Free Requested - Regional Publications
Free Requested Copies [Print/Digital]
A single free copy requested by and distributed to a known individual.
Principles
1. Single copy per issue, distributed to a known individual
2. Individual has personally requested to receive the publication
3. Only copies distributed in UK and Republic of Ireland can be claimed
Requirements
1. Single copy per issue, distributed to a known individual
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You must be able to demonstrate the copy is distributed to the individual. For a digital copy:
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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.
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If distribution/notification is by email, you must exclude Hard Bounces (non-delivery notices typically measured up to 24 hours after being sent).
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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 for any issue in the reporting period on request. Note:
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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).
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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.
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You cannot claim distribution of back issues.
2. Individual has personally requested to receive the publication
- 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.
Reporting
You will report Free Requested as follows, which will be broken out on the ABC Certificate:
1. By print and digital copies, and by total average circulation over the period.
2. By print and digital copies, and by combination with other circulation types.
- Free Pick Up (print only) and Free Letterbox (print only).
Guidance
G1. Single copy per issue, distributed to a known individual
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You must be able to demonstrate the copy is distributed to the individual. An example for print copies is:
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If via a third party: 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.
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G2. Individual has personally requested to receive the publication
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You must have third party evidence that the individual has, within the last five years, made a clear request to receive the publication before you send it to them. The following provide guidance and examples of acceptable methods of achieving this:
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The requestor must have been asked and agreed, or they have stated, that they wish to receive a copy of the publication. 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’.
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There must be a clear separate request to receive the publication that is not combined with a request for another product or service. For example: This means if the requestor is being offered the opportunity to request two or more publications, or register for an exhibition at the same time as requesting the publication, it should be clear to them that they can separately request to receive the publication(or not) with or without requesting or accepting the other product/service. You may use separate questions or separate boxes to make it clear what the individual is requesting in this scenario.
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For a written request, the evidence could be demonstrated as third party by requiring the requestor to sign and date the form/request.
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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:
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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.
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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.
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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.
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You are advised to retain copies of online forms/screenshots or telephone scripts to provide evidence of questions asked and responses recorded.
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