guide – tracking compliance within the framework of the general … · 2018. 6. 26. · an email...

48
Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR) Inxmail Professional 4.7.0 / 4.7.1

Upload: others

Post on 18-Aug-2020

0 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR) Inxmail Professional 4.7.0 / 4.7.1

Page 2: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

Version: LFXPRO-A-EN-18-4.7.1-1.0

© 2018 Inxmail GmbH, Wentzingerstr. 17, 79106 Freiburg, Germany Tel.: (+49-761) 296979-0 | Fax: (+49-761) 296979-9 [email protected] | www.inxmail.de

This publication is protected by copyright. All rights reserved, especially the right of translation, reproduction, photocopying or copying in any other form, and storage in electronic form.

Names, trade names, commodity names etc. used in this publication may be brand names or trademarks and therefore subject to legal requirements, despite the fact that they are not labelled as such.

Page 3: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

I

Contents

1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR) 1

1.1 Introduction and overview .......................................................................................................... 2 1.1.1 Personal data in Inxmail Professional ....................................................................................... 2 1.1.2 Tracking in Inxmail Professional ................................................................................................. 3 1.1.3 Unique count tracking in Inxmail Professional 4.7 .................................................................. 3 1.1.4 Tracking permission in Inxmail Professional 4.7 ...................................................................... 4 1.1.5 Obtaining consent for person-based tracking .......................................................................... 4 1.1.6 Interplay between tracking permission and unique count tracking ..................................... 5 1.1.7 Storing personal data ................................................................................................................... 6 1.1.8 Evaluating and using personal data ........................................................................................... 7 1.2 Expanded and changed functional areas in Inxmail Professional 4.7 / 4.7.1 ..................... 10 1.2.1 Obtaining and withdrawing tracking permission ................................................................... 12 1.2.2 Managing tracking permission and enabling the ‘Tracking permission’ property ............ 31 1.2.3 Evaluating and using personal data ......................................................................................... 35 1.2.4 Link parameters .......................................................................................................................... 44

Page 4: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

1

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

The guide "Tracking compliance within the framework of the General Data Protection Regulation (GDPR)" is also available as a download in PDF format in German, English and French.

The EU GDPR (EU General Data Protection Regulation) was agreed on by the EU Parliament on 14 April 2016. It came into force on 25 May 2016. Application of the EU GDPR will become mandatory for all EU member states on 25 May 2018.

Personal data The GDPR is of particular relevance to processing the personal data of EU citizens. In your capacity as an email marketer or Inxmail Professional user, you process your recipients’ personal data, which means that you need to uphold the corresponding GDPR provisions. Very stringent data protection requirements for email marketing already exist in Germany, as stipulated by the German Federal Data Protection Act and the German Telemedia Act; these already cover many of the chief requirements set out by the GDPR.

Person-based tracking The EU GDPR has accorded a new significance to the practice of tracking recipient behaviour on a person-based level, and stipulates stricter penalties and sanctions as far as this is concerned. Within the scope of email marketing, tracking recipient behaviour on a person-based level entails collecting opening and click information and the ability to create corresponding recipient profiles. Recipient profiles can be used as a basis for creating personalised newsletters, for example.

Until now, users gave their consent to person-based tracking by subscribing to a newsletter, or, as was frequently the case, they were simply not informed that person-based tracking would be carried out. If a recipient wished to be excluded from person-based tracking, they would have to entirely forgo subscribing to a newsletter, if applicable, or unsubscribe from a newsletter.

Email marketers such as yourself must now determine whether the declaration of consent you are currently using for newsletter subscriptions also covers consent to personal tracking, as well as whether recipients have the option to withdraw their consent.

In order to ensure a greater degree of legal compliance regarding person-based tracking, you must decouple consent to newsletter subscriptions from consent to person-based tracking and offer a separate option for recipients to provide consent to the latter. Moreover, you must ensure that recipients can withdraw this consent without having to unsubscribe from the newsletter in question, and that this withdrawal is logged in the status history for the consent.

What you will learn from this guide Inxmail Professional 4.7 contains a range of new functions as well as changes to existing functions so that you can implement the requirements set out in the EU GDPR. For example, it includes options to obtain consent to person-based data processing from your recipients, options to withdraw consent and the option to store personal data in an anonymised and therefore GDPR-compliant form.

This GDPR Guide will provide you with an overview of all new and changed functions in Inxmail Professional 4.7. As such, it will also provide you with a detailed overview of what you need to bear in mind if you would like to process data and generally work in a GDPR-compliant manner.

Page 5: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

2

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

At numerous points in this guide, you will be advised to refer to Inxmail Professional user documentation or online help for further, more detailed information.

Additional information You can find further information related to the GDPR on our website.

1.1 Introduction and overview

1.1.1 Personal data in Inxmail Professional

The following contains general information on collecting and processing personal data in Inxmail Professional.

Personalising mailings You use your mailings to draw your customers’ or recipients’ attention to new products, services or offers. Generally speaking, you can send the same mailing to all recipients, or send personalised mailings.

Personal data voluntarily provided by recipients You can personalise mailings by using data or information that recipients have provided to you voluntarily. Examples of this kind of data include first names and surnames that recipients have voluntarily entered into the subscription form for a newsletter.

Based on these information, you can send mailings that address recipients directly by their names, for instance. To do so, you can use a salutation model in Inxmail Professional (Anredebaustein neu anlegen).

Additional options that you can use in Inxmail Professional to obtain personal information voluntarily provided by your recipients are profile management (Webseite "Profilverwaltung") and survey (Webseite "Umfrage") Web pages.

Tracked personal recipient data Alongside collecting voluntarily provided personal information, Inxmail Professional also gives you the option to use your recipients’ behaviour to personalise your mailings. Your recipients’ behaviour relates to the following actions:

• Opening a mailing

• Clicking text and image links

• Downloading images in an email program

These actions carried out by recipients are designated as ‘recipient reactions’ in Inxmail Professional. Based on recipient reactions, you can create interest profiles for your recipients. In this way, you can determine, for example, which recipients clicked the Adventure trips link and which recipients clicked the Study trips link. Based on these clicks, you can form target groups and send recipients further detailed information on their areas of interest. A high degree of personalisation is usually correlated with a high open rate.

You need to obtain the express consent of your recipients in order to rack recipient reactions. (Until application of the GDPR becomes binding on 25 May 2018, it suffices to obtain consent through corresponding prompts in the subscription form.)

Page 6: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

3

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

1.1.2 Tracking in Inxmail Professional

Tracking in Inxmail Professional means following and storing recipient behaviour. Recipient behaviour relates to the following three actions taken by your recipients:

• Opening a mailing

• Clicking text and image links

• Downloading images in an email program

When a recipient opens a mailing, clicks a link or downloads images in their email program, Inxmail Professional can register and store this information.

Unique count tracking (person-based tracking) versus count tracking (anonymous tracking) In Inxmail Professional, recipient behaviour can be tracked on a recipient- or person-based level, or on an anonymous level. Person-based tracking is designated as ‘unique count tracking’ in Inxmail Professional, and anonymous tracking is designated as ‘count tracking’.

Unique count tracking allows a recipient’s behaviour to be directly traced back to said recipient. Count tracking, on the other hand, merely stores a recipient’s behaviour. It does not allow conclusions to be drawn about the recipient themselves.

Example: Link tracking In Inxmail Professional, text and image links can be designated as either unique count or count links.

When a recipient clicks a unique count link, Inxmail Professional stores the recipient’s unique ID. Based on this ID, you can later perform actions such as forming target groups for the recipients who clicked the link. At the same time, the unique click number can be determined for unique count links.

Figure 1: Empfängerkennung speichern

When recipients click a count link, Inxmail Professional stores the number of all clicks made regardless of how many times a given recipient clicked.

Figure 2: Count-Link

1.1.3 Unique count tracking in Inxmail Professional 4.7

Inxmail Professional 4.7 contains a key change related to unique count tracking.

In Inxmail Professional 4.6.3 and previous versions, the data determined through unique count tracking was generally stored in a person-based way. You were required to inform your recipients of this person-based storage.

Page 7: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

4

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Starting with Inxmail Professional 4.7, you have the option to make the form in which the data determined via unique count tracking is stored dependent on the respective recipient’s consent for person-based tracking.

Making the storage option dependent on consent for person-based tracking Starting with Inxmail Professional 4.7, every standard mailing list will contain the advanced property Include consent for person-based tracking. If the value Include (global settings will be ignored) is selected for this property, then Inxmail Professional will determine the value stored for the respective recipient each time unique count tracking is carried out, and store information this in either person-based or anonymised form.

If the value Do not include (global settings will be ignored) is selected for this property, then the value stored for the respective recipient is irrelevant. When this is the case, Inxmail Professional will generally store information in a person-based way when carrying out unique count tracking. This means that when the value No is selected for this property, Inxmail Professional will behave in the same way as Inxmail Professional 4.6.3 and previous versions did.

For more information on this, also see the Storing personal data page 6 section.

1.1.4 Tracking permission in Inxmail Professional 4.7

Starting with Inxmail Professional 4.7, every mailing list will contain the Tracking permission column in the recipient table. Information as to whether each recipient has consented to the recipient-based storage of their data determined through unique count tracking will be saved in the Tracking permission column.

If a given recipient has consented to person-based tracking, this will be indicated by a green tick and Yes ( Yes) next to said recipient’s email address in the Tracking permission column. If no consent has been obtained from a given recipient, this will be indicated by a red circle with a slash through it and the word No ( No) next to said recipient’s name in the Tracking permission column.

Figure 3: Tracking Permission

Consent to tracking permission is either provided or not provided. Statuses such as ‘Consent to tracking permission not yet provided’ or ‘Not yet known whether consent to tracking permission has been provided’ cannot be depicted.

The Tracking permission system column is only included in the individual mailing lists. It is not included in the global recipient list. Tracking permission can only be specified at the list level.

1.1.5 Obtaining consent for person-based tracking

Inxmail Professional 4.7 includes options to obtain or manage consent to person-based recipient tracking in various functional areas. You can also provide your recipients with the option to withdraw consent to person-based tracking once they have given it at any time.

Page 8: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

5

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

The following describes the three main areas in which you can obtain the consent of your recipients to person-based tracking.

Obtaining consent for person-based tracking alongside subscription Inxmail Professional 4.7 includes a new form element for subscription Web pages with which you can obtain your recipients’ consent to person-based tracking when they subscribe to a newsletter.

Figure 4: Subscription form

Obtaining consent for person-based tracking through mailings Inxmail Professional 4.7 includes new link types related to tracking permission that you can integrate into your mailings. By clicking one of these links, recipients can give or withdraw their consent for person-based tracking.

Importing consent when importing recipients Inxmail Professional 4.7 includes the option during recipient import to import the information on consent to person-based tracking stored in the data source.

Figure 5: Tracking permission for imported recipients

1.1.6 Interplay between tracking permission and unique count tracking

When the advanced property Include consent for person-based tracking is assigned the value Include (global settings will be ignored) for a mailing list, then Inxmail Professional generally reviews in

Page 9: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

6

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

connection with unique count tracking whether recipients have given consent to person-based tracking.

Figure 6: Tracking permission

If consent has been given, the data acquired through unique count tracking is stored in a person-based manner. If consent has not been given, the data is stored in anonymised form.

Example: Link tracking If a recipient who has given consent to person-based tracking has clicked a unique count link, this click is stored in person-based form.

If a recipient who has not given consent to person-based tracking clicks a unique count link, this click is stored in anonymised form.

Inxmail Professional reviews at the time in which the click is made whether the respective recipient has given tracking permission.

1.1.7 Storing personal data

If the advanced property Include consent for person-based tracking is assigned the value Include (global settings will be ignored) and the Tracking permission column in a mailing list is assigned the value Yes for a recipient, then Inxmail Professional stores the recipient reactions in person-based form.

If the advanced property Include consent for person-based tracking is assigned the value Include (global settings will be ignored) and the Tracking permission column in a mailing list is assigned the value No for a recipient, then Inxmail Professional stores the recipient reactions in anonymised form.

Example: Link tracking The (stylised) table in which click behaviour is stored appears as follows:

Figure 7: Click table

Data is stored in person-based form for the recipient Jansen. Data is stored in anonymised form for the recipient Petersen.

If the advanced property Include consent for person-based tracking is assigned the value Do not include (global settings will be ignored), then Inxmail Professional stores the recipient reactions in person-based form. The values saved in the Tracking permission column are irrelevant here.

Page 10: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

7

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Example: Link tracking The (stylised) table in which click behaviour is stored appears as follows:

Figure 8: Click table

Data for the recipients Jansen and Petersen is stored in person-based form.

1.1.8 Evaluating and using personal data

The selected form of data storage (person-based or anonymised) affects all functional areas within Inxmail Professional that access the data acquired through unique count tracking.

The following describes the way in which the three main functional areas Target groups, Reports and Actions are affected by the form of data storage.

1.1.8.1 Target groups

Inxmail Professional contains the option to form target groups based on recipient reactions (Auf Empfängerreaktionen bezogene Bedingungen erstellen). For example, you can create a target group that contains all recipients who clicked a certain link in a certain mailing.

In Inxmail Professional 4.6.3and previous versions, this target group contained all recipients who clicked the corresponding link.

Starting from Inxmail Professional 4.7, the way in which recipients belonging to a target group are determined is based on the advanced property Include consent for person-based tracking and, if applicable, the consent the recipient has given to person-based tracking.

Scenario 1

Setting

Include consent for person-based tracking Do not include (global settings will be ignored)

Recipients are determined in the same way as in Inxmail Professional 4.6.3 and previous versions.

Scenario 2

Setting

Include consent for person-based tracking Include (global settings will be ignored)

When determining which recipients belong to a target group, only the recipients who gave consent to person-based tracking are included.

Please note that these scenarios apply at the level of the mailing list. This means that, for example, a recipient may have given their consent to person-based tracking for the Adventure trips newsletter but not for the Study trips newsletter.

Page 11: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

8

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

1.1.8.2 Reports

One key figure included in the Inxmail Professional reports is the number of unique clicks (Wichtige Berichtskennzahlen).

In Inxmail Professional 4.6.3 and previous versions, click behaviour was stored in a person-based way for links with the Unique count setting.

Starting from Inxmail Professional 4.7, the way in which click behaviour is stored depends on the advanced property Include consent for person-based tracking and, if applicable, the consent the recipient has given to person-based tracking.

Scenario 1

Setting

Include consent for person-based tracking Do not include (global settings will be ignored)

Click behaviour is stored in a person-based way, i.e., in the same way as inInxmail Professional 4.6.3 and previous versions.

The (stylised) table in which click behaviour is stored appears as follows:

Figure 9: Click table

Data for the recipients Jansen and Petersen is stored in person-based form.

Scenario 2

Setting

Include consent for person-based tracking Include (global settings will be ignored)

If the recipient has given consent to person-based tracking ( Yes), the click behaviour is stored in person-based form.

If the recipient has not given consent to person-based tracking ( No), the click behaviour is stored in anonymised form.

The (stylised) table in which click behaviour is stored appears as follows:

Figure 10: Click table

Data is stored in person-based form for the recipient Jansen. Data is stored in anonymised form for the recipient Petersen.

Page 12: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

9

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Determining the number of unique clicks Anonymised clicks are unique clicks. Inxmail Professional cannot draw any types of conclusions on recipient data from anonymised clicks. However, Inxmail Professional can differentiate between anonymised clicks. This means that anonymised clicks can be evaluated as unique clicks.

Scenario 1 (Stylised) click table

Figure 11: Click table

Key figure Unique clicks in report

Figure 12: ‘Unique clicks’

Two unique clicks are determined.

Scenario 2 (Stylised) click table

Figure 13: Click table

Key figure Unique clicks in report

Figure 14: ‘Unique clicks’

Two unique clicks are (also) determined.

1.1.8.3 Actions

Actions can be triggered through the Click on a certain link event (Defining an event for the action sequence). Starting from Inxmail Professional 4.7, as a standard, these types of actions will only be triggered for recipients who have consented to person-based tracking.

Page 13: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

10

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

If, for example, you have selected Send action mailing as an action, the action mailing will be sent to recipients who have consented to person-based tracking when they click the Book an appointment link.

Figure 15: Action will be triggered

The action mailing will not be sent to recipients who have not consented to person-based tracking.

Figure 16: Action will not be triggered

You have the option to set up the Click on a certain link event in such a way that the corresponding action is also triggered for recipients who have not consented to person-based tracking.

1.2 Expanded and changed functional areas in Inxmail Professional 4.7 / 4.7.1

Affected levels: • (Standard) mailing list or

• Global settings

Area of application Level Expansions/changes Further information in chapter:

Properties

New property: Include consent for

person-based tracking • Managing tracking

permission and enabling the ‘Tracking permission’ property page 31

Recipient table

No changes -

New Tracking Permission <Name of mailing list> column

• Default value No for all recipients for whom there is no information on tracking permission

• Managing tracking permission and enabling the ‘Tracking permission’ property page 31

• Manually activating and deactivating person-based tracking in the recipient table page 30

No changes -

Page 14: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

11

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Manual recipient import

New step in import dialog: Tracking permission

• Managing tracking permission during manual import page 20

Import automation

Import tracking permission in new Column assignment dialog.

• Managing tracking permission during import automation page 27

Dynamic Web pages

New form fields:

• Grant tracking permission

• Withdraw tracking permission

• ‘Subscription’ Web page page 12

Subscription Servlet New check box for recording tracking permission

• HTML subscription form (‘Subscription Servlet’) page 19

Mailings (editing) Link dialog:

• Changed names for link types

• New link types:

Tracking permission consent link

Tracking permission withdrawal link

• Mailings (editing) – Link types page 35

Mailings (check) New check for Tracking permission withdrawal link

• Mailings (check) page 37

Target groups

New conditions for target groups

based on the Tracking permission column

• Target groups page 40

Actions New actions and events based on the Tracking permission column

New check box: Also perform action if recipient has not provided consent for person-based tracking

• Actions page 38

Reports Changes in the reports. Background:

• Anonymised clicks can be evaluated as unique clicks

• Reports page 42

Page 15: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

12

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

1.2.1 Obtaining and withdrawing tracking permission

1.2.1.1 ‘Subscription’ Web page

1.2.1.1.1 Adding the ‘Tracking permission’ element

Affected level: • Global settings

--

§ GDPR Application of the EU GDPR will become mandatory for all EU member states on 25 May 2018. If you process your recipients’ personal data in your capacity as an email marketer or Inxmail Professional user, you will need to obtain your recipients’ consent to do so. If you send or use several mailing lists, you will need to obtain consent for each of these mailing lists. At the same time, you should provide your recipients with the opportunity to withdraw their consent at any time.

If you would like to collect personal data, you need to directly obtain a declaration of consent when users subscribe to a newsletter. To facilitate this, you need to add the Tracking permission element to your ‘Subscription’ Web page.

‘Subscription’ Web page starting from Inxmail Professional 4.7 Starting from Inxmail Professional 4.7, the template for the ‘Subscription’ Web page automatically contains the Tracking permission element. If you would like to create a new ‘Subscription’ Web page starting from Inxmail Professional 4.7, you can find the Tracking permission element beneath the main element Form.

Detailed information can be found in the section Creating new ‘Subscription’ Web pages page 15.

‘Subscription’ Web page in Inxmail Professional versions prior to Inxmail Professional 4.7 ‘Subscription’ Web pages that you created in Inxmail Professional versions prior to Inxmail Professional 4.7 do not contain the Tracking permission element. If you would like to collect personal data through these Web pages, you will need to update them.

Detailed information can be found in the section Updating existing ‘Subscription’ Web pages page 12.

1.2.1.1.1.1 Updating existing ‘Subscription’ Web pages

Step-by-step To update a Subscription Web page that was created in an Inxmail Professional version prior to Inxmail Professional 4.7, proceed as follows:

1. Open the Web page editor.

2. Select the corresponding Subscription Web page in the overview of Web pages.

Page 16: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

13

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

An information message will be displayed in the Web page editor. This prompts you to update the selected Web page.

Figure 17: Updating ‘Subscription’ Web page

3. Click the button.

A dialog box appears.

4. Confirm the dialog box by clicking OK.

The Tracking permission element has been added.

Figure 18: ‘Tracking permission’ element

Name Description

Tracking permission

§ GDPR

Use this form element to obtain consent to person-based tracking from your newsletter recipients.

Page 17: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

14

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Obtaining consent through a check box

If you select this option, Inxmail Professional generates a check box on the subscription form that the interested party or newsletter recipient will have to enable in order to give consent to person-based tracking.

Figure 19: ‘Tracking permission’ element

The text from the Explanatory text on personalised tracking text field will be displayed alongside the check box.

We recommend enabling this option, since this requires the interested party or newsletter recipient to actively give consent by taking deliberate action.

If the interested party or newsletter recipient enables the check box, the value Yes is set for the Tracking permission column for the corresponding mailing list.

§ GDPR The GDPR (General Data Protection Regulation) will come into effect on 25 May 2018 and immediately require you to obtain declarations of consent for the use of personal data. You can find more detailed information on our website.

Considering consent to have been given through subscription to the newsletter (not recommended)

If you select this option, the text from the Explanatory text on personalised tracking text field will merely be displayed on the subscription form.

We recommend against selecting this option, since this does not require interested parties or newsletter recipients to actively give consent by taking a deliberate action.

When the interested party or newsletter recipient subscribes to the newsletter, the value yes is set for the Tracking permission column for the corresponding mailing list.

§ GDPR The GDPR (General Data Protection Regulation) will come into effect on 25 May 2018 and immediately require you to obtain declarations of consent for the use of personal data. You can find more detailed information on our website.

Page 18: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

15

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

5. Specify your settings in the fields.

6. Save your settings.

You have updated a Subscription Web page that was created in an Inxmail Professional version prior to Inxmail Professional 4.7.

1.2.1.1.1.2 Creating new ‘Subscription’ Web pages Starting from Inxmail Professional 4.7, every Subscription Web page that you create will include the Tracking permission form field as a standard.

Figure 20: ‘Tracking permission’ element

1.2.1.2 ‘Profile management’ Web page

1.2.1.2.1 Adding the ‘Tracking permission’ element

Affected level: • Global settings

--

§ GDPR Application of the EU GDPR will become mandatory for all EU member states on 25 May 2018. If you process your recipients’ personal data in your capacity as an email marketer or Inxmail Professional user, you will need to obtain your recipients’ consent to do so. If you send or use several mailing lists, you will need to obtain consent for each of these mailing lists. At the same time, you should provide your recipients with the opportunity to withdraw their consent at any time.

If you would like to collect personal data, you will need to obtain the consent of your recipients. You can use the ‘Subscription’ dynamic Web page and the ‘Profile management’ dynamic Web page to obtain this consent. You can also give your recipients the option to withdraw their consent to person-based tracking and view the status of their consent via the ‘Profile management’ dynamic Web page. To facilitate this, you need to manually add the Tracking permissionelement to the Subscription element.

‘Profile management’ Web page from release Inxmail Professional 4.7.1 Starting from release Inxmail Professional 4.7.1, the template for the ‘Profile management’ Web page contains the Tracking permission element. If you would like to use this element, you will need to add it manually to the Subscription element.

Detailed information can be found in the section Creating new ‘Profile management’ Web pages page 18.

Page 19: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

16

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

‘Profile management’ Web page prior to release Inxmail Professional 4.7.1 ‘Profile management’ Web pages that were created in Inxmail Professional versions prior to Inxmail Professional 4.7.1 do not contain the Tracking permission element. If you would like to use this element, you will need to update these Web pages.

Detailed information can be found in the section Updating existing ‘Profile management’ Web pages page 16.

1.2.1.2.1.1 Updating existing ‘Profile management’ Web pages

Step-by-step To update a Profile management Web page that was created in an Inxmail Professional version prior to Inxmail Professional 4.7.1, proceed as follows:

1. Open the Web page editor.

2. Select the corresponding Profile management Web page in the overview of Web pages.

An information message will be displayed in the Web page editor. This prompts you to update the selected Web page.

Figure 21: Updating a ‘Profile management’ Web page

3. Click the button.

A dialog box appears.

4. Confirm the dialog box by clicking OK.

5. Click (Add element) in the Subscription form field.

Page 20: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

17

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

The Add new element dialog box is displayed.

Figure 22: Adding the ‘Tracking permission’ element (1)

6. Select Tracking permission.

7. Confirm the dialog box by clicking Add + Close.

The Tracking permission element is displayed in the Subscriptionelement.

Figure 23: Adding the ‘Tracking permission’ element (2)

After the Web page has been saved and published, a check box is displayed on the Web page along with the text from the Tracking permission element.

Note The Tracking permission element must be added separately for each Subscription element.

You have updated the ‘Profile management’ Web page and added the Tracking permission element.

Page 21: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

18

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

1.2.1.2.1.2 Creating new ‘Profile management’ Web pages

Step-by-step To add the Tracking permission element to the Subscription element on the ‘Profile management’ Web page, proceed as follows:

1. Click (Add element) in the Subscription form field.

The Add new element dialog box is displayed.

Figure 24: Adding the ‘Tracking permission’ element (1)

2. Select Tracking permission.

3. Confirm the dialog box by clicking Add + Close.

The Tracking permission element is displayed in the Subscriptionelement.

Figure 25: Adding the ‘Tracking permission’ element (2)

Page 22: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

19

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

After the Web page has been saved and published, a check box is displayed on the Web page along with the text from the Tracking permission element.

Note The Tracking permission element must be added separately for each Subscription element.

You have added the Tracking permission element to the Subscription element on the ‘Profile management’ Web page.

1.2.1.3 HTML subscription form (‘Subscription Servlet’)

Affected level: • (Standard) mailing list

--

To import consent to person-based tracking through your subscription forms, you can expand the forms by integrating an additional check box into them: <input type="checkbox" name="INXMAIL_TRACKINGPERMISSION">

Related Topics » Overview of the parameters contained in the HTML form

» Form for newsletter subscription

1.2.1.4 Integrating the ‘Grant tracking permission’ link type into mailings

Affected level: • (Standard) mailing list

--

The Grant tracking permission link allows you to obtain consent to person-based tracking from your recipients. As soon as a recipient clicks this link in the mailing, the value in the Tracking permission column is set to Yes. § GDPR

Step-by-step To add a tracking permission link to a mailing, proceed as follows:

1. Open the mailing in the Editing workflow step.

2. Click the position in your mailing where you would like to insert the tracking permission link.

3. Click the (Insert link) button.

Page 23: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

20

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

A dialog box appears.

Figure 26: ‘Tracking permission’ link type

4. Select Grant tracking permission to add a link with which the recipient can give their consent to person-based tracking.

Select Withdraw tracking permission to add a link with which the recipient can withdraw their consent to person-based tracking.

5. In the Link address field, specify the URL (https://...) of the Web page to which the link points.

6. In the Link text field, specify a text that will be connected to the link and displayed in the mailing.

If you leave the Link text field empty, the link address will be displayed in HMTL mailings. In text mailings, the link text will be displayed in front of the link address.

7. Enter a (descriptive) name in the Name in the report field. The link will be included in the reports under this name.

8. Confirm your entries by clicking OK.

You have added a tracking permission link to a mailing.

Managing tracking permission during manual import Affected level: • (Standard) mailing list

--

In Inxmail Professional4.7 , the manual import behaves differently depending on the import target:

• Import target (Standard) mailing list, Subscribed tab: Dialog step 3, Tracking permission, is added to the manual import.

• Import target (Standard) mailing list, Unsubscribed tab: The manual import is the same as in Inxmail Professional 4.6.3 and previous versions. Tracking permission cannot be imported.

Background: Recipients who unsubscribe from a newsletter revoke their consent to person-based tracking when doing so. For this reason, Inxmail Professional sets the value in the Tracking permission column to No for all unsubscribed recipients. If these recipients re-subscribe, tracking permission must be obtained from them again.

• Import target Global settings: The manual import is the same as in Inxmail Professional 4.6.3 and previous versions. Tracking permission cannot be imported.

Page 24: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

21

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Background: In Inxmail Professional, the recipient’s consent to person-based tracking is recorded in a list-specific manner. No cross-list value can be defined for the Tracking permission column in the global recipient table.

--

In the new dialog step 3, Tracking permission, you make specifications for the import of new data to the Tracking Permission <Name of mailing list> column. Here, you specify all import settings for the Tracking permission column:

• Assign source column

• Define data format

• Handle import conflicts

Figure 27: Complete ‘Tracking permission’ dialog

Column assignment and conflict handling for all other columns takes place, as was the case with previous releases, during the import steps with which you are already familiar: Column selection and allocation and Import conflicts and special settings.

The following contains step-by-step instructions for manually importing recipient data during the new step 3 of the import dialog:

• Without tracking permission value

• With tracking permission values

Page 25: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

22

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Related Topics » Empfänger (aus Importquelle) importieren

» Schritt 3 des Dialogs: Tracking Permission

» Schritt 3 des Dialogs: Spaltenauswahl und -zuordnung

» Schritt 4 bzw. 5 des Dialogs: Importkonflikte und Sondereinstellungen

1.2.1.4.1 Step 3 (Option 1): No source column with tracking permission available § GDPR

If your source file contains no column with details of consent to person-based tracking, proceed as follows:

Step-by-step Tracking permission: Assign source column

1. In the Source column, which contains details of tracking permission: list box, click Select column.

A drop-down list containing the column names of your source file opens.

2. Select: None available.

Note If you do not specify a value for the Tracking permission column, the default value No will be set for newly created recipients. No means: You do not have consent to person-based tracking for this recipient and the current list.

Existing values of the Tracking permission will be retained for recipients already included in the list.

3. Click Next.

This directs you to Step 3 or 4 of the import dialog: Column selection and allocation.

1.2.1.4.2 Step 3 (Option 2): Source column with tracking permission available § GDPR

If your source file contains a column with details of consent to person-based tracking, proceed as follows:

Page 26: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

23

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Step-by-step Tracking permission: Assign source column

1. In the Source column, which contains details of tracking permission: list box, click Select column.

A drop-down list containing the column names of your source file opens.

Figure 28: Assignment of the ‘Tracking permission’ source column

2. Select the column of your import file that contains details of the recipients’ consent to person-based tracking.

Page 27: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

24

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

The dialog box now displays two further elements: Tracking permission: Define data format and Tracking permission: Import conflicts.

Figure 29: Complete ‘Tracking permission’ dialog

Tracking permission: Define data format Two values are permitted in the Tracking permission column:

Yes (means you have consent to person-based tracking for this recipient and the current list).

No (means you do not have consent to person-based tracking for this recipient and the current list).

3. Enter the tracking permission value from your source file that corresponds to the value Yes for the Tracking permission target column. The system ignores upper and lower case. Blanks are taken into account.

Note If the import result is not as expected, check the following:

If the value Yes for the Tracking permission in your source file contains blanks at the end or at the beginning, these blanks need to be entered into the input field as well. Only this way, the value Yes for the Tracking permission target column will be mapped correctly.

If you would like to import recipient data that you have previously exported from Inxmail Professional, you must enter TRUE as the Yes value for the tracking permission, as the values of Yes/No columns in Inxmail Professional are exported as TRUE/FALSE values.

Page 28: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

25

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

All other tracking permission values are set to No by Inxmail Professional. This also concerns blank tracking permission import values. This means: Recipients for whom no value for person-based tracking exists are handled by Inxmail Professional during the import as if they had refused consent to person-based tracking.

Tracking permission: Import conflicts

4. Enable one of the following options under Import rules for when recipients already exist:

Import rules Description

Leave existing tracking permission values unchanged

Existing tracking permission values in the recipient data record are retained and are not overwritten.

Overwrite existing tracking permission values but not with blank import values

Existing tracking permission values of the recipient data record are overwritten with the values from the import source. If the import source contains column fields without a tracking permission value, the tracking permission value of the recipient data record is retained.

Overwrite existing tracking permission values

Existing tracking permission values of the recipient data record are overwritten with the values from the import source. If there are column fields in the import source that contain no tracking permission value, the corresponding column fields of the recipient data record are set to the value No.

Page 29: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

26

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

The sample preview is updated in accordance with the selected option, so that you can check whether the result meets your requirements:

Figure 30: Tracking permission: Update of the sample preview for import conflicts

5. Click Next.

This directs you to Step 3 or 4 of the import dialog: Column selection and allocation.

Related Topics » Managing tracking permission and enabling the ‘Tracking permission’ property page 31

Page 30: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

27

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

1.2.1.5 Managing tracking permission during import automation

Affected level: • Global settings

--

Inxmail Professional 4.7 contains the following changes to import automation:

• Settings workflow step: Redesign of the dialogs in which you can specify the structure, format and column assignment of the import file:

Inxmail Professional 4.6.3 Inxmail Professional 4.7

Dialog with settings options for the CSV file:

• Settings for the CSV file

• Format of the CSV files

Dialog with settings options for the CSV file:

• Column assignment

• File formatting

• File structure

Figure 31: Import Automation – ‘Settings’ workflow step in Inxmail Professional 4.6.3

Figure 32: Import Automation – ‘Settings’ workflow step in Inxmail Professional 4.7

• Settings workflow step: Import tracking permission in new Column assignment dialog.

Page 31: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

28

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Starting from Inxmail Professional 4.7 , you can import the tracking permission through import automation. To do so, tick the new Column assignment dialog.

Figure 33: ‘Column assignment’ dialog box: Import of tracking permission

In Inxmail Professional4.7 , import automation behaves differently depending on the import target:

• Import target (Standard) mailing list, Subscribed tab: Users can tick the Column assignment dialog to enable it. Tracking permission can be imported.

• Import target (Standard) mailing list, Unsubscribed tab: The Column assignment dialog cannot be ticked and thereby enabled. The corresponding part of the dialog appears greyed out. Tracking permission cannot be imported.

Background: Recipients who unsubscribe from a newsletter revoke their consent to person-based tracking when doing so. For this reason, Inxmail Professional sets the value in the Tracking permission column to No for all unsubscribed recipients. If these recipients re-subscribe, tracking permission must be obtained from them again.

• Import target Global settings: The Column assignment dialog cannot be ticked and thereby enabled. The corresponding part of the dialog appears greyed out. Tracking permission cannot be imported.

Background: In Inxmail Professional, the recipient’s consent to person-based tracking is recorded in a list-specific manner. No cross-list value can be defined for the Tracking permission column in the global recipient table.

Page 32: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

29

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Conflicts workflow step: Separate conflict handling for the values in the Tracking permission column.

Figure 34: Import automation – ‘Conflicts’ workflow step

Critical scenarios: Situation § GDPR An import is in progress, in which values for the Tracking permission column are being imported. While this import is running, the Include consent for person-based tracking system or list property is changed.

Behaviour of the system The system continues to import all data correctly. A change to the system or list property for person-based tracking has no effect on imports that are running.

This means that you have the option to start by gathering data through the automatic import before you enable the Include consent for person-based tracking property.

Related Topics » Import automation

» Edit settings for the CSV file

» Specify format of the CSV data

» Specify file structure

» Manage import conflicts

Page 33: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

30

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

1.2.1.6 Manually activating and deactivating person-based tracking in the recipient table

Affected level: • (Standard) mailing list

--

In Inxmail Professional4.7, the Tracking permission column is shown and can therefore be edited based on the respective relationship:

• (Standard) mailing list > Recipient agent > Subscribed tab: The Tracking permission column is displayed. Double-click a column value to edit it. You can select the value Yes or

No from a drop-down list.

Figure 35: Manual editing of the ‘Tracking permission’ column

Important Be aware that you may only set the tracking permission to the value Yes with the recipient’s explicit consent. You may use person-based tracking for a recipient only if they have granted consent.

Note If you do not specify a value for the Tracking permission column, the default value No will be set for newly created recipients. No means: You do not have consent to person-based tracking for this recipient and the current list.

• Standard mailing list > Recipient agent > Unsubscribed tab: There is no Tracking Permission column.

Background: Recipients who unsubscribe from a newsletter revoke their consent to person-based tracking when doing so. For this reason, Inxmail Professional sets the value in the Tracking permission column to No for all unsubscribed recipients. If these recipients re-subscribe, tracking permission must be obtained from them again. Moreover, recipient data generally cannot be edited in the Unsubscribed tab in Inxmail Professional.

• Global settings > Recipient agent: There is no Tracking Permission column.

Background: In Inxmail Professional, the recipient’s consent to person-based tracking is recorded in a list-specific manner. No cross-list value can be defined for the Tracking permission column in the global recipient table.

Page 34: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

31

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

1.2.2 Managing tracking permission and enabling the ‘Tracking permission’ property

Starting from Inxmail Professional 4.7, there are two settings that affect how Inxmail Professional handles personal data:

• The value in the Tracking permission column ( Yes or No) for the individual recipients.

• Enabling or disabling the ‘Include consent for person-based tracking’ advanced property (tracking property for short):

for all recipients in Inxmail Professional (= global tracking property) or

for all recipients on a list (=list-specific tracking property).

1.2.2.1 Effects of tracking permission and ‘Tracking permission’ property

Enabling or disabling the Include consent for person-based tracking advanced property (tracking property for short) has the following effects.

Tracking openings The way in which Inxmail Professional tracks mailing openings changes based on whether the tracking property has been enabled.

Tracking property enabled Tracking property not enabled

Inxmail Professional queries which value is stored in the Tracking permission column for each recipient.

• Yes: The recipient is tracked in a person-based manner.

• No: The recipient is tracked in an anonymised manner.

Inxmail Professional tracks all recipients in a person-based manner, regardless of which value is set in the Tracking permission column.

Page 35: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

32

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Tracking links and graphic call-ups The functionality of the Unique count tracking type changes depending on whether the tracking property has been enabled. The tracking property has no effect on the Total count and No count tracking types.

Tracking type Tracking property enabled Tracking property not enabled

Total count No effects. Recipients will never be tracked in a person-based manner.

Unique count Inxmail Professional queries which value is stored in the Tracking permission column for each recipient.

• Yes: The recipient is tracked in a person-based manner.

• No: The recipient is tracked in an anonymised manner.

Inxmail Professional tracks all recipients in a person-based manner, regardless of which value is set in the Tracking permission column.

No count No effects. Recipients will never be tracked in a person-based manner.

Importing and editing tracking permission The options for importing and editing tracking permission values for individual recipients do not depend on whether the tracking property has been enabled.

This means that you have the option to start by gathering and preparing data through the various import and editing options before you enable the Include consent for person-based tracking property.

Inxmail Professional functional area

Tracking property enabled Tracking property not enabled

Subscription Web page No effects. Recipients can grant or withdraw tracking permission at any time through the Tracking permission element.

HTML subscription form (‘Subscription Servlet’)

No effects. Recipients can grant tracking permission at any time through the registration page you have created.

Clicking the Tracking permission link type

No effects. Recipients can grant tracking permission at any time by clicking the Tracking permission link type.

Clicking the Withdraw tracking permission link type

No effects. Recipients can withdraw tracking permission at any time by clicking the Withdraw tracking permission link type.

Manual importer No effects. You can import information on tracking permission at any time.

Page 36: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

33

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Automatic importer No effects. You can import information on tracking permission at any time.

Manual editing in the recipient table

No effects. You can edit information on tracking permission at any time.

SOAP API No effects. Information on tracking permission can be imported at any time.

REST API No effects. Information on tracking permission can be imported at any time.

1.2.2.2 New ‘Tracking permission’ column in the recipient table

Affected level: • (Standard) mailing list

--

In order to record consent to person-based tracking, the Tracking permission column has been added in Inxmail Professional 4.7. In Inxmail Professional, consent to person-based tracking is recorded by list and only stored for subscribed recipients. There is no Tracking permission column in Global settings > Recipient agent; this only includes the list-specific Tracking Permission <Name of mailing list> columns in the > Subscribed tab.

Two values are permitted in the Tracking permission column:

• Yes (means you have consent to person-based tracking for this recipient and the current list).

• No (means you do not have consent to person-based tracking for this recipient and the current list).

Recipients for which no value for person-based tracking exists are handled by Inxmail Professional as if they had refused consent to person-based tracking. This means that the standard value No is entered into the Tracking permission column for these recipients.

1.2.2.2.1 Changing the tracking permission value You can change the value for the Tracking permission column using the following options:

• Manual editing in the recipient table

• Import through manual importer

• Import through import automation

• Transfer via SOAP API

• Transfer via REST API

Page 37: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

34

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

The recipient has the option to change the value for the Tracking permission column by issuing or withdrawing tracking permission via the following options:

• ‘Subscription’ Web page

• HTML subscription form (‘Subscription Servlet’)

• Grant tracking permission link type

• Withdraw tracking permission link type

Related Topics » Obtaining and withdrawing tracking permission page 12

1.2.2.3 New property: ‘Include consent for person-based tracking’

Affected level: • (Standard) mailing list and

• Global settings

--

There is a new advanced property starting from Inxmail Professional 4.7: Include setting for person-based tracking (tracking property for short).

The tracking property can be set at two levels:

• Global

• List-specific

List-specific settings can be set to be coupled with or decoupled from the global settings.

The following contains find information about:

• What effects the tracking property setting has.

• How you can set the tracking property to be global or list-specific.

1.2.2.3.1 Enabling or disabling person-based tracking You can determine the advanced property Include setting for person-based tracking (tracking property for short) at the following places:

• On the (Global settings) tab > Properties agent. Here you enable or disable a check box:

(means enabled)

(means not enabled)

Note In the tab (Global settings) the Properties agent is only visible to users with the role ‚Administrator‘ and ‚Main user‘.

• On the tab of the mailing list > Properties agent. Here you use a drop-down list:

Apply global settings: If selected, the setting from the (Global settings) tab > Properties agent is applied. Depending on what is set in the global properties, the tracking property for this list is enabled or not enabled .

Yes (global settings will be ignored) (means enabled)

No (global settings will be ignored) (means not enabled)

Only certain users can view the Properties agent or the Advanced properties area contained within it (the user must be assigned the corresponding right).

Page 38: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

35

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Related Topics » Setting up the properties of mailing lists

1.2.3 Evaluating and using personal data

1.2.3.1 Mailings (editing) – Link types

Affected level: • (Standard) mailing list

--

Inxmail Professional contains the following link types:

1. Text and image links

2. Unsubscribe links

3. § GDPR Tracking permission links

You can integrate the various link types into a mailing by clicking (Insert link) in the mailing editor. The Insert link dialog box is then displayed.

Figure 36: Link types in Inxmail Professional

1. Text and image links There are three different types of text and image links. These differ in terms of the way in which Inxmail Professional tracks recipients’ click behaviour.

Unique count link (unique clicks) For this type of tracking, Inxmail Professional determines two key figures for text and image links:

• Number of clicking recipients (‘unique clicks’)

Page 39: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

36

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Here, only one click is counted per recipient (initial reaction). This means that if the same recipient clicks a link with this type of tracking several times, only one click will be counted.

In the Inxmail Professional reports, the number of clicking recipients will be displayed under Unique clicks.

• Total number of clicks (‘All clicks’)

Here, the total number of clicks is counted. This means that if the same recipient clicks a link with this type of tracking several times, each click will be counted.

In the Inxmail Professional reports, the total number of clicks will be displayed under All clicks.

Total count link (all clicks) For this type of tracking, Inxmail Professional determines one key figure for text and image links:

• Total number of clicks (‘All clicks’)

Here, the total number of clicks is counted. This means that if the same recipient clicks a link with this type of tracking several times, each click will be counted.

In the Inxmail Professional reports, the number of clicking recipients will be displayed under All clicks.

No personal data is stored for this type of tracking. This means you can’t tell if the clicks were made by various newsletter recipients or by just a single newsletter recipient. Inxmail Professional only stores the absolute number of clicks.

No count link (no counting) This setting does not involve any type of tracking for text and image links. A no count link (no counting) only makes the link functionality available.

2. Unsubscribe links

Unsubscribe link – transferring predefined settings from the ‘Subscriptions’ agent For this unsubscribe link, the predefined settings are automatically transferred from the Subscriptions agent.

Note Predefined unsubscribe links are inserted statically into mailings. This means that if you change your predefined unsubscribe link in the Subscriptions agent, these changes will notbe applied to unsubscribe links already inserted into mailings.

Unsubscribe link – immediate unsubscription and forwarding to success message For this unsubscribe link, you create an individual unsubscribe link that directly starts the unsubscribe procedure set up in the Subscriptions agent > Cancel subscription tab.

Unsubscribe link – unsubscription via unsubscribe Web page For this unsubscribe link, you create an individual unsubscribe link that initially brings the recipient to the ‘Confirm unsubscribe’ dynamic Web page (‘Confirm unsubscribe’ Web page). The unsubscribe procedure set up in the Subscriptions agent > Cancel subscription tab is not started until the recipient has confirmed their unsubscription on the ‘Confirm unsubscribe’ dynamic Web page.

Page 40: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

37

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

§ GDPR3. Tracking permission links

Grant tracking permission The Grant tracking permission link allows you to obtain consent to person-based tracking from your recipients. As soon as a recipient clicks this link, the value in the Tracking permission column is set to

Yes.

Withdraw tracking permission You can provide your recipients with the option to withdraw consent to person-based tracking once they have given it at any time through the Tracking permission link. As soon as a recipient clicks this link, the value in the Tracking permission column is set to No.

1.2.3.2 Mailings (check)

Affected level: • (Standard) mailing list

--

Brief description

This test examines whether there is a tracking permission withdrawal link which recipients can use to withdraw their consent to person-based tracking. A tracking permission withdrawal link is a legal requirement if you use person-based tracking.

Prerequisites The tracking permission withdrawal test will only be carried out if the property Include consent for person-based tracking is assigned the value Include (global settings will be ignored) or the value Apply global settings (include consent) in the advanced properties of the mailing list.

Background § GDPR Application of the EU GDPR will become mandatory for all EU member states on 25 May 2018. If you process your recipients’ personal data in your capacity as an email marketer or Inxmail Professional user, you will need to obtain your recipients’ consent to do so. If you send or use several mailing lists, you will need to obtain consent for each of these mailing lists. At the same time, you should provide your recipients with the opportunity to withdraw their consent at any time.

Possible test results • Green = There is a tracking permission withdrawal link

• Orange = There is no tracking permission withdrawal link

Related Topics » Inserting tracking permission links

» Link types in Inxmail Professional

Page 41: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

38

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

1.2.3.3 Actions

Affected level: • Global settings

--

Starting from Inxmail Professional 4.7, there are two new events and three new actions within action sequences.

New events in Inxmail Professional 4.7

Will be triggered by Will not be triggered by

Grant tracking permission • Clicking a tracking permission link

• Granting tracking permission through a dynamic Web page (see the JSP-Vorlage „Anmeldung")

• Granting tracking permission via a subscription page you have created, see An- und Abmelde-Webseiten selbst erstellen (HTML)

• The action Grant tracking permission

• The action Adopt tracking permission

• Manual import

• Import automation

• Manual changes in the recipient table

Withdraw tracking permission • Clicking a tracking permission withdrawal link

• Withdrawing tracking permission through a dynamic Web page (see the JSP-Vorlage „Anmeldung")

• Withdrawing tracking permission via a subscription page you have created, see An- und Abmelde-Webseiten selbst erstellen (HTML)

• The action Withdraw tracking permission

• The action Adopt tracking permission

• Manual import

• Import automation

• Manual changes in the recipient table

Page 42: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

39

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

New actions in Inxmail Professional 4.7

Description Application example

Grant tracking permission

Automatically sets the value of the Tracking Permission <Name of mailing list> column in a particular list to Yes.

A recipient grants tracking permission for a mailing list (event) – for example, using the grant-tracking-permission link in a mailing. As a result of this, tracking permission for a further list is to be granted (action).

Withdraw tracking permission

Automatically sets the value of the Tracking Permission <Name of mailing list> column in a particular list to No.

A recipient withdraws tracking permission for a mailing list (event) – for example, using the tracking permission withdrawal link in a mailing. As a result of this, tracking permission for a further list is to be withdrawn (action).

Import tracking permission

Imports the value for the Tracking Permission <Name of mailing list> column from a source list to a target list.

A recipient has the possibility to subscribe to various mailing lists, for example, Mailing list 1: Study trips, and Mailing list 2: Adventure trips. If the recipient subscribes to one of the two mailing lists (event), he/she is to be automatically subscribed to a third mailing list used to send out a birthday mailing (Action 1: Subscribe recipient). In the course of automatic subscription to the birthday list, the tracking permission from the original list is to be imported (Action 2: Import tracking permission).

As usual, these events and actions can be combined with other events and actions in Inxmail Professional.

Related Topics » Aktionen

» Ereignis für Aktionsabfolge festlegen

» Aktion - Tracking Permission erteilen

» Aktion - Tracking Permission widerrufen

» Aktion - Tracking Permission übernehmen

Page 43: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

40

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

1.2.3.4 Target groups

Affected level: • (Standard) mailing list and

• Global settings

--

§ GDPR Interplay between tracking permission and target groups related to recipient reactions Note that the recipients determined for a respective target group depend on the advanced property Include consent for person-based tracking.

Detailed information can be found in the section Mailing lists > Fortgeschrittene Eigenschaften.

Scenario 1

Setting

Include consent for person-based tracking Include (global settings will be ignored)

Condition for link

The recipient has/has not clicked a specific link in a specific mailing.

Initial situation

Recipients Clicked link 1 Tracking permission

Jansen Yes

Petersen No

Robertsen Yes

Ulfsen No

The (stylised) table in which click behaviour is stored appears as follows:

Figure 37: ‘Click table’

Page 44: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

41

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Result Condition: Clicked a specific link in a specific mailing

Only the recipient Jansen belongs to the target group.

The recipient Robertsen also clicked Link 1. However, he did not give consent to person-based tracking, so he will not be included in the formation of the target groups.

Condition Did not click a specific link in a specific mailing

Only the recipient Petersen belongs to the target group.

The recipient Ulfsen also clicked Link 1. However, he did not give consent to person-based tracking, so he will not be included in the formation of the target groups.

Scenario 2

Setting

Include consent for person-based tracking Do not include (global settings will be ignored)

Condition for link

The recipient has/has not clicked a specific link in a specific mailing.

Initial situation

Recipients Clicked link 1 Tracking permission

Jansen Yes

not relevant Petersen No

Robertsen Yes

Ulfsen No

Page 45: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

42

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

The (stylised) table in which click behaviour is stored appears as follows:

Figure 38: ‘Click table’

Result Condition: Clicked a specific link in a specific mailing

The recipients Jansen and Robertsen belong to the target group. Both clicked link 1.

The value in the Tracking permission column is not relevant to determining which recipients belong to the target group.

Condition Did not click a specific link in a specific mailing

The recipients Petersen and Ulfsen belong to the target group. Neither of them clicked link 1.

The value in the Tracking permission column is not relevant to determining which recipients belong to the target group.

Reports Affected level: • Global settings

--

One key figure included in the Inxmail Professional reports is the number of unique clicks (Wichtige Berichtskennzahlen).

In Inxmail Professional 4.6.3 and previous versions, click behaviour was stored in a person-based way for links with the Unique count setting.

Starting from Inxmail Professional 4.7, the way in which click behaviour is stored depends on the advanced property Include consent for person-based tracking and, if applicable, the consent the recipient has given to person-based tracking.

Page 46: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

43

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Scenario 1

Setting

Include consent for person-based tracking Do not include (global settings will be ignored)

Click behaviour is stored in a person-based way, i.e., in the same way as inInxmail Professional 4.6.3 and previous versions.

The (stylised) table in which click behaviour is stored appears as follows:

Figure 39: Click table

Data for the recipients Jansen and Petersen is stored in person-based form.

Scenario 2

Setting

Include consent for person-based tracking Include (global settings will be ignored)

If the recipient has given consent to person-based tracking ( Yes), the click behaviour is stored in person-based form.

If the recipient has not given consent to person-based tracking ( No), the click behaviour is stored in anonymised form.

The (stylised) table in which click behaviour is stored appears as follows:

Figure 40: Click table

Data is stored in person-based form for the recipient Jansen. Data is stored in anonymised form for the recipient Petersen.

Determining the number of unique clicks Anonymised clicks are unique clicks. Inxmail Professional cannot draw any types of conclusions on recipient data from anonymised clicks. However, Inxmail Professional can differentiate between anonymised clicks. This means that anonymised clicks can be evaluated as unique clicks.

Scenario 1 (Stylised) click table

Figure 41: Click table

Page 47: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

44

Inxmail Professional 4.7.0 / 4.7.1 | 1 Guide – Tracking compliance within the framework of the General Data Protection Regulation (GDPR)

Key figure Unique clicks in report

Figure 42: ‘Unique clicks’

Two unique clicks are determined.

Scenario 2 (Stylised) click table

Figure 43: Click table

Key figure Unique clicks in report

Figure 44: ‘Unique clicks’

Two unique clicks are (also) determined.

1.2.4 Link parameters

Online parameters So-called online parameters, which are integrated in links for calling some dynamic Web pages, for example, are encrypted from Inxmail Professional 4.7.1.

The [%online_params] command encrypts the online parameters.

If you wish to pass online parameters in unencrypted form to a Web application, for example, you can do this using the [%online_params_unencrypted] command.

Detailed information can be found in the section Commands and Inserting an unsubscribe link.

Passing link parameters dependent on the tracking permission You have the option to make the transfer of personalisation parameters dependent on the consent to person-based tracking.

You use the considerTrackingPermission statement, which is appended to the respective recipient attribute and separated by a comma, to control the dependence on the tracking permission for the transfer of parameter values.

Detailed information can be found in the section Passing link parameters dependent on the tracking permission.

Page 48: Guide – Tracking compliance within the framework of the General … · 2018. 6. 26. · an email marketer or . Inxmail Professional. user, you process your recipients’ personal

Imprint

Editor:

Address:

Telephone:

Telefax:

Email:

Internet:

Author:

Inxmail GmbH

Wentzingerstr. 17, 79106 Freiburg, Germany

+49 761 296979-0

+49 761 296979-9

[email protected]

www.inxmail.de

Inxmail GmbH

About Inxmail More than 15 years of expertise in email marketing: Over 2.000 customers and more than 200 agencies in more than 20 countries worldwide realize successful campaigns and newsletters with the powerful solutions of the email marketing provider Inxmail. The company has subsidiaries in Germany, Italy, France and Australia.

For its excellent customer service Inxmail was honoured with the award "Germany's most customer-oriented service provider" in 2014. Customers include Robinson, s.Oliver and well-known agencies. Inxmail also strongly promotes fair email marketing. It is co-founder and member of the Certified Senders Alliance (CSA).

+49 761 296979-0

Subscribe to the Inxmail Newsletter

[email protected]

Visit the Inxmail Blog