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Controlled Free Circulation - Business Magazines

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 Definition

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. Copies reported either as requested or non-requested

 

Requirements | Reporting | Guidance


 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.

  3. You cannot claim distribution of back issues.

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.

 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.

    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. Copies reported either as requested or non-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.

  3. The date of the request must be recorded so that it can be analysed by age.

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 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.

  3. The date of the request must be recorded so that it can be analysed by age. 

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, depending on the circulation category in which it is claimed.

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

  1. Audit Issue by geographical type:

    1. United Kingdom

    2. Other Countries

  2. Audit Issue by circulation type:

    1. Individual requests

    2. Company requests

    3. Non-requested by name

    4. Non-requested by job title/function

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

  4. If you’re claiming any controlled requested copies you will 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

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  

Source Type

Example Evidence

Date of Source

Written communication from addressee / addressee’s company

Copy of communication

Date of document

Telephone communication with addressee / addressee’s company

Record of the response to personal identifier question, copy of record and telephone number

Date of communication

Requests for other journals

Copy of request card

Date of request

Reader Enquiry cards

Copy of reader enquiry card

Date of enquiry, postmark or distribution of the issue which contained the card

Web based reader enquiry form

Record of the response to the personal identifier question, copy of record and email address/telephone number

Date of communication

Email communication from addressee / addressee’s company

Record of the response to Personal Identifier Question and copy of communication

Date of email

Competition entries – paper

Copy of the entry

Date of entry

Competition entries – web  

Record of the response to the personal identifier question, copy of record and email address / telephone number

Date of entry

Press cuttings

Copy of the cutting, which includes issue date or complete publication

Cover date of the publication or the first day of the cover date month

Published directories that are publicly available

Copy of the directory

Month and year of publication date. E.g. Cover date is 2013/2014 the date is 1st January 2013 unless an actual publication date is shown

Exhibition attendee lists

Copy of list, invoices / suppliers statement

Last day of Exhibition

Suppliers / business lists

Copy of list, invoices / suppliers statement

Date of acquisition of list

Business cards- if signed and dated

Copy of the Business Card

Date of signature on card

Website data*

Method and date of contact must be recorded. A hard or soft copy of the page which contains the sourced data plus the site’s home page must be retained

Either a specific date within the published text on the webpage, or a copyright date (where the 1st of the year should be used - e.g. © 2013 = 1/1/2013) Note: If there is no date on the website then it is unlikely source can be used for ABC purposes (a screen print date generated by the user’s computer is not acceptable) unless the data has been validated by ABC’s source validation service.

*If you are sourcing large quantities of data from websites we recommend you tell us at the time of collection and would like to remind you that it is your responsibility to ensure you are legally entitled to use and store the data for the purposes of the ABC claim and audit. We may ask you to make a declaration that internet sites used as sources are third party. It may be acceptable to use other methods of record keeping or audit as long as you obtain our written agreement.

 

 

 G4. Copies reported either as requested or non-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. 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. 

    3. 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.

    4. 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. 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. Age of requests bandings - example

    1. Audit Issue distributed on 20 .11. 2013

      Under 1 year: All requests dated between 21.11.2012 and 20.11.2013 inclusive

      1 to 2 years: All requests dated between 21.11.2011 to 20.11.2012 inclusive

      2 to 3 years All requests dated between 21.11.2010 to 20.11.2011 inclusive

      Requests dated before 21.11.2010 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.