On 16 February 2023, the Australian Government released a set of privacy recommendations that will evolve the way businesses interact with their customers and with personal information. Typically, our discussions across the industry suggest that most organisations are assessing how to respond from a compliance perspective only.

Whilst that is a given, our position is that if your business has a direct line of communication with the end consumer, you really should be looking at this as a growth platform.

At Crystal Box, we have always had the experience that working with transparently collected consent and first party data as the cornerstone of your customer engagement operations drives a genuine competitive advantage, as opposed to relying on market standard techniques that typically fall back on third party relationships as their basis of operations.

Given the impact of these regulations will include a decrease in the scale and value of third party options, today’s release should accelerate how quickly you should be transitioning your operations to ensure that first party is at the heart of how you operate. 

The statement we hear most in response to this is “I understand this, but I don’t know how to get there”. The front-runners in this space don’t treat this as a large project.  Rather – it is a journey of continuous improvement, where many of the largest benefits can be achieved with the first simple steps. 

1. Create a clear value exchange

Create a clear value exchange with your customer for their consent and ensure this is clearly articulated to the customer.

2. Overlay first party digital capability on top of your existing infrastructure.

It is typically unnecessary to replace core systems and embedded operations. Simply ‘plugging the gaps’ can be very quick a low investment approach that can occur in days/weeks rather than months/years.

3. Ensure you control your own customer data

Don’t repeatedly distribute your customer data into a myriad of suppliers. Use your service providers for what they are good at; Service. Create a controlled environment for them to use your customer data, while maintaining visibility and security of this valuable asset at all times.

4. Create a cross-functional learning environment in your business

If you aren’t using customer data to experiment and learn – you are not evolving. Ensure that your CX, marketing, data, ops and compliance teams can coordinate and evolve from learnings in one unified way.

Treating these four themes as the initial sprints in a grander vision will always realise value faster and achieve the end vision sooner than launching an all-encompassing project. This approach will also provide the dual benefit of:

  1. Greater growth from your customer engagement; and
  2. An easier path towards compliance of upcoming regulatory and technical changes in the industry.

We hope that sharing some of the learnings we have observed through more than 10 years of first party digital experience can bring positivity and speed to your journey.


Vaughan Chandler

Vaughan is a pioneer in the loyalty, data and digital media sectors in Australia, with a successful record of both strategy and execution using a unique combination of commercial, analytics and leadership capabilities.


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