Controlled Free Circulation - Consumer Magazines

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Controlled Free Circulation [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 three years old

4. Print copies may be requested or non-requested, digital copies must be 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.

   1. Each copy should be addressed or accompanied by instructions which enable the distributor to deliver to the individual.

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. 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 (from January 2023)
   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. For publications publishing fewer than 18 issues in a calendar year – issues up to 6 months old against the issue current at the time of sale/distribution.

   2. For publications publishing 18 or more issues in a calendar year – issues up to 3 months old against the issue current at the time of sale/distribution.

   3. 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 three years old

1. At the date you distribute a copy you must have third-party 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 three years old. Please refer to the guidance for dating evidence.

2. *A related party (as defined in the General Principles section) is NOT a third party. Therefore evidence provided by a related party is not acceptable for ABC purposes except in the following circumstances where at least one of the following applies:

   1. ABC has audited and verified the data at audit to be compliant with all the requirements necessary for the circulation claim in question. For example: ABC has already audited the data from included on an attendance list as part of an event audit or has carried out a satisfactory review of a bespoke distribution process (see section 1b (i) above).

   2. You have purchased the data from the related party and:

      • You have paid a purchase invoice (money must have changed hands - an inter-company accounting transaction is not sufficient).

      • The data purchased is sold as part of an established data rental/sale business. The onus is on you to provide suitable proof of this fact. Examples of suitable proof include promotional material and data rental/sale invoices.

Guidance Available

4. Print copies may be requested or non-requested, digital copies must be requested

The following additional requirements apply to copies claimed in these categories

Individually requested

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

2. You must have third-party evidence that the individual has, within the last three years, made a clear request to receive the publication before you send it to them.

   1. Company requested

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

4. At the date you distribute the copy you must have third-party evidence that another employee or colleague from the individual’s company or organisation has, within the last three years, made a clear request to receive the publication on the individual’s behalf.

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

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

6. 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. 

Note: If you’re claiming digital copies, please also refer to the additional requirements in the Digital Copies section.

Guidance Available

Reporting

You will report controlled circulation as follows, which will be broken out on the ABC Certificate:

1. By average geographical type:

1. United Kingdom and Republic of Ireland

2. Other Countries

2. By total average circulation over the reporting period:

1. Regular - net

2. Sample - net

   Note:

   1. Controlled circulation is defined as regular if the quantities are broadly similar for the majority of issues in the Reporting Period.  If not regular the copies will be claimed as sample.

   2. Controlled copies deemed to be net for reporting purposes as they are distributed to individuals.

   3. There is no 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’re optionally analysing any controlled requested copies you may choose to report an analysis of the age of the requested copies from the date of the distribution of the Audit Issue in the following bands:

1. 0-1 year
2. 1-2 years
3. 2-3 years

5. 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 Available

Guidance

G1. Single copy per issue, distributed to an individual

1. 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 third party evidence that is less than three years old

1. You may use third party 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 the third party 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 the exception for data provided by a related party (The data purchased is sold as part of an established data rental/sale business):  The onus is on you to provide suitable proof of this fact. Examples of suitable proof include promotional material and data rental/sale invoices.

 Example sources and dates of sources  

G4. Print copies may be requested or non-requested, digital copies must be requested

Individually requested and company requested circulation

1. You must be able to demonstrate third party evidence of a clear request to receive the publication within the last three years. The following provide guidance and examples of acceptable methods of achieving this:

   1. The requestor must have been asked and agreed, or they have stated, that they wish to receive a copy of the publication (or for company requested for their colleague to receive a copy). Bear in mind you will need to be able to demonstrate this at audit. For example using a question such as ‘sign here to request a free copy of <publication name> or ‘Complete this form to continue receiving this publication’.

   2. For a written or faxed request, the evidence could be demonstrated as third party by requiring the requestor to sign and date the form/request.

   3. For a request made over the telephone, by email or online, the following gives guidance and examples of how details could be demonstrated as third party:

      • Asking the requestor 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.

      • In the case of telephone requests, 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.

      • 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.

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

2. If you change a publication’s name or merge two publications then valid requests for the original publication may be transferred to the new publication as requested controlled circulation providing you can still prove the individual meets the Terms of Control for the new publication.  

 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.

G5. Reporting 

1. Optional age of requests bandings - example

   1. Audit Issue distributed on 20 .11. 2021

      Under 1 year: All requests dated between 21.11.2020 and 20.11.2021 inclusive

      1 to 2 years: All requests dated between 21.11.19 to 20.11.2020 inclusive

      2 to 3 years All requests dated between 21.11.2018 to 20.11.2019 inclusive

      Requests dated before 21.11.2018 are no longer valid to be claimed as controlled circulation copies (they may be eligible for non-controlled circulation in sectors where this is available)

2. The ageing of requests for Annual Publications may be from the end of the distribution period if this method of reporting period is chosen.