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Driving Effective Consumer Consent Management in a Multichannel Environment: Part 2

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January 9, 2018
By: LiveVox

In the first post of this three-part series, we covered why managing consumer consent is important in a multichannel environment. With this second entry, we’ll look at the four components that make up an effective consent management strategy. While each contact center may have variations to their approach based on business need, there are fundamental processes that are key to any multichannel contact center. Let’s take a look at them.

Four Key Processes for Effectively Managing Multichannel Consent 

1) CONSENT ACQUISITION

As we discussed in our first post, obtaining prior consent is sometimes required and, at a minimum, is always a sound risk-mitigation measure. For example, when sending commercial SMS, obtaining prior express consent is a regulatory requirement, unless the system used to send it is not an autodialer. For email outreach programs, obtaining prior express consent is a best practice to avoid getting marked as a spammer and running afoul of certain laws, such as those in New York State. 

Obtaining and managing proper consent can be a complex proposition in a multi-channel environment.  To help manage this, contact centers should define a process across each individual channel for:

  • Integrating consumer consent capture into existing workflows
  • Obtaining consent either electronically and/or via voice recording

2) CONSENT REVOCATION

Every contact center should provide for a well-defined opt-out process. Commercial messages should include a clear notice of the recipient’s right to opt-out of future messages from the sender.

Ideally, the opt-out process is not only clearly defined, but also automatically integrated into your existing workflows.  If your workflows fail to adhere to opt-out requests within a timely manner (e.g., 10 days), your business may be left exposed to regulatory risk.

Below are regulatory guidelines addressing multichannel opt-out requirements.

  • CTIA guidelines are widely used for SMS stop Commercial texts should include ‘Text STOP to opt out’ on each SMS communication sent to a consumer stating very clearly that they can at any time stop receiving SMS
  • CAN-SPAM Act regulates opt-out requirements for commercial email. According to the law, one of the following mechanisms for opting out should be available in a commercial
    • A functional return email address, allowing the recipient to simply “reply” to the email indicating the recipient’s opt-out
    • Another internet-based opt-out mechanism (for example, a link to a separate web page containing the opt-out mechanism) 

3) AUDIT READINESS CAPABILITIES

Another fundamental benefit of a robust consent management strategy is a comprehensive and retrievable database of consent records (both verbal and written). The ability to centralize and index both audio and written records of consent obtainment and revocation are key in an effective risk mitigation strategy.

In addition, the ability to quickly provide proper consent evidence can greatly reduce the cost and resources required if / when a contact center finds itself facing a litigation or audit.

A best practice for TCPA risk mitigation is to maintain consumer consent for at least four years.

 4) CONSENT STORAGE AND MANAGEMENT

As we discussed in our previous post, building a centralized system of record for consent spanning all channels is essential for creating an intelligent multichannel, multi-touch campaign.

Most contact centers today operate in a siloed multichannel environment as a result of leveraging disparate channel applications. These siloed environments pose significant challenges in the consent management process.

If each channel application is siloed, then so is the consent. This disconnection creates a complex, confusing, and high-risk process for multichannel risk mitigation.

For example, if consent for SMS is stored in one location, and consent for voice in another, and email in another, the ability to track which channel the consumer prefers is nearly impossible – especially if consent for one channel is revoked. This restricts contact centers from executing a seamless workflow based on real-time consumer channel of choice. 

How Cloud is Leading the Charge on Multichannel Consent Management

At the core of these four components is the ability to: 

  1. Track and centralize consent in real-time, and
  2. Overlay contact workflows based on the consumer consent for each channel

Doing so with legacy technology has proven extremely complex and costly. Cloud is providing a much simpler and affordable path to achieving this.

To learn how LiveVox’s cloud-based channel of choice solutions can help simplify your multichannel consent management, contact us here.

 

**This publication is not legal advice.  Readers should consult with their own experienced legal counsel to independently review the topics discussed here and independently evaluate any compliance measures they undertake.

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