Nintendo scrubbed its existing database to identify the ages of the individuals, then got parental permission for each existing and future member. The initial database was reduced to less than half, but a subsequent mailinggarnered a terrific response. Results to this new, parentally OK'd opt-in list was 25,208 total messages delivered, 19,914 total links clicked (79 percent), and only 48 (.19 percent) unsubscribes.
Double opt-in is widely considered (and rightly so) the best, most ethical practice for email marketers growing a mailing list. An individual visits your web site, asks to be added to a mailing list, and submits an email address. The marketer sends a confirmation request to the address, and the individual must reply to the confirmation request, typically by clicking on a link in the email message or by hitting the reply button in the mail program, before being added to the mailing list.
But are there ever cases where double opt-in doesn’t go far enough?
One possible situation that comes to mind is the case of children. When a company’s target audience is individuals younger than 18, especially the early teens and younger, is this practice sufficient?
Nintendo doesn’t think so. It has created an opt-in approach that requires action not only on the part of the user the child but action on the part of the parents as well.
Now, I understand that this is a delicate topic. I’ve asked myself a number of questions about what’s the best way for a company to communicate with kids via email (if at all), but, not being a parent myself, I have little experience with children going online.
Therefore I’d like to lay out the case-study facts here, with little editorial comment on my part, and invite you to send your feedback, comments, questions etc., to me, and I’ll summarize the responses next week.
OK, here goes. Nintendo (Do I really need to tell you what they do? If so, I’ll sum up by saying they’ve sold more than a billion video games), over a period of approximately a year or a year and a half, had built an opt-in list of customers, with more visiting the site and requesting information daily. In many cases, the individuals gave their ages, but in some cases, they didn’t.
Nintendo and @Once, an email marketing company, decided they needed to scrub this database clean it up so they knew as best they could the ages of the individuals and get parental permission for each existing and future member. This was toward the end of last year, and I think it’s important to put this into context by noting that The Children’s Online Privacy Protection Rule, according to The Federal Trade Commission, was going to become effective in April 2000. The ruling spelled out what web site operators need to do with regard to a privacy policy and when and how to seek parental consent. (For more information, I recommend you take a look at http://www.coppa.org/ftc_how_to.htm.)
Michael Eisenberg, the vice president of client services at @Once, notes that Nintendo wanted to develop its online community in a way that was consistent with existing laws, laws such as this on the horizon, and Nintendo’s own policy. So here’s what they did.
To every person under the age of 18 who had opted in (and the list was completely opt-in), Nintendo sent an email form that needed to be downloaded. The form clearly stated that if you want to receive anything from Nintendo, this is what you need to do. The company asked the parent or legal guardian to sign this hard copy and either fax or mail it in, granting parental permission for Nintendo to contact their children. Until the signed form was received in the Nintendo office, Nintendo would, in effect, remove that individual from its list.
The result was that the company ended up reducing its initial database to less than half its original size. But, Eisenberg says, Nintendo was prepared for this. “They knew up-front this could happen,” Eisenberg said. “You can have a large list, but if people aren’t responding, it doesn’t matter.”
But, he notes, even though the database Nintendo ended up with was much smaller, the results of the next mailing were all they could hope for. Here are the results of the first campaign sent to this new, parentally OK’d opt-in list, mailed out in December 1999:
Eisensberg notes that these click-through rates continue to be high and that parents are able to come in and unsubscribe their children, which they do so at a rate of less than 1 percent.
Nintendo continues to require that parents give hard-copy permission before it signs children 12 and younger up for its mailing list. Now that the law has been put into effect, and it does not appear to apply in the same manner to those 12 and younger as it does to those between the ages of 13 to 18 (it’s naturally stricter for those in the “tween” market), Nintendo uses an online parental information form (parental information is confirmed through direct mail) for its 13 and older members.
Now, a couple of notes. One, I asked Eisenberg how they know that those who say they’re 13 or older, or 18 or older, really are. He responded that if someone comes in and says she’s older than 18, there’s little you can do now to verify that, but Nintendo gives users incentives not to lie by giving them straightforward information. For instance, a child 12 or younger knows that by giving his correct age, he’ll get the information about games designed for his age group.
And two, this permission procedure may be modified in the future once the law allowing digital signatures as legal evidence goes into effect. In the next quarter or so, Nintendo may begin allowing parents to send permission online, as long it is accompanied by a digital signature.
