Is Your Hotels Email Marketing List Prepped for GDPR?

Busy hoteliers can find preparing for GDPR overwhelming; understanding requirements and implementing processes while also running the hotel can be very time-consuming. Follow these tips to ensure your hotel’s GDPR requirements are in place for email marketing in advance of the new laws coming into effect in May, while building transparency and trust with your subscribers. 

A Hotel’s Email Marketing List is Invaluable to Marketing

Many savvy hoteliers have built strong email marketing databases over several years that bring in significant revenue in direct bookings. Many contacts are loyal customers and, while they don’t open every email, they do purchase from time to time.  We recently reviewed a sample of clients that are using email marketing effectively and found an average value of €0.58 / £0.49 per contact per campaign. Therefore, despite advice to look for consent prior to May, it is understandable that there is a reluctance to risk reduction of these valuable lists.  

GDPR and Consent to Email Marketing

GDPR experts in recent hotel workshops have advised that without “proof of consent”, hotels should send a re-permission email asking for explicit consent from the subscriber to remain on the list. It is not beyond belief that a re-permission request could lose up to 95% of the database and, for many hotels that have spent years building lists and use them regularly to boost direct sales, this is a drastic step to take.  
GDPR requires that you have proof of consent for each person on your list. The problem for many hotels is that emails may have been added from various sources and they don’t always have proof of consent. If you are unable to supply proof when asked, you could be landed with a hefty fine. 

Legitimate Interest

There is, however, a situation where you don’t require proof of consent if you can make a case for “legitimate interest”.  Legitimate interest applies where there is a relevant and appropriate relationship: for example, where the individual is a customer and where the receiver could reasonably expect to receive communication.  Showing a “balance of interests”, where the individual benefits as much as the sender, helps make a stronger case for legitimate interest. 

Hotels that have built lists with integrity from customers who have stayed, dined, enquired or from people genuinely interested in the hotel will be able to make a case for legitimate interest. On the other hand, hotels that have bought lists, transferred databases from outside companies and generally don’t trust the integrity of the list should not rely on legitimate interest and will need to run a well-planned re-permission campaign.  

Ignoring or avoiding the consent issue is a dangerous approach. We recommend dealing with it head on. Following a database review, hotels should act prior to May 2018 choosing either legitimate interest or re-permission. 

Hotels that can reasonably assume legitimate interest should email their list. The email copy should be specific and clearly in relation to GDPR informing the recipients that they are keeping them on their list on the basis of having a legitimate interest.  The communication should make clear that the recipient can unsubscribe at any time. Hotels should keep a copy of the correspondence and the recipients in their GDPR file to show in case of a query. 

Re-Permissioning Your Hotel’s Email List

Hotels should take this option when they cannot rely on legitimate interest. Setting out a program of 2 to 4 emails, each one explaining the benefits of staying on the list.  Excellent subject lines should be employed to make it as enticing as possible. Remember, many on the list may not open the email if it is not currently interesting to them (even if they might open a subsequent later one when it suits).  Each step should be thought out carefully and explained well. User experience should be considered carefully and supported by good design. Hotels should expect to significantly reduce lists with this option.

After May 2018

Hotels should ensure they are getting explicit consent through the double opt in system on AróConnect and most reputable email marketing packages will have this built in as standard. The advantage of double opt in is that new subscribers know the email address is from a valid, monitored inbox.  To build rapport and trust with subscribers, the hotel’s email communications should present a benefit for the recipient.  

Hotels that apply a good healthy respect for privacy while offering benefits will continue to reap significant reward from email marketing campaigns. 

Learn More About Email Marketing and GDPR

Our email delivery platform, Sendgrid, brought in GDPR legal experts to educate all of us and answer questions. This webcast is 54 minutes long, but well worth a listen to understand legitimate interest versus consent. You can access the webcast via this link.

If your hotel needs any further support or information on GDPR, please contact us.