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Like the aria of a grand European opera, the hype surrounding the imminent implementation of GDPR* has reached a fevered crescendo. Now that the GDPR deadline (May 25th) has passed, it’s worth taking a moment to cut through the fog of frenzied activity to take a realistic look at where we now stand.

GDPR is about personal data not corporate management data. The regulation passed in response to revelations of the pervasive disinterest in personal privacy reflected in Facebook’s shifting (and shifty) ‘terms of use’ agreements. In their lazy pursuit of the billions of dollars in low-hanging fruit that this data represented, Facebook changed the deal they originally made with their members by modifying their terms of use behind the scenes with little if any real notice to members about the seismic shift. Rather than forcing US tech firms to cease and desist their use of unenforceable ‘click-wrap’ agreements (100-page contracts that 100% of people agree to without reading them) the EU decided instead to scare the bejesus out of online business information services. Yes, these firms offer data on executives who, after all, are people too, but these firms never were and still aren’t the subject of these laws.

So what is an online business information service to do? Well, now that the period of consultant- and lawyer-driven panic is starting to subside it is worth keeping these guidelines in mind:

Eliminate the dissemination of old/incorrect data. This is accomplished through several easy steps:

  • Update 100% of executive records every year or, even better, every six months, deleting any old record that cannot be positively confirmed;
  • Display the “Last update date” on profiles with executive data;
  • Link to the underlying source URL(s) for the data;
  • Send an email to execs for whom you have an email address; and,
  • Periodically ‘ping’ the source URLs to confirm that they still exist.

Demonstrate respect for the EU as a regulatory body. At the heart of GDPR is the feeling of many Europeans that American tech firms think that regulations are for suckers and deserve to be ‘disrupted.’ The ways to allay this (legitimate?) concern about the Uber-ization of the world’s economy are as follows:

  • Create a page on your site linked from every company/executive profile explaining what you are doing to address the privacy concerns of EU citizens expressed in the GDPR by showing the public sources of the data and the date it was retrieved, explaining that old data is removed, and explaining how to request the removal of data; and,
  • Send EU-based execs an email that they will never read (i.e., with a boring subject line) explaining that their data will be removed upon request.

Demonstrate a legitimate business interest. GDPR explains that contacting EU citizens is acceptable if there is a “legitimate business interest” in doing so. By extension, the firms that enable the contacting of specific people responsible for specific tasks would appear to be a legitimate as well. In other words, a steel wholesaler has a legitimate interest in calling BMW’s purchasing manager so isn’t the role of the data publisher who identifies the specific person at BMW in that specific role simply enabling that effort? But does “legitimate business interest” insulate all direct publishing/marketing firms from the blow-back from a bellowing Bavarian executive?

Remind Europeans of their own corporate transparency laws. On May 14, 2018 the EU passed company ownership transparency rules meant to expose shell companies used for tax evasion and money laundering. Under this rule every EU member state must create a national registry listing the beneficial owners of all registered companies and trusts. The registries (listing individuals with a share of 25% or more of a company) can be accessed by persons of “legitimate interest” including tax advocacy groups, journalists, and by clear extension those firms that assist companies to research registered entities with which they may want to do business. Since ‘the public’ includes the business community (in the same exact way that executives are people protected by personal privacy laws) the employees of those firms, the unions that are a party to agreements with those firms, and the regional/local governments that grant these firms privileges all have a right to know who they are interacting with. That right extends beyond the owners of the businesses to the officers that work for those owners. After all, what if those executives have conflicts of interests due to share holdings, board seats, or compensation from other entities?

So, to summarize, online information services with data on EU executives should not be vulnerable to frivolous lawsuits or EU sanctions if they demonstrate an eager embrace of the principles of all EU regulations about privacy and transparency and show this via the simple application of due diligence.

* The European Union’s ‘General Data Protection Regulation’.


posted by Shyamali Ghosh on May 28, 2018

by Matt Manning

No matter how many articles are written about the critical importance of data to the functioning of a modern enterprise, it remains a fact that keeping critical data up-to-date is only a reality for a handful of well-heeled firms. The senior executives at these companies know that a small slip-up in understanding a prospective or existing customer’s business can make a relationship with that firm difficult to impossible and the size of these deals more than justifies the expense of constant diligence.

But what about the sea of middle managers working for the majority of firms? These are the folks traditionally served by industry-specific b-to-b media. They also frequently have a rat’s nest of data in their CRM systems, their deal sizes are smaller, and they have no budget or time to untangle the messes they inherit.

Enter the Chief Data Officer.

Never has this role been more important. Whether you prefer the metaphor of data as infrastructure or data as a raw material essential to decision-making, there’s no doubt that the person managing your data understands your pain and knows how to assuage it. It is also likely the CDO knows that a dollar spent on clean data yields several dollars in return and knows how to get at this ROI.

Since we work with so many CDOs, we have multiple examples of these ROI calculations here at IEI. Let me share a few scenarios with you.

How much is it worth to truly understand your market share? For less than $15K IEI was able to tell a major US clothing retailer the names of the vendors serving prospects who weren’t their customers, the contact info for purchasing managers at those prospects, and the names and contact information for emerging prospects. The project involved data harvesting, telephone verification, and a whole lot of data wrangling.

What is the value of knowing about new enterprises and operations in your core markets? These new entrants tend to buy everything at first, and the vendors who get in the door first can often have a long, profitable relationship with these firms. Monitoring public filings and news sources for thousands of firms costs less with each passing year, and a one-week edge on the competition may be an annuity that pays off for years to come. We’ve monitored drilling permits, professional licenses, EPA filings, IRS filings, and business news to find this data as soon as it breaks for a wide range of clients, usually for just dollars a day.

Where do my old customers go when they leave their firm? Businesses are increasingly realizing the value of following their happy customers to their new employers. Now a “cold call” is a happy reunion of partners with your old customer basking in the glow of their honeymoon period, when their budget requests are approved more often than not. The process of following and replacing customers in a CRM database or a subscription-based data service is merely a matter of some elbow grease and lean processes applied by a trusted vendor for around a dollar an update. Convert 2% of those updates and you’re probably way ahead of the game.

So when you read the latest report on “data is the next X,” please feel free to skip the hype and get back to basic question: Where are the clogs in my data supply chain that are keeping the revenue from flowing? And, who’s got the Drano?


posted by Shyamali Ghosh on April 25, 2018