is important, but some of these regulations are going to cause small, independent operators some grief and while it’s for the common good in the long term, in many cases it’ seems to be a case of using a sledgehammer to crack a walnut.