Management Instruction: Marketing E-mail

This management instruction (MI) establishes the Postal Service's policy for marketing e-mail and gives employees guidelines to follow when they write and send marketing messages via e-mail to existing or potential customers. This MI supports the Postal Service Transformation Plan to improve customer service and grow revenue while maintaining our customers' privacy protections.

Date: May 10, 2004

Effective: Immediately

Number: AS-350-2004-4

Obsoletes: AS-350-2003-6

Unit: Advertising and Promotions

Anita Bizzotto
Senior Vice President and
Chief Marketing Officer

 

What Is the Purpose of This Document?

Who is the Audience for this Document?

What Is the Postal Service's Policy on E-mail Marketing?

Policy

Required Procedures

How to Provide Customer Notice

How to Provide Customer Choice

How to Provide Customer Access to Personal Information

How to Provide Customer Redress

How to Provide Customer Security

How to Use Appropriate Technology That Provides Ease of Use and Safeguards Privacy

What is the Policy Approval Process for a Marketing E-mail Campaign?

How Do I Contact the Offices Listed in this MI?

What Definitions Do I Need to Know?

Attachment 1 United States Postal Service Marketing E-mail Guide

Attachment 2 - Marketing E-mail Policy Checklist

What is the Purpose of This Document?

The Postal Service intends for this policy and the guidelines in this MI to do the following:

Standardize the Postal Service's process for developing and sending marketing messages via e-mail.

Ensure that Postal Service marketing e-mail messages meet customers' needs and honor their preferences.

This MI applies when the Postal Service, or its supplier, sends to a customer or prospective customer an e-mail message that markets a different product or service than the customer may already have received from the Postal Service (or refers to a Web site or directs a customer to a Web site that markets such a product or service).

Who Is the Audience for This Document?

This MI applies to the following:

Any functional organization of the Postal Service that initiates or plans to initiate a marketing e-mail message/campaign.

Any third-party supplier initiating or operating a marketing e-mail message/campaign under contract with the Postal Service.

What Is the Postal Service's Policy on E-mail Marketing?

Policy

Postal Service employees and suppliers must incorporate the following elements in the e-mail when a marketing e-mail campaign is conducted by or on behalf of the Postal Service:

Providing customers notice about the e-mail.

Providing customers a choice about being on the e-mail address list.

Providing customers access to personal information that the Postal Service collects and retains on them.

Providing customers with redress about the e-mail, which involves not only feedback but also timely processing of that feedback.

Providing customers with security of personal information that the Postal Service manages, transfers, and stores.

Providing customers with usability and privacy through the use of appropriate technology.

Required Procedures

How to Provide Customer Notice

There are two kinds of required notice:

1. Notice of e-mail sender, content, purpose.

The subject line of the e-mail outlines the purpose and identifies the sender of the e-mail. The subject line is the most critical part of the e-mail (see Attachment 1 for more detailed explanation). The subject line must do the following:

Clearly define the topic of the e-mail (i.e., advertisement or promotion).

Mention the specific product or service that the e-mail promotes.

Identify the sender (i.e., the Postal Service, a Postal Service affiliate, or a supplier on behalf of the Postal Service).

2. Privacy Notice.

The e-mail message must include a reference or link to the Postal Service's privacy policy at www.usps.com. If a customer's response to a marketing e-mail might result in the collection and placement of that customer's data in a system of records (a file, database, or program from which information about customers or employees is retrieved by name or other identifier), the same e-mail that solicits data must contain a privacy notice.

If consumers are the target audience, the notice must read: Privacy Notice

Your information will be used to provide you requested products, services, or information. Collection is authorized by 39 USC 401, 403, & 404.

Providing the information is voluntary, but if not provided, we may not process your transaction. We do not disclose your information without your consent to third parties, except to facilitate the transaction, to act on your behalf or request, or as legally required. This includes the following limited circumstances: to a congressional office on your behalf; to financial entities regarding financial transaction issues; to a USPS auditor; to entities, including law enforcement, as required by law or in legal proceedings; and to contractors and other entities aiding us to fulfill the service (service providers). For more information on our privacy policy, see our privacy link at www.usps.com.

If business customers are the target audience, the notice must read: See our Privacy Policy at www.usps.com.

How to Provide Customer Choice

Customers must be able to choose whether or not they want to receive the marketing e-mail message. This means that you must give customers a way to (1) get on the list (i.e., opt in) and (2) get off the list (i.e., opt out) for future mailings. Follow these steps to ensure that customers have a choice about being on the list:

1. Send the e-mail message to customers that are on a Postal Service house list or the www.usps.com registration list. Customers who have chosen to receive any marketing e-mail messages must be:

Consumers who have opted in.

Businesses that have either opted in or not opted out.

2. Send the e-mail message to prospective customers from a third-party list provider. Customers on such a list must be either of the following:

Consumers who have opted in.

Businesses that have opted in or not opted out.

Follow these steps to provide customer choice in getting off the list:

1. Clearly and conspicuously include an opt out function in every marketing e-mail message that you send customers. An opt out function is an e-mail or other Internet-based mechanism enabling customers to request not to receive future marketing e-mail messages from the Postal Service.

Opt out function must be fully operational for no less than 30 days after the message was sent.

Honor customer choices to opt out within 10 business days after receipt or before the next marketing e-mail campaign (whichever is first).

Opt out applies to the specific e-mail address from which the opt out was sent.

The preferred placement of the opt out function is at the top of the e-mail.

2. Require list providers to validate the methods they use to give customers a choice. All suppliers that provide lists of prospective customers must also document clearly how they confirmed that (1) consumers have opted in or (2) businesses have opted in or have not opted out. List providers must identify the suppression file and merge/purge process used. Forward the documentation that you receive from the supplier to the manager of Segment Advertising.

3. Process the mailing list file for all marketing e-mail campaigns through the central Postal Service suppression file maintained by the Advertising and Promotions department. This allows the Postal Service to merge or purge the list to eliminate the names of customers who have opted out and to consolidate duplicate records of customers.

Honor customer choices to opt in and opt out. Customer requests to opt out must be made within 10 business days after receipt or before the next marketing e-mail campaign (whichever is first). Incorporate all requests to opt in or opt out into the Postal Service suppression file.

How to Provide Customer Access to Personal Information

Customers must be able to access information that the Postal Service collects and retains about them. Customers may access their information depending on how personal data is maintained.

If the Postal Service maintains data on customers. Give customers information on how to access their data and to request corrections or updates to the data.

If the Postal Service uses a supplier to maintain personal data on customers. Give customers information on how to access their data and request corrections or updates to the data. Work with the third-party and agree on how you will provide information to customers.

If neither the Postal Service nor a supplier maintains personal information. Advise customers that neither the Postal Service nor a third-party maintains their personal data.

How to Provide Customer Redress

The customer must be able to provide feedback about the marketing e-mail messages they receive and a process must be in place to respond to their questions or complaints. You must follow these steps to provide customers redress about the marketing e-mail message sent to them:

1. In each e-mail, tell the customer that he or she can provide feedback by replying to the e-mail address from which the marketing message was sent (i.e., originating e-mail address). You must also provide a physical Postal Service address in the e-mail message. The Postal Service has designated the following address to be placed in all marketing e-mail messages:

USPS MARKETING DEPARTMENT
PO BOX 149263
AUSTIN TX 78714-9263

2. Process customer questions or complaints in a timely manner.

How to Provide Customer Security

The Postal Service must provide security and safeguard procedures when managing, transferring, and storing customer information. Follow these requirements:

To ensure confidentiality, show only the individual recipient's name in the e-mail address block or message content.

Add a layer of protection to the transfer of e-mail names by using encryption software in accordance with security policies in Handbook AS-805, Information Security.

Conduct a Business Impact Assessment (BIA) if there is no BIA for the e-mail storage system or if the data collection system or process is newly created, as required per Handbook AS-805.

Contact the Corporate Information Security Office if there are technical concerns about security compliance.

How to Use Appropriate Technology That Provides Ease of Use and Safeguards Privacy

Customers must be able to easily access the marketing e-mail message regardless of the equipment or technology they use, and the technology used must not compromise their privacy. Follow these requirements:

Provide standard, readable formats to allow all customers, regardless of equipment or software, access to the e-mail message.

Never use tracking devices such as beacons and cookies, unless you have prior written approval from the chief privacy officer.

What is the Policy Approval Process for a Marketing E-mail Campaign?

The functional group initiating the e-mail marketing campaign must complete the attached Marketing E-mail Policy Checklist (see Attachment 2) and forward it to the manager of Segment Advertising. The checklist requires (if applicable) the initiating group to do the following:

Obtain approval from the manager of Brand Equity and Design, Public Affairs and Communications, for any use of the Postal Service brand identity design elements in the e-mail message.

Obtain approval on legal and policy compliance for the e-mail message. Send requests to the Customer Protection and Privacy Group in the Office of General Counsel for approval.

Obtain approval from the chief privacy officer for any use of tracking devices such as cookies or beacons in the e-mail message.

Obtain a letter from the supplier, confirming that the supplier is fully aware of and will comply with the marketing e-mail policies in this MI, including the specific information required for choice (see "How to Provide Customer Choice").

Notify the manager of Customer Care Operations (at least 48 hours before the start of the campaign) of when (date and time) and how many e-mails will be released; if the origin of the e-mail is from within the Postal Service intranet; and if the e-mail reply is directed to an address within the Postal Service intranet.

How Do I Contact the Offices Listed in this MI?

For more information on this e-mail policy, contact the appropriate department below:

MANAGER SEGMENT ADVERTISING
UNITED STATES POSTAL SERVICE
475 LENFANT PLAZA SW RM 1227
WASHINGTON DC 20260-1227
CHIEF PRIVACY OFFICER
UNITED STATES POSTAL SERVICE
475 L'ENFANT PLZ SW RM 10407
WASHINGTON DC 20260-2200
MANAGER CUSTOMER CARE
OPERATIONS
UNITED STATES POSTAL SERVICE
4200 WAKE FOREST RD
RALEIGH NC 27668-9300
OFFICE OF GENERAL COUNSEL
UNITED STATES POSTAL SERVICE
475 L'ENFANT PLZ SW RM 6004
WASHINGTON DC 20260-1135
MANAGER BRAND EQUITY & DESIGN
UNITED STATES POSTAL SERVICE
475 L'ENFANT PLZ SW RM 10636
WASHINGTON DC 20260-3100
MANAGER CORPORATE INFORMATION SECURITY
UNITED STATES POSTAL SERVICE
475 L'ENFANT PLZ SW RM 2411
WASHINGTON DC 20260-2411

What Definitions Do I Need to Know?

The following terms are essential to understanding the policy that this MI establishes:

Affiliate - The owner of a Web site that has placed hyperlinks on its site and entered into a formal agreement with another site to send electronic traffic to the other (except as provided in the Uniform Fee Approaches section of MI AS-610-2001-6, Web Site Affiliation Program) site in return for compensation.

House list - A list of current Postal Service customers that have registered for a product or service or provided their e-mail addresses through other means.

Marketing E-mail - An e-mail message/campaign sent by the Postal Service or its supplier, to a customer or prospective customer that markets a different product or service than the customer may already have received from the Postal Service (or refers to a Web site or directs a customer to a Web site that markets such a product or service). The term Marketing E-mail does not include transactional or relationship messages.

Merge/purge - The practice of consolidating e-mail customer lists, eliminating duplicates, and removing names of customers who have opted out.

Opt in - Customer takes affirmative steps to receive marketing e-mail.

Opt out - Customer takes steps to prevent receiving marketing e-mail. Customer elects not to receive or to discontinue receiving marketing e-mail messages.

Personal information - Includes personally identifiable information such as name, e-mail address, mail address, phone number, and preferences for receiving specific marketing messages.

Suppression file - A database of names and e-mail addresses that have opted out from receiving future communications from the Postal Service.

System of records - A file, database, or program from which information about customers or employees is retrieved by name or other identifier.

Third-party provider - Supplier that provides e-mail lists for acquisition and lead generation programs.

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