Controlled Free - Consumer Magazines

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Controlled Free [Print/Digital]

Copies sent free to a defined group of individuals.

Principles

1. Single copy per issue, distributed to an individual

2. Individual falls within defined criteria (Terms of Control) 

3. Individual’s details supported by third party evidence that is less than five years old

4. Copies may be requested or non-requested 

Requirements 

1. Single copy per issue, distributed to an individual

1. You must be able to demonstrate the copy is distributed to the individual. For a digital copy:

   1. You must be able to demonstrate distribution either by the copy being delivered to a consumer or the consumer being notified of the availability of the issue to access. 

   2. If distribution/notification is by email, you must exclude Hard Bounces (non-delivery notices typically measured up to 24 hours after being sent).

2. You must retain a list of individual recipients for one designated issue each reporting period (the Audit Issue – see General Principles and Record Keeping section). In addition you must be able to recreate a list of any issue in the reporting period on request.

   1. The list is to include details of the recipients of individually distributed print and digital copies across all circulation types, excluding those that are not available due to the nature of a third-party supplier relationship or represent a duplicate print copy or a duplicate digital copy to the same individual (which are ineligible for claiming).

   2. You must be able to identify the circulation category/type each copy is claimed in, and which copies, if any, represent a print and digital copy for an issue that are circulated to the same individual.

   3. We may agree to waive this requirement where you use a bespoke distribution process involving a new route to market that is operated by a third party or partner operation under the following conditions:

      • You are not able to provide a mailing list because the third party/partner operation responsible for the data will not/cannot provide it for the purposes of the audit.

      • You do not provide to the third party/partner operation details of specific individuals that should receive a copy of the publication under their process. 

      • We are able to review the third party/partner’s operation and distribution system and satisfy ourselves that the copies meet the definition and principles of Controlled Circulation and that there is not likely to be a significant level of duplication of a particular issue to individuals through this distribution process. [Note: individuals distributed to under this process need not be tested for duplications against copies distributed outside of the process].

      • You notify us that you are claiming copies that utilise these requirements in order that we can plan appropriate verification work.  

3. You cannot claim distribution of back issues. (with the exception of repurposed unsold retail copies – see below).

   Repurposed unsold retail copies 
   Repurposed unsold retail copies are print copies supplied to wholesale/retail for retail sale, but which have been returned unsold and are subsequently sold or distributed in accordance with these standards. For the avoidance of doubt, these copies cannot be claimed more than once.

   You may claim back issues of repurposed unsold print retail copies as follows:

   1. Issues up to 12 months old against the issue current at the time of sale/distribution.

   2. The level of repurposed copies included in your claim must be reported – see the Reporting section below for details.

Guidance Available

2. Individual falls within defined criteria (Terms of Control)  

1. The publisher sets the Terms of Control, complying with the following:

   1. The wording must be clear and relate to individuals not companies

   2. Phrases or words that are subjective and/or difficult to explicitly prove are not permitted.

   3. There must be at least one qualifying demographic which is neither:

      • a geographic criteria at a country level or higher (for example individuals in the UK); or

      • an interest in the field (for example individuals with an interest in technology).

   4. It must be possible for individuals not to meet the criteria.

2. You must not publish either the Terms of Control or an approximation of these in the publication or on any documents or promotional material targeted at the reader where the effect might be to lead them to provide inaccurate data about themselves in order to meet the Terms of Control.

Guidance Available

3. Individual’s details supported by third party evidence that is less than five years old

1. At the date you distribute a copy you must have identifiable and verifiable evidence* that:

   1. supports the individual’s name, job title/function (as appropriate) and address details.

   2. proves explicitly that the individual meets the Terms of Control.

   3. is less than five years old. Please refer to the guidance for dating evidence.

      *Identifiable and verifiable

      You must be able to identify (for any particular individual or information relevant to the claim) when and from where the information was obtained. For example: The date plus whether it was obtained:

      • From a direct communication with the individual or a colleague (e.g. online form, event registration, telephone call); or
      • From another organisation/operation, such as a Data Broker, Event Organiser or list specialist.

      We must be able to verify to our satisfaction that the relevant information has been obtained either directly from the individual or from a colleague or other organisation/operation and can be relied upon in support of the claim. This may require us to contact some individuals/colleagues and/or examine relevant records, such as campaign instructions, orders, invoices and/or payments as we consider appropriate.

Guidance Available

4. Copies may be requested or non-requested

The following additional requirements apply if you choose to optionally break out your controlled circulation claim into requested and/or non-requested circulation:

Individually requested

1. The copy must be addressed to the individual by name.

2. You must have identifiable and verifiable evidence that the individual has, within the last five years, made a clear request to receive the publication before you send it to them.

Company requested

1. The copy must be addressed to the individual, either by name or job title/function.

2. At the date you distribute the copy you must have identifiable and verifiable evidence that another employee or colleague from the individual’s company or organisation has, within the last five years, made a clear request to receive the publication on the individual’s behalf.

Non-requested (either by name or by job title/function)

1. The copy must be addressed to the individual, either by name or job title/function.

2. For by job title/function copies you may add a stylized/generic job title/job function to the address of an organisation for which you have third party evidence of the organisation’s name and address providing:

   1. The job title/ job function could reasonably be expected to relate to an individual in that organisation. 

   2. Multiple or similar job titles/ job functions at the same organisation are not used in a way that might result in copies being distributed to the same individual. 

Guidance Available

Reporting

You will report controlled free circulation as follows:

1. By print and digital copies, by total average controlled free over the period, by geographical type:

1. United Kingdom and Republic of Ireland

2. Other Countries

It will be reported on the ABC Certificate combined with the other Free Circulation categories into a total average Free Circulation, by print and digital copies, and by geographical type. 

2. It will also be reported on the ABC Certificate as part of a summary analysis showing for each free circulation category, a total print and digital combined figure, across all geographical regions. Note: There is no mandatory requirement to breakout Controlled Copies into individual requests, company requests or the non-requested types.

3. If your claim includes any controlled circulation copies you will report the applicable Terms of Control.

4. If you have claimed repurposed unsold retail copies, then you must combine the repurposed copies with any other
repurposed copies in other categories and report the total as a percentage of the total average circulation for the reporting
period. 

Guidance

G1. Single copy per issue, distributed to an individual

1. Print distribution evidence: This will usually be from a third party company whose normal business is single copy distribution (such as Royal Mail).  Typically the evidence will include testing the payment of invoices and related advice notes sufficient to identify the publication, issue, quantities and date distributed. This means copies posted using a franking machine will not normally be able to be claimed as the records will not identify what has been posted.

G2. Individual falls within defined criteria (Terms of Control) 

1. The Terms of Control enable you to demonstrate the attributes or quality of your circulation to potential advertisers and to differentiate your publication from others serving the same or similar markets. Controlled circulation is therefore useful to advertisers and media buyers because they enable them to target their advertising more effectively.

   1. The Terms of Control must relate to individuals not companies.  For Example: ‘Engineering companies in the U.K.’ would not be allowed whereas ‘individuals in engineering companies’ is acceptable.

   2. Subjective phrases or words that are subjective and/or difficult to explicitly prove are not permitted .This may include terms such as: related, associated, selected, allied to the field, various, specialist, professional, executive, key, substantial, high spending, major, senior (unless it has a capital S and is part of a job title), all..., every.....

   3. There must be at least one qualifying demographic (for example job title, job function, purchasing responsibility, business, industry sector or members of a particular society). Note: A geographical region at country level alone is specifically not permitted as a qualifying demographic as it is not considered a sufficiently distinguishing demographic. For example: ‘Individuals in the UK’ would not be allowed but ‘Company Directors in the UK’ would.

G3. Individual’s details supported by identifiable and verifiable evidence that is less than five years old

1. You may use evidence from different sources (also known as ‘secondary sources’) to prove the addressee meets the Terms Control, verify the individual’s name and address details or a request for the publication.

2. Any material used to capture information to prove the individual meets the Terms of Control must neither explicitly or implicitly lead the addressee to give the desired qualification data in order to receive the publication. Suitable ways to ensure this requirement is complied with is to add an option to the possible answers such as: Other ……….. (please specify.); or add possible responses/tick boxes (where used) that include some items that would fall outside the Terms of Control.

3. You must be able to provide evidence at audit.

   1. It is your responsibility to comply with copyright legislation in relation to the use of data from third-party sources

   2. If you are sourcing data from websites, and may have difficulty proving the date of the source, you may opt to use ABC’s source validation service. An engagement letter detailing the provision of this service must be in place before the date of distribution of the issue for which the source will be used. Please contact us to arrange this.

4. Examples of possible evidence types and how they must be dated are provided in the table below.

5. For data captured over the telephone, by email or online, the following gives guidance and examples of how details could be demonstrated as third party:

   1. Asking the individual providing the data to provide their name and the answer to ABC’s Personal Identifier Question (PIQ) - a memorable question set by ABC and changed each calendar year – details of the current PIQ can be found on the ABC website.

   2. In the case of information obtained via telephone calls, recording the telephone calls in a manner that can be made available for review at audit. If you would like our advice on whether a call recording system might be acceptable please contact us. Note: It remains your responsibility to comply with any legislation regarding the recording of telephone conversations.

   3. It may help if a copy of the data captured via online or telephone campaigns is kept in its original state as once this data is entered or merged onto a main database the audit trail evidencing the collection of the data can be lost. You may also consider retaining invoices from external contractors evidencing the work carried out in this regard.

   4. You are advised to retain copies of online forms/screenshots or telephone scripts to provide evidence of questions asked and responses recorded.

6. In relation to data purchased from an established data rental/sale business, examples of suitable evidence may include promotional material and data rental/sale invoices.

 Example sources and dates of sources  

G4. Copies may be requested or non-requested

Non-requested circulation 

1. When adding stylised/generic job titles/functions: 

1. 1. These must reasonably be expected to relate to an individual in that organisation (for example Managing Director, Credit Controller).

   2. Multiples of a job title/ job function (or similar ones) must not used in a way that might result in them being distributed to the same individual. For example: If 30 copies were addressed to ’Company Secretary’ at 30 branches of XYZ Co Ltd, these copies would be treated as duplicates as XYZ Co Ltd would be expected to have only one Company Secretary. It would be expected that copies from each branch would be forwarded to the one Company Secretary. This problem would not arise if each of the copies were addressed to a Branch Manager as it would be reasonable to assume each branch would have a manager.