DMA Email Council: Understanding Email Tracking Pixels
26 Feb 2021
The DMA Email Council responds to the BBC article on Spy Pixels in Email
Komal Helyer – Chair, DMA Email Council
Email has been in the national press for two reasons in the last few weeks. The first because it is now the communication method of choice for Spinach and secondly, last week, when the BBC ran a story on so-called “spy pixels” placed in emails to consumers from brands.
The DMA Email Council members, as the central intelligence for the Email Marketing Community in the UK, respond to the BBC. (Who also, by the way, use tracking pixels in their emails.)
We move away from sensationalist language used to create fear, to take a pragmatic look at tracking pixels in context, why they are a good sending practice and how we can, as an industry, drive greater transparency and clarity to consumers.
But first a little about the use cases for tracking pixels and the regulation governing them.
When tracking pixels were first used in email, it was not the consumer they were tracking. When email marketing as we know it today was in its infancy, the tracking pixel was a common way for email senders to prove to their clients that the emails were being sent. It was just like any other image in the email, but we needed an image that could go in every email. We made it small (1 pixel) because at the time bandwidth was expensive and invisible, so it did not clash with the brand's email designs.
Today the primary purpose of these pixels is still to report on how well an email campaign has performed by showing how many people have opened the email. They are also used to monitor data quality and remove people who are no longer interested in receiving emails – nobody wants to keep sending emails to people that are not reading or even opening them.
Pixels are governed by the Privacy and Electronic Communications Regulation 2003 (PECR) and technically you require ‘consent’ to place information or read information from a person’s device. However few email service providers allow the option to turn off these tracking pixels and certainly not at an individual level. It is therefore impossible to fully comply with the regulation and obtain any of the crucial information about how many emails were sent, received, opened, or sent to Spam folders.
The ICO consider things like pixels used for performance monitoring low risk to individuals and make allowances for certain uses in their recent guidance.
Pixels are governed by the Privacy and Electronic Communications Regulations 2003 (PECR). PECR does not prohibit the use of cookies and similar technologies. However, since 2011, if you are using such technologies you are required to obtain user consent in addition to clearly explaining what cookies you wish to use and what they will be used for, in ways that are compliant with UK GDPR. The regulations governing cookies, which include email pixels used by organisations to track email opens of their newsletters to their customers, are very wide in scope. Such broad rules can cause unnecessary complexity and difficulty for compliance in practice with tools such as pixels. Perhaps, with this knowledge in mind, this is why the ICO considers things like pixels used for performance checking low risk to individuals and has made allowances for certain uses in their guidance:
Therefore, transparency is the key, below is an example of an email footer that explains how their pixel (or in this case a .gif) is used and how to turn off its functionality.
Consumer marketing emails are almost always sent because the individual has requested them by opting in. The data from pixels used for campaign measurement is not shared nor does it track a person or create a profile.
If your intention was to spy on consumers, then using a pixel is not a good choice. First, it is not very accurate. Switch off your pictures and you switch off tracking. Second, the data it collects is low impact compared to other things a consumer may opt-in to, such as a multi-brand loyalty scheme. It can identify the IP address shared with many other households and the type of device used but marketers cannot use that data. This data is used to make sure that the sender is doing their job and to help solve support queries when an email does not look the way it was intended.
That said, I would expect most consumers to be surprised to learn about pixels, which can only mean that marketers must do a much better job of explaining what they are what information is being collected, how they will use it and the benefits for both the consumer and the brand.
Guy Hanson - Validity
Email is consistently rated as consumers’ preferred channel when it comes to receiving marketing messages. The reasons are the high levels of trust they have in the channel, and the relevance of the communications they receive.
We need to step back from the negative hype that claims like pixel-based “spying” creates. Open rates provide important data points that help measure the address owners’ levels of engagement, when they like to engage, what content they are most interested in, and their preferred cadences & frequencies.
Email senders use these insights in a positive way to deliver improved subscriber experiences, by delivering more relevant messaging that adds real value to recipients’ lives,
This is why email is the preferred channel - the fact subscribers feel this way hardly points to them feeling exploited!
Email is a highly responsive channel and when senders are seen to be a bad actor, negative feedback is swift (complaints and opt-outs). That’s why good senders rarely do this, they know their customer relationships are in equilibrium when both parties are realising value.
Elliot Ross – Taxi for Email
Pixels in emails. For a start, here’s how it works.
- A transparent gif is added to most bits of marketing email that are sent
- This gif is unique to each recipient (it’s not really a gif technically, it’s a unique URL that returns a gif)
- When the gif is downloaded the sending tool records it.
This means that marketers can theoretically track:-
- Who opened
- How many times
- What device
- IP Address and in theory, a rough location
So the article – which actually reads like a press release for Hey.com – it’s mostly true, but not really the whole story.
For a start, tracking gifs are just a bit twee compared to the huge amount of tracking and analysis that happens on websites. They're just not that good. If anything, marketers over-egg their significance — it's a signal, but not a perfect one. It's a download of an image.
The far bigger issue is free email clients that scan your email's contents and use that for profile building purposes.
Ever notice how Amazon email receipts don't tell you the products you ordered anymore?
They mention Superhuman. That was taking this tech and putting it in the hands of personal email. For marketers, whether you opened an email is usually an aggregate metric. At best it's used to change follow up content.
Personal email knowing whether you read, and what you’ve said is lots shadier. Just take a look at Google’s positioning on how snooping your Gmail is an actual service!
Jenna Tiffany – Let’s Talk Strategy
The impact of tracking has been a topic of discussion in the industry that over the past year has been growing momentum and one I think we should be prioritising.
I found the BBC article to be biased towards Hey.com’s own offering and especially with the naming of ‘spy pixel’. Little was also mentioned about the benefits email tracking provides subscribers with timely and relevant communications something which the DMA Email Tracker research is always voted with high importance by consumers.
But I question if we as marketers are transparent and clear about the tracking that takes place in the inbox. I don’t believe we are always upfront to subscribers about the tracking taking place and there are examples where the BBC article does highlight this. You only have to see the uptake of Hey.com to see that there’s a desire to not be tracked by subscribers. Providing a choice to subscribers as to whether they would like to be tracked or not isn’t something that all ESPs currently offer marketers. We can do better and as an industry, we should be striving together to do so.
Suzanna Chaplin - ESB Connect
Much like necessary cookies on websites, impression pixels are vital to good sending practices. They are paramount to ensuring those who want to receive their emails do and those that do not are removed from the senders' list due to non-engagement. Email, unlike many other channels, is quite self-regulated – it is opt-in and opt-out and if you have a poor engagement or data hygiene, you will not inbox. A good sender will actively manage who opens to ensure those who are not, are removed. This protects their own sender's reputation and ensures inbox delivery to those who do want to receive the email.
Impression pixels are also used for other purposes such as segmenting data, split testing, and profiling. With the way privacy is moving, consumers at some level should be given a choice, the open pixel should remain for necessary reasons (to remove non-engaging data) but we should consider how we provide consumers with the option to opt-out of other uses. This may be a simple notice at top of the email, with a link to opt-out or they are made aware of it at the point of opt-in or via the first email send. Simply blocking them full stop will lead to bad data hygiene practices and consumers receiving more, not fewer emails.
The DMA Email Council is continuously working on how to help build a better environment for better email practice. If you would like to learn more about email marketing or contribute to the discussion, please get in touch with councils@dma.org.uk
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