X-Ray is a customer assistance tool which enables businesses worldwide to see and capture all unsubmitted typed customer data and product choices from new and existing customers live. It has been established that businesses can compliantly contact these customers who were historically lost, in order to assist them, dependent on market considerations and territory compliance.
Contact strategies and best practice may vary dependent on B2B / B2C offerings, business sector and business location.
Contact methods to engage customers who do not complete web forms or orders include:-
  • Telephone – customers can be contacted (preference service checks may be advisable).
  • Direct Mail – customers who include name + postal details may be engaged via post.
  • Service Messages – in the event of any incomplete online transaction, service messages can always be used to clarify if there was an issue or problem and offer assistance. 
  • Email & SMS – service messages may be used or equally, data captured by X-Ray can augment data already on file for existing customers.
  • Over-the-Shoulder Live Chat – live engagement may be used with an “over-the-shoulder” view, augmenting existing chat or bot solutions.
Compliance/GDPR Audit Trail
As well customer assistance, X-Ray Leads gives businesses a unique analytical insight into customer behaviour, whilst also performing the role of a compliance/GDPR audit trail with full searchable customer keystroke, product selection and activity history. Searches can be made for completed or abandoned customer input using IP address or any other data field / web form field.
This information is for guidance on compliant use to capture and contact customers who start but do not complete an online transaction. In campaigns across Europe and Worldwide the addition of X-Ray has increased lead and data capture by a minimum of 5% and a high of 117%. Within the framework of GDPR and other regulations the ICO has communicated how businesses CAN compliantly contact these new and existing customers to assist.
A significant percentage of consumers begin transactions which they do not complete. Analysis confirms there are a number of causes and improved customer service and assistance is commonly required. These include lack of telephone number visibility on a website, technical problems or issues within web forms, device problems, mobile data, coverage, Wi-Fi, voice initiated forms, cart time-outs and product shortages, uncertainty regarding a product, lacking information required to complete, or equally the increasing issues caused by lifestyle, multi-tasking and interruptions amongst other factors causing non-completion and abandonment.
These are customer issues which X-Ray Leads allows a business to respond to in real-time by communicating with B2B and B2C customers appropriately.
Legitimate interests (those of a business) is the most flexible lawful basis for processing and contacting data. These extend to include both the commercial interests (of a business) and individual interests (such as where a consumer may experience a technical issue whilst on a site). In this circumstance there is potential for a contract/agreement between the customer and the business and it is reasonable to conclude a business cannot reasonably achieve the same result using another less intrusive way and legitimate interests will apply.
The ICO response identifies a framework allowing potential customers to be contacted (i) by telephone or (ii) by direct mail without specific consent in order to assist them, or (iii) by email or SMS subject to appropriate soft opt-in which may either pre-exist (with existing customers) or can be achieved upon arrival at the site via appropriately detailed pop-up, or – significantly – can and may commonly be achieved within the product selection, process or form stages. It is also advisable to document the contact and the outcome as well as the partial details indicating they have shown interest (this would be stored within the GDPR audit trail provided by X-Ray).
The stage of a transaction is also a key consideration and in a high % of incomplete transactions there is substantial critical data which is lost AFTER consent has already been gained meaning consent is the lawful basis for processing and contacting data. Examples include an existing returning customer, or a cascading, 2-step or multi-step forms where field-1 or step-1 captures consent but the details then typed on a subsequent profile, registration, subscription or shipping form are unsubmitted.
We asked the ICO whether it is appropriate to use software so a business can (a) analyse unsubmitted data and the causes of abandonment and (b) communicate with customers during their web visit. In this software, the business employee would be able to see the information the customer was typing into the form. This enables live analysis and also engagement with the individual in a way similar to live chat but with the added value of communication based on in-form data. In response the ICO clarified there is nothing in the General Data Protection Regulation (GDPR) that specifically prohibits a business from doing this.
Online visitors must have an understanding of how their data is processed and why the organisation requires it. The easiest way to provide this information is to include a clear and concise statement regarding your organisations’ data processing within your privacy policy, this should also contain how a data subject can withdraw consent and also remove their data. As part of your GDPR audit, it is likely you will need to make alterations to your privacy policy to include this information. You should also include information regarding data that may be collected using your web chat software and analytics solution.
ICO feedback confirmed that GDPR and PECR regulations allow compliant contact of customers appropriately by telephone. This includes where customers (B2B or B2C) enter a name and telephone number in a form but do not submit. This may come about as a result of a number of issues and businesses are able to use the legitimate interest lawful basis to contact the individuals by telephone, provided they screen the number against the TPS. The ICO also agreed processes used to contact the individuals via telephone should include customer assistance focus, with initial use of the data for communication on the initially expressed interest only, and an offer remove data if a customer did not pursue or proceed with their enquiry which would comply with the Privacy and Electronic Communication Regulations 2003 (PECR). The ICO also agreed on best practice and on contacting the customer the processor would
                (i) Offer to assist with their enquiry
                (ii) Identify the reason for the non-completion in order to offer assistance and assist appropriately
                (iii) Confirm removal of the data if the customer did not want to continue their enquiry or transaction
(iv) Reasoning should be clear on why a customer was contacted and businesses could explain this if queried
Where businesses using X-Ray have achieved either (a) consent or a (b) a real-time or recent soft opt-in they will be able to contact unsubmitted data using email or SMS. Soft opt-in may also be achieved during an unsubmitted enquiry in the event that during the transaction the contact details are obtained in the course of a sale (or negotiations for a sale) of a product or service to that person. As in all electronic marketing it is necessary to give the person a simple opportunity to unsubscribe, stop or opt out of the marketing in every subsequent message.
Where a name and address is typed but not submitted, along with an indicated product or service interest, direct mail can be used to re-engage the customer. This could consist of offers, voucher codes, literature, brochures or any other appropriate engagement message. It is good practice to screen marketing mailings against the Mail Preference Service although this isn’t a requirement like the TPS is for telephone marketing.
In the event of any incomplete online transaction, service messages can always be used to clarify if there was an issue or problem and offer assistance.
These details and guidance provide indications on a compliant basis for post, phone call, email and SMS communication. We are happy to provide further insight around this where available. X-Ray Leads clients are deploying best practice strategies to assist customers compliantly and analyse site and form conversion performance. The results are clear and as follow.
• X-Ray Leads provides immediate scope to increase direct mail where address fields are part of a form
• Telephone contact to assist consumers is proving a successful customer service practice as well as engaging and converting new customers
• Live chat options are enhanced with the on-screen visibility of a customers’ actual keystrokes
• SMS and email marketing recovery strategies are highly effective to recover customer orders which would otherwise be 100% anonymous
Significantly, results show that most customers contacted are interrupted, side-tracked, or in need of help and assistance. Frequently consumers still have the form open behind multiple other pages on mobile, or comment that they ran out of time to finish the enquiry or purchase, or could not find the phone number on the website.