EU GDPR – Digital Marketing – European Commission – General Data Protection Regulation

What impact will the EU General Data Protection Regulation (GDPR) have upon advertising, media, marketing and social media channels in both the EU and outside?

How important is involvement of IT/web teams, customers, legal, financial, communications and marketing?

EU EC GDPR 2018 description for business and marketing

European Commission GDPR General Data Protection Regulation (image copyright European Commission)

The European Commission GDPR

According to the European Commission:

Fundamental rights

The EU Charter of Fundamental Rights stipulates that EU citizens have the right to protection of their personal data.

Legislation

The new data protection package adopted in May 2016 aims at making Europe fit for the digital age. More than 90% of Europeans say they want the same data protection rights across the EU and regardless of where their data is processed. (European Commission, 2018)

Scope of the GDPR

From the technology consultancy Trunomi (2018):

‘The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy. The key articles of the GDPR, as well as information on its business impact, can be found throughout this site.

An overview of the main changes under GDPR and how they differ from the previous directive

  • IncreasedTerritorial Scope (extra-territorial applicability)
  • Penalties
  • Consent
  • Data Subject Rights
  • Breach Notification
  • Right to Access
  • Right to be Forgotten
  • Data Portability
  • Privacy by Design
  • Data Protection Officers’

 

Australian context for the GDPR

From the Office of the Australian Information Commissioner (OAIC 2018):

Key messages

The European Union General Data Protection Regulation (the GDPR) contains new data protection requirements that will apply from 25 May 2018.

Australian businesses of any size may need to comply if they have an establishment in the EU, if they offer goods and services in the EU, or if they monitor the behaviour of individuals in the EU.

The GDPR and the Australian Privacy Act 1988 share many common requirements, including to:

  • implement a privacy by design approach to compliance
  • be able to demonstrate compliance with privacy principles and obligations
  • adopt transparent information handling practices.

There are also some notable differences, including certain rights of individuals (such as the ‘right to be forgotten’) which do not have an equivalent right under the Privacy Act.

Australian businesses should determine whether they need to comply with the GDPR and if so, take steps now to ensure their personal data handling practices comply with the GDPR before commencement.

Issues of non-compliance

However, Hern in The Guardian (2018) when observing large personal data using companies states:

Privacy policies from companies including Facebook, Google and Amazon don’t fully meet the requirements of GDPR, according to the pan-European consumer group BEUC.

An analysis of policies from 14 of the largest internet companies shows they use unclear language, claim “potentially problematic” rights, and provide insufficient information for users to judge what they are agreeing to.

“A little over a month after the GDPR became applicable, many privacy policies may not meet the standard of the law,” said Monique Goyens, BEUC’s director general. “This is very concerning. It is key that enforcement authorities take a close look at this.”

Impact on Email marketing

Email marketing software company MailChimp (2017):

The scope of the GDPR is very broad. The GDPR will affect (1) all organizations established in the EU, and (2) all organizations involved in processing personal data of EU citizens. The latter is the GDPR’s introduction of the principle of “extraterritoriality”; meaning, the GDPR will apply to any organization processing personal data of EU citizens—regardless of where it is established, and regardless of where its processing activities take place. This means the GDPR could apply to any organization anywhere in the world, and all organizations should perform an analysis to determine whether or not they are processing the personal data of EU citizens. The GDPR also applies across all industries and sectors…… relevant to MailChimp…

 

…..Expansion of scope; definitions of personal and sensitive data; individual rights: EU citizens will have several important new rights under the GDPR, including the right to be forgotten, the right to object, the right to rectification, the right of access, and the right of portability and stricter processing requirements’

 

However, the most significant issue are the stricter consent requirements:

Stricter consent requirements

Consent is one of the fundamental aspects of the GDPR, and organizations must ensure that consent is obtained in accordance with the GDPR’s strict new requirements. You will need to obtain consent from your subscribers and contacts for every usage of their personal data, unless you can rely on a separate legal basis, such as those found in number 5 below. The surest route to compliance is to obtain explicit consent. Keep in mind that:

1 Consent must be specific to distinct purposes.
2 Silence, pre-ticked boxes or inactivity does not constitute consent; data subjects must
explicitly opt-in to the storage, use and management of their personal data.
3 Separate consent must be obtained for different processing activities, which means
you must be clear about how the data will be used when you obtain consent. (MailChimp 2017).

Consent would appear to be both central to compliance and rights of privacy yet problematic for much existing practice in ‘marketing’.

Best Practice Marketing

Meanwhile in Australia Hanson (2018) argues in ‘Mumbrella’ that it’s best practice for both business and customers:

For Australian businesses that want to better serve their customers, the GDPR signals the end of activities that marketers should have abandoned long ago. This means that it’s no longer good enough to buy a mailing list, nor is it appropriate to send cold-call emails or, heaven forbid, actually send spam.

Under the new rules, customers have to explicitly opt-in to getting your communications. In the old days, it was fine to pre-tick boxes on a web form allowing you to send a customer marketing emails. Now you can’t do that. Instead, customers have to give consent to you communicating with them, and that consent needs to be clear, in plain English, as well as informed, specific, unambiguous and revocable.

How to implement GDPR?

What does this mean for marketing in a digital environment or system? According to the Digital Marketing Institute (2018):

Step 1. Get your privacy policy page up to scratch

Step 2. Audit your current databases for opt-in consent

Step 3. Re-opt-in campaigns for current databases

Step 4. Create a process for opt-in consent

Step 5. Get the sales team on board

Step 6. Review third-parties who have access to your databases

Step 7. Have a streamlined process for information requests

Step 8. Prepare for a security breach.

 

In the short term the direct impact is neither selling nor buying of client email lists, but clear or voluntary consent or opting-in, through organic collection of prospective and existing clients’ details, how?

Using digital marketing techniques for organic inbound SEO search engine optimisation traffic as not just strategy but a living system to attract prospective clients over time. This will ensure compliance and allow prospective clients to opt-in voluntarily for newsletters, follow up etc. with the peace of mind their data will be private and not be shared.

However, organic inbound SEO requires cooperation and input across departments to share inter disciplinary expertise whether strategic management, IT, legal, finance, logistics, marketing, communications and importantly, customers or clients.

 

Reference List:

Digital Marketing Institute, 2018, ‘Trends & Insights: The Definitive GDPR Checklist for Marketers’, 5 April, viewed 7 July 2018, < https://digitalmarketinginstitute.com/en-au/blog/05-04-2018-the-definitive-gdpr-checklist-for-marketers >

European Commission, 2018, ‘Data protection in the EU’, viewed 7 July 2018, < https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en >

Hanson, G 2018, GDPR is a great thing for Aussie marketers, Blog, 13 June, viewed 7 July 2018, < https://mumbrella.com.au/gdpr-is-a-great-thing-for-aussie-marketers-522988 >

Hern, A 2018, ‘Privacy policies of tech giants ‘still not GDPR-compliant’’, The Guardian, 5 July, viewed 7 July 2018, < https://www.theguardian.com/technology/2018/jul/05/privacy-policies-facebook-amazon-google-not-gdpr-compliant >

MailChimp, 2017, Getting ready for the GDPR, MailChimp Blog, 9 Oct 2017, viewed 7 July 2018, < https://blog.mailchimp.com/getting-ready-for-the-gdpr/ >

OAIC Office of the Australian Information Commissioner, 2018, ‘Privacy business resource 21: Australian businesses and the EU General Data Protection Regulation’  <  https://www.oaic.gov.au/agencies-and-organisations/business-resources/privacy-business-resource-21-australian-businesses-and-the-eu-general-data-protection-regulation > 7 July 2018.

Trunomi, 2018, ‘EU GDPR key changes’, viewed 7 July 2018, < https://www.eugdpr.org/key-changes.html >

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Technology in Higher Education – Innovation Policy – Skills – Digital Literacy

Following is an article by Rogoff in Project Syndicate on the adoption, or not, of technology in universities and higher education whether MOOCS, flipped learning model, online or e-learning etc.

From Project Syndicate:

When Will Tech Disrupt Higher Education?

Feb 5, 2018 KENNETH ROGOFF

Universities pride themselves on producing creative ideas that disrupt the rest of society, yet higher-education teaching techniques continue to evolve at a glacial pace. Given education’s centrality to raising productivity, shouldn’t efforts to reinvigorate today’s sclerotic Western economies focus on how to reinvent higher education?

CAMBRIDGE – In the early 1990s, at the dawn of the Internet era, an explosion in academic productivity seemed to be around the corner. But the corner never appeared. Instead, teaching techniques at colleges and universities, which pride themselves on spewing out creative ideas that disrupt the rest of society, have continued to evolve at a glacial pace.

Sure, PowerPoint presentations have displaced chalkboards, enrolments in “massive open online courses” often exceed 100,000 (though the number of engaged students tends to be much smaller), and “flipped classrooms” replace homework with watching taped lectures, while class time is spent discussing homework exercises. But, given education’s centrality to raising productivity, shouldn’t efforts to reinvigorate today’s sclerotic Western economies focus on how to reinvent higher education?…

…Universities and colleges are pivotal to the future of our societies. But, given impressive and ongoing advances in technology and artificial intelligence, it is hard to see how they can continue playing this role without reinventing themselves over the next two decades. Education innovation will disrupt academic employment, but the benefits to jobs everywhere else could be enormous. If there were more disruption within the ivory tower, economies just might become more resilient to disruption outside it.

 

Issues for higher education may emanate from teaching and/or learning tradition or habits, physical size and complexity e.g. silos, self-perception of being leaders not followers, older generations lacking digital literacy making strategic decisions, interests of permanent versus temporary personnel, slow moving and long communication lines both top down vertical, and lateral.

 

Tradition versus Innovation?

 

One could argue that traditional university lectures, religious preaching and political propagation have centred round expert or influencer communicating physically to non-experts in familiar formats that have not been challenged since the time of Gutenberg, duplicator and photocopiers?

 

Further, underlying issue is may be existing personnel, hence processes and systems, preclude taking on new digital technology (optimally) as observed in other sectors due to perceived disruption or lack of encouragement, or even discouragement.

 

Digital or e-Marketing and Communications

 

Marketing and communications in international education was a case in point whereby strategy informed by faculty attendance at international events was replicated in ‘international marketing’ with focus upon events including professional development and networking opportunities, versus marketing grounded in enrolled students on campus (customer journey, relationship management, satisfaction, testimonials, peer influence and word of mouth).

 

Digital or e-marketing arrived by early noughties but at best was used by universities etc. for international marketing as modest ‘budget allocation’ through traditional advertising and promotional channels. Described by some technophobes as something for the domestic ‘web marketing team’ when in fact digital behaviour upends traditional channels requiring bottom up analysis and strategy development, plus KPIs and ROI.

 

Architecture of Higher Education and Policy

 

Another concern with the focus now upon effective, efficient or economic education delivery and digital technology is the specialisation and/or atomisation of those working in all levels of education versus well rounded professionals with skills of content, teaching, learning, design, delivery, assessment, evaluation, administration and technology.

 

Rather than expecting or commissioning sub-contractors to consult with subject matter experts (SMEs), doing ‘instructional design’ (possibly lacking knowledge pedagogy and andragogy), narrow evaluation e.g. of course design only, using doctorate qualified temporary instructors for blended learning or flipped model but lacking skills of teaching; why not multi-skilled educators delivering based upon customer or student learning needs?

FLIPPED Model – Pedagogy or Andragogy in Higher Education Teaching Learning

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FLIPPED Teaching and Learning Model in Higher Education

 

Introduction

 

Nowadays in higher education there is much talk of MOOCS (Massive Open Online Courses), e-learning, blended learning and the ‘FLIPPED’ (Flexible Environments, Learning Culture, Intentional Content, Professional Educators, Progressive Activities, Engaging Experiences, and Diversified Platforms) classroom; what does it mean, what are the issues and solutions?

 

Brief Literature Review

 

One of the first issues to be apparent is that ‘FLIPPED learning’ is under utilised and even when utilised, there maybe sub-optimal delivery for good teaching and learning outcomes (Chen et al., 2014).  Conversely, whether a fee-paying program, compulsory K12 or a MOOC, FLIPPED learning can dramatically increase access (Hazlett, 2014).

 

Flipped classroom is also a benefit to both teaching and learning, with students being exposed to subject content online and participate in active lessons; moving away from teacher directed pedagogy to student centred learning or andragogy (especially important for transition of youth to adulthood).  The benefits are exemplified by less homework issues, question and answer, deeper exploration and those away with illness can keep up.  For teachers it means supporting students in application, reusable, easier individual student attention and more transparency for parents (Mihai, 2016).

 

Another view includes the following benefits: more student control, student centred, content more accessible for students or parents, and more efficient.  However, this is tempered by disadvantages of digital divide or illiteracy, requires significant preparation and front-end input, not good for test preparation and increased screen time (Acedo, 2013).

 

Other related concerns including potential side lining of teachers and their related skills, online content and instructional design can be boring versus active and interesting lessons, excusing bad pedagogy, internet access issues (e.g. Australia has internet speed and bandwidth issues comparing with less developed nations), assuring online content e.g. videos are watched, online content and instructional design can be very time consuming (November & Mull, 2012).

 

What are the issues for FLIPPED model in adult vocation or higher education teaching and learning?

 

The obvious issue is that when developed for K12 it is based upon pedagogic learning theories for children and youth, supported by teachers with strong background in theory and application of teaching, learning, assessment and technology.  However, this may not translate well to adult education, vocational or higher education requiring skills of applying andragogy i.e. matching adult learning styles with instructors, trainers, teachers or lecturers lacking the same education background.

 

What are the differences between pedagogy and andragogy in teaching and learning?

 

Firstly, what do adults bring to learning and how do they learn optimally as identified by Malcolm Knowles?  Knowles identified six principles including internal motivation and self-direction, life experience and knowledge, goal oriented, relevancy, practical and need for respect.  Contrasted with pedagogy in the following table:

 

Andragogy versus Pedagogy in FLIPPED Model for Higher Education

Andragogy versus Pedagogy for the FLIPPED Model in Higher Education

(Education Technology & Mobile Learning, 2018)

 

Reflection on issues and solutions for FLIPPED Model in Higher Education

 

One has experienced online blinded learning in higher education i.e. online MBA with webinars, CPD (Continuing Professional Development) via e-learning platform and vocational training certificate via distance learning and recorded webinars as ‘add-ons’, not well integrated.

 

Issues encountered included lack of teaching, learning, assessment and technology skills in instructional design, lesson planning, delivery of interesting lessons, developing and testing activity resources, creating opportunities for interactivity, involving all students (not just strong or dominant), using existing or old lecture slides for content, technology breakdowns with no disaster plan, not using or updating discussion forums and relying too much on ‘presenting’ versus teaching.

 

Solutions could include CPD like ‘train the trainer’ or in Australia the TAE40116 Certificate IV Trainer & Assessor, however many are not suitable for adult learners whether young or old.  In more diverse international cohorts where English is not the first language, adapt using the Cambridge CELTA (Certificate to Teach English Language to Adults) framework (applied qualification studied full time intensively four weeks including practice and observations).

 

The latter is especially well designed to include all learning theories including pedagogy and importantly andragogy, for student centred communication interaction.  It is based on the PPP model (Presentation, Practice and Production), when applied well is active, interesting, with clear learning outcomes and multi levelled hidden curriculum, in addition to communication skills, when pitched at advanced or proficiency level students (UCLES, 2018).

 

Nowadays with empowered and fee paying adult learners, top down directed teaching and learning of subject matter may neither be accepted nor acceptable?

 

Reference List

 

Acedo, M. (2013) 10 Pros and Cons of a Flipped Classroom. Available at: https://www.teachthought.com/learning/10-pros-cons-flipped-classroom/  (Accessed on: 27 January 2018).

 

Chen, Y; Wang, Y; Kinshuk & Chen, N. (2014) Is FLIP enough? Or should we use the FLIPPED model instead? Computers & Education. 79 pp. 16-27. Available at: https://www.sciencedirect.com/science/article/pii/S0360131514001559

 

Education Technology & Mobile Learning (2018) Awesome Chart on “Pedagogy versus Andragogy”.  Available at: https://www.educatorstechnology.com/2013/05/awesome-chart-on-pedagogy-vs-andragogy.html (Accessed on: 28 January 2018).

 

Hazlett, C. (2014) Parallel Sessions: MOOC meets Flipped Classroom. Available at: https://blog.edx.org/parallel-sessions-mooc-meets-flipped (Accessed on: 27 January 2018).

 

Mihai, L. (2016) Blended Learning: 8 Flipped Classroom Benefits for Students and Teachers. Available at: https://elearningindustry.com/8-flipped-classroom-benefits-students-teachers (Accessed on: 27 January 2018).

 

November, A. & Mull, B. (2012) Flipped Learning: A Response to Five Common Criticisms. Available at: http://web.uvic.ca/~gtreloar/Articles/Technology/flipped-learning-a-response-to-five-common-criticisms.pdf (Accessed on: 27 January 2018).

 

UCLES (2018) Cambridge English Teaching Framework. Available at: http://www.cambridgeenglish.org/teaching-english/cambridge-english-teaching-framework/ (Accessed on: 27 January 2018).

 

Introduction to Digital or e-Marketing for Small Business – Instructional Design

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Topic:  Introduction to Digital or e-Marketing

for Small Business

 

Goal:

Small business owners and/or managers understand the concepts, resources and actions for a digital or e-marketing strategy.

Subject Matter Expert and/or Target Market:

Have the SME covered personally, however I would potentially approach a local business chamber of commerce looking to support local businesses in their marketing and sales.  It could also target a specific sector, like has already been done below, i.e. travel and tourism, or international education sector.

 

Rationale:

Worked in education and training small business related to study abroad in Australia developing a digital marketing strategy covering Central Europe, Turkey, UK and Australia; conventional marketing was too expensive, not transparent and ineffective.

Self-taught using available online resources, became familiar with many techniques and actions, with formalisation of learning through recent MBA course subject ‘e-Marketing’.

In my professional experience, in addition to state university and vocation school marketing managers, many small private colleges precluded any effective digital marketing strategy in favour of expensive conventional advertising and promotion via travel to one off events for international student recruitment; not financially viable in new markets nor medium term market development.

Generally Australia has low very digital literacy amongst managers and owners, including small business, due to legacy industries preferring existing processes, sub-optimal education curricula, demand for immediate simple solutions and lack of innovation.

However, the travel and tourism industry, with state agency support, have had access for over 10 years to an e-Marketing kit, designed for small travel operators to leverage their marketing and sales digitally, both locally in Australia and internationally with global network; it’s been quite successful as world’s best practice.

The advantage is that small businesses with good digital strategy can increase their target market, analyse well, work with their and gain insight into their own customer base and have more significant profile than physically larger organisations.

 

Content Delivery &/or Presentation:

Can be introduced, presented, learnt and assessed via basic understandable steps, requiring participants to bridge differences between conventional marketing or sales, with digital.

 

 The design would include:

 

  1. What is marketing? How do your customers find you? What do they say about you?
  2. Website appearance, design and management and content management systems (CMS)
  3. Social Media how does it work? Which blog and social media?
  4. SEO/SEM How to reach new audiences and markets?
  5. How to evaluate any strategy or system?

 

Teaching and learning resources would include examples of good (and bad) practice via following or analysing a business from its website (social media, blogs, customer feedback etc.), feedback from participants relating to their own business examples.

This should be leading to them being able to assess needs, develop strategy, implement and evaluate, continually.

Outcomes are assessed by learner input, producing a strategy or approach, resources and media e.g. how to create a Facebook page, open a Twitter account, find useful resources etc.; using own PC, laptop, tablet or mobile.

After this overview, e.g. even presenting to actual target audience, could lead to being commissioned for more of the same, and higher-level training courses.