If you thought GDPR was bad – Just wait for ePrivacy Regulation

GDPR (in force since May 25, 2018) has brought many non-EU companies into a pro-active position regarding data protections, there is an even more challenging regulation waiting in the wings -- ePrivacy Regulation or ePR for short.

According to Information Management, "It is intended to provide a single digital data privacy framework under which all companies doing [any] business with EU residents [including a single customer online] must conform, and the penalties are similar to those enforced under the GDPR."

This covers communications data, metadata, telecommunications, online advertising, and the InternetOfThings. As Lisa Loftis notes in the Information Management article, "Another question concerns how to manage the specific consent requirements in today’s high-volume, real-time analytic environments needed for customer experience initiatives. And the big elephant in the room - a significant change to the many on-line businesses that rely on advertisers to provide free services (social media, paid search, etc.)....It is unclear where ePR will land in terms what types of IoT data will eventually be covered, what consent will be needed and what processing can occur. This is an area of significant concern, and many industries are weighing in and watching closely."

For the entire article see http://bit.ly/2KvQswX

Systems Selection and Implementation Timeframe

If you have outgrown your current order management and fulfillment system and/or you are planning to implement a new eCommerce platform, you typically need at least 17 months to undertake this process.

Preparation
Month 1 — Most companies, no matter how small, don’t wake up one day and suddenly decide to start looking for a major new enterprise system. There are as many scenarios as there are multi-channel merchants. But essentially, one or more managers will share their frustration with the current systems they are using, and jointly come to the conclusion that the company should at least explore what’s available, what the costs of a new system are likely to be, and what the likely ROI is, based on some assumptions about improved efficiencies, better marketing tools, more flexible fulfillment, more dynamic customer database management, and so on. Included in this pre-project month is some initial consideration of who should be involved on a “Project Team” to shepherd the systems project through to completion. (Don’t forget, the team members already have “full-time” jobs!)

Needs Analysis
Month 2 — You should allow one month for a thorough Needs Analysis. The actual work will take less than a full person-month, but the Project Team will need to schedule half-day meetings with representatives from each major department: the call center, customer service, inventory management, fulfillment, purchasing, accounting, marketing, merchandising, and other relevant entities (like the Board of Directors). The notes from these meetings will need to be shared, revised, shared again, and finalized. While this can be done much more quickly than a month, if you are undertaking this project entirely on your own in-house, a month is a realistic period of time.

This is partly because you don’t know starting out what ground you will have to cover. You many want to consider a battery of optimized solutions for:

• order entry/customer service
• eCommerce/mCommerce/fCommerce
• affiliate management
• shopping site feeds/integration
• payment processing
• demand forecasting
• purchasing/procurement
• inventory management
• item personalization
• fulfillment
• back-order management
• drop-shipping
• customer database analysis
• Producing a Request for Proposal (RFP)

Request for Proposal
Month 3 — Once you have sign-offs on all the requirements you have determined from all of the managers or departments involved, you will need to produce a formal, written Request for Proposal (RFP) that defines in detail what you would like the new system(s) to be able to do (see the Services page in this Website). Again, this is something that can be done in a couple of weeks, but most companies don’t do RFPs very often, so allowing a month for this is realistic. This includes getting input from everyone who participated in the Needs Analysis, making revisions, and finalizing the document.

Vendor Identification
Month 4 — Once you know what type of system or systems you are looking for, you can undertake a thorough search for vendors who are likely to have solutions that will address or meet your needs and requirements. Please contact us at ernie@schell.com if you need help finding the types of software vendors you are looking for. (This assumes you are not going to program the system yourself in-house, which is a two- to three-year project — minimum!) Five to ten candidates for each type of system is a good number (more than that and you are just “fishing”).

RFP to Vendors
Month 5 — You should give the vendors/solution providers a month to submit a formal proposal based on your RFP.

Evaluate Proposals
Months 6-7 — You will need a month to evaluate vendor proposals, check on references, eliminate the clearly unqualified candidates, and get Web demos from the vendors on your “short list.” That will take a full month, at least. After the Web demos, you should develop a final list of just two or three of the best qualified candidate vendors, and have them come on site for day-long demos and discussions. Allow a month for this, as well.

Contract Negotiations
Month 8 — Once you have selected the vendor(s) you will be working with, allow at least a month (and December is a “short” month, with the last week basically written off…) for contract negotiations. This is something that your CFO and your legal team will be working on along with your CEO and maybe your COO. Give the lawyers at least two weeks to finalize everything (and the vendors’ lawyers may need at least that much time, if not more).

System Implementation
Months 9 – 14 — You need to allow AT LEAST six months for this phase. I’ve seen it take 9 – 12 months or even 18 months, so this is definitely the minimum time required to do data conversion, make any necessary modifications in the systems you will be implementing, and set up the configuration you need to support your business.

Testing
Month 15 — Once everything is set to “go,” you need to spend at least a month in very rigorous testing to find any bugs or problems with the new system(s) you will be moving to in the near future. The testing should be done using detailed business case scenario scripts which you can be producing during the implementation phase.

Debugging/Training
Month 16 — Allow a month to have the vendor(s) debug and correct problems that you discover during the testing phase. There can be dozens, if not hundreds, of such issues, and your Project Manager needs to monitor the correction of each one of them.

This is also the time when you will do your training of everyone who will be using the new system. Some of this training will take place at your site, and typically some of it will take place at the vendor’s site, depending on the type of user and the type of training (even if you use a “train the trainers” approach).

Go Live!
Month 17 — One word of advice: Schedule it for mid-week, so users have a chance for last-minute training to become better adept at using the new system(s).

And there you have it! Marketing Systems Analysis would be happy to work with you on any or all of these phases (probably saving you a lot of time and trail-and-error in the process). Specifically, turn to us for:

• a systems audit and evaluation of resources currently in place
• strategic planning for improving your presence in each sales channel
• assisting in the Needs Analysis and producing the RFP (we’ve done over 240 of them!)
• streamlining order management
• warehouse facilities and fulfillment assessme
• optimizing of inventory management practices
• user training evaluation and refresher training
• on-site and consultative optimization of all operations and systems for order management, inventory management, eCommerce, and mCommerce

Short-Term… or Long-Term
We are available for a short-term or long-term commitment to help you specify, select, and implement new multi-channel solutions. We also believe “if it ain’t broke, don’t fix it!” We will help you identify what you are doing right as well as what needs fine-tuning and what could benefit from a more comprehensive overhaul. But don’t delay– the biggest mistake you can make is complacency, followed by procrastination (or denial).

Are you compliant with the General Data Protection Regulation (GDPR) Requirements?

European businesses have been aware for some time that beginning in May 2018 they must be compliant with the General Data Protection Regulation, which protects customer data when it is handled by those who collect it ("Controllers") and those who "Processors" who manipulate that data on behalf of Controllers.

Surveys reveal, however, that only 25 percent of U.S. companies believe the regulation applies to them. That misconception could cost them up to four percent of global revenues or €20 million (approximately $24.5 million), whichever is greater.

To drive home the point: if you have ANY customers who reside in or have their businesses located in the European Union, you are obligated to be complaint with the GDPR. There is no threshold for this, such as more than one percent or five percent or ten percent of your customers reside in the EU. Technically, if even one customer resides there, or you process credit card data there, the GDPR applies to you.

If businesses collect or process any personal data of EU residents, they have to follow strict rules such as reporting any data breaches within 72 hours of occurrence, getting consent from customers before collecting personal data, and offering customers the ability to request all of their records be deleted.

And here's an important wrinkle -- the GDPR applies to EU citizens even if they are not residing in the EU. That means eCommerce platforms will have to ask each new customer if they are EU citizens, and will have to include those who have become EU citizens after they already already part of your customer base.

One of the key components of GDPR is the way it governs data breaches, giving companies just 72 hours to notify users if their personal data has been compromised.

An article in Information Week summarizes what action to take to establish compliance. In brief, these are:

1. Determine if you’re a controller or a processor.
2, Audit your data to make sure you get a "single view" of each customer (because you may have customer data stored in more than one place).
3. You will need to appoint a representative for your company who is established in your EU supervisory country. This person is the point of contact for all communications with the GDPR supervisory body. 
4. "If required, appoint a Data Protection Officer. Not all organizations need one, but given the vastness of the compliance requirements, it may be wise to have one. Make sure this person has the expertise you need."
5. "Data subjects will need to check a box (or its equivalent) for every single use-case you have for their data. This includes profiling and big data purposes. They need to be able to select those they agree with and decline those they don’t, and you need to be able to comply and track their preferences in your systems."
6. Audit third-party providers to make sure they are compliant in their service-level agreements. 
7. "Consider where your data centers should be. Some companies are moving data centers to the EU to comply; some cloud-based database providers are able to easily discern and segregate EU data for you."

And if you won’t be 100-percent ready by May? Be sure to documentin all actions taken to build and implement your GDPR compliance framework. This will help provide evidence of your strategy and good faith for the regulators. GDPR is not demanding perfect privacy and security. According to Daniele Catteddu in another Information Week article, it’s asking for a risk-based approach to privacy.

Here's another Information Week article that provides a slightly different perspective.

Finally, says Ed Addario in yet another Information Week article, "Because of the complex system upgrades and internal process changes required for GDPR compliance, it’s safe to say that the shift will feel like a burden for IT, legal and HR teams at first. However, I see GDPR as a dose of tough love for organizations both inside and outside the EU. It serves as a forcing function for companies to modernize their data management systems, while improving how they communicate with, and relate to, their customers."

P.S. As Julie Hunt of juliehuntconsulting.com observes, "Third parties are extensive: payroll, marketing/digital agencies, anything SaaS, website/eCommerce management services, and so on. One phrase sticks with me: even though organizations may be controllers or processors, it's best that every org approach compliance as a data controller."

And - "US orgs are better served if they simply adopt GDPR as the 'gold standard' instead of fooling themselves into trying to manage data piecemeal, based on different regional regs. Way less mess & wasted time."

Why NOW is the best time to start searching for a new OMS/WMS/CRM platform

Multichannel merchants have more than a dozen fully integrated OMS/WMS/CRM third-party solutions to choose from (actually, down from three dozen in the 1990s). These are, by definition, complex systems that require careful specification and painstaking implementation to be fully functional and provide maximum ROI to the companies using them.

Implementation can take anywhere from six to eighteen months, with twelve months a practical goal if managed properly. Before running through a high-level pro forma schedule, let's focus on the "managed properly" aspect of the process.

There are three basic elements to such management:

1) The merchant must have a designated Selection and Implementation Team whose top priority is choosing and implementing the new system. The team should include a representative from purchasing, sales & marketing, operations/fulfillment, IT, eCommerce, and order entry/customer service. And it needs a Team Leader, who can be from any department or C-Level position, so long as they have a demonstrated track record for project management. This will be one of the most important and critical projects the company will be undertaking for quite some time, and cannot be sidetracked, neglected, or mismanaged. Everything is riding on its success.

Note, however, that none of the team members, including the Leader, will be working on the implementation project as a full-time commitment. Some days and weeks it will be full time and more, but in general it will require about eight to twelve hours per week, some in contact with the system vendor, others in meetings of the entire team or designated members, and some in administrative or follow-up tasks.

2) The Selection and Implementation Team must have an Implementation Plan. This must be done in close collaboration with the third-party vendors, which include at minimum the OMS/WMS/CRM provider, the eCommerce provider (if separate from the OMS vendor), the company handling sales tax calculation, and the company doing payment processing. There are some OMS solution providers who offer all of these services in one integrated package, but even then, there will be integration with other systems in the merchant's IT stack, including accounting, product management, merchandise forecasting, supply chain management, and so on.

And last but far from least, there will be data conversion, which can be a snake pit of problems and challenges. In general, since systems manage order data so differently from one another, merchants should keep the old system up and running for at least six months, and use it for looking up orders that were created on it. Customer and product look-ups and management, on the other hand, will be done on the new platform from Day One (see "Go Live" in the Pro Forma Schedule below).

3) No scope creep! Once the system has been selected, based on careful evaluation of how well it meets the defined criteria and functional specification, the functionality of the system should be "closed," with no "by the way" or "if you're doing that, can you do this?" Scope creep is death by a thousand cuts, and should be avoided completely!

PRO FORMA SCHEDULE

The following is a generic schedule for the entire systems specification, selection, and implementation process that can be adapted to suit any company's specific situation:

Month 1: Preparation
The company needs to determine first of all if a new system is really required. I have seen all too many instances where an initial planning group gets together to discuss general system needs, and discovers to its shock and delight that the current system can actually handle everyone's top priorities (and often more) but users were unaware because those functions had never been implemented or "turned on."

During the prep month team members should compile a list of system vendors to be included for consideration for the new system. In general, there are three "buckets" for candidate solutions. A) Systems that focus on one or two aspects of the OMS/WMS/CRM process, B) Systems that will meet most requirements, but from vendors who have a high-cost business model based on large sales teams and expensive database platforms, and C) "The Goldilocks" systems that manage all OMS/WMS/CRM functions and cost in the $50,000 to $500,000 range (for, let's say, 30 users; will be in seven figures for 50 user or more). The latter are specifically designed for multi-channel merchants.

Finally, in the Prep month the company needs to form the System Selection and Implementation Team and make sure everyone understands the process. The Team needs to determine the Team Leader, and contact any potential consultants that can assist with this process.

Month 2: Request for Proposal
A Request for Proposal, or RFP, can be an extremely detailed document covering a broad range of features and functions, or it can be a much more focused summary of system needs and requirements. If the latter, the top ten requirements should be described in sufficient detail to assure that system providers/vendors can ascertain the degree to which they can support them.

Month 3: Vendor Responses
The system vendors who have received the RFP will submit their responses. Some may request an extra few weeks to complete their replies, but in general, we can assign one month for this.

Month 4: Proposal Reviews
Some vendors will be eliminated based on system cost (way out of line with the trend) or lack of critical functionality. Those who remain based on review of their proposals should be contacted to do remote Web demos of about two hours or so. From this group (perhaps three or four vendors), two "finalist" candidates should be invited to do full-day, on-site demos at your facility.

Month 5: Vendor Selection
Based on the on-site demos (and review of any available system documentation), the Selection Team will make a final vendor selection, which should be based not only on "functionality" but also on how well you feel your organization will fit with the vendor's existing user "family." The companies using the system should be somewhat similar to yours in size, product range, and company culture. If the vendor personnel and/or the system users aren't compatible with your corporate style, the likelihood of long-term system success is greatly diminished.

Month 6: System Configuration Planning
Once selected, the vendor should meet with your Team and determine exactly which features and functions are the highest priority and focus on any configuration or customization that might be required to provide them. Even if you have a chosen a cloud solution with few if any options for modification, there will always be configuration to take care of, and this is the time for nailing it down in detail.

Month 7: Configuration Review/Data Conversion
The Team should review in minute detail all system configurations, and specify in detail how existing customer and product data should be converted for management on the new platform.

Months 8 and 9: Execute Configuration and Data Conversion; User Training
Training Users should be done in two phases. A week-long overview of the entire system for all users, followed by a week of training specifically for each user group on the features and functions they will be most focused on going forward.

Month 10: Go Live!
With the new system fully configured and populated with legacy customer and SKU data, and users ready to use the system, you are ready to cut over to the new system. I recommend doing this on a Wednesday, so that on the previous two days users can do a final "recap" or "review" of the new functionality (and often new terminology, as well), and can use Thursday and Friday to "clean up" any glaring or show-stopper issues or problems. Don't assume you won't have any such issues. You'd be the very first companies in history to be so lucky!

Months 11 and 12: Debugging, Documentation 
So certain is it that there will be problems of some kind that two months should be allocated for resolving all of them. Sometimes, fixing one problem will cause two others. That's just the way it is.

And finally, I have not included a full discussion of documentation in this overview for the sake of simplicity, but you need to pay attention to it. Review whatever documentation the vendor has provided to be sure it is current (it is often anything but!). If there is no adequate documentation, you should devote these two months to working with the vendor to create it specifically for your use. It can be on-line or a PDF or other format (including Evernote), and if possible, it should have keywords or an index for easy reference.

Finally, your business is constantly evolving. Work closely with your system vendor to make sure that your new system evolves with you to the extent that is possible. Remember, you're part of each other's "families" now, and you need to keep those connections refreshed and friendly!

P.S. If you are reading this in September, your new system should be truly and fully ready to Go Live this time next year, which is the perfect time for merchants who have a heavy fourth quarter order volume. Your company will be very busy in the fall, but you can be assured that when the orders start ramping up you will be able to handle them on your new stable and functional solution!

Questions? Please contact me at ernie@schell.com

4 Steps to Getting Started with the EU's General Data Protection Regulation

"Most data managers have now heard enough about the European Union’s General Data Protection Regulation that they’ve moved beyond denial, anger, bargaining, and depression to grudging acceptance that it will indeed require major changes in their operations," writes David Raab in an August 7 posting on the Information Management website. But this leaves many wondering exactly how to move ahead in adapting to the new regime.

Be sure to check out David's post - 4 steps to getting started with GDPR compliance - for all the details. 

Seattle startup offers online merchants overnight ground delivery to virtually the entire country

According to Supply Chain Brain, "In less than five years, Flexe has created a marketplace of spare storage space in 550 warehouses, quickly establishing better geographic coverage than the vast delivery network that Amazon.com Inc. spent decades and billions building. Flexe did it without spending a nickel on facilities and already has 25 million square feet of storage, about 25 percent of Amazon's capacity, and expects to add 10 million square feet this year. Merchants book storage space via a simple-to-navigate website; Flexe is essentially the Airbnb of warehousing.

"The new overnight delivery service, launching this week, is well-timed because online merchants are looking for new ways to reach customers but have few options that match Amazon’s speed. And because the inventory is stashed all over the country, overnight deliveries can be made by truck rather than plane, which is cheaper. Online brands such as mattress seller Casper also like Flexe because orders flow through their own websites, letting them maintain a direct relationship with customers."

The Progress Group becomes Crimson & Co North America

After two years in partnership, The Progress Group is renamed Crimson & Co and continues to extend its global footprint with offices worldwide beginning May 15, 2017

Leading U.S. supply chain consultancy The Progress Group LLC (TPG) is becoming Crimson & Co, whose global market includes Europe, Australia, South America and Asia.

For the past two years as part of the Crimson & Co network, TPG and Crimson & Co have brought expanded capabilities and expertise to the global market. This step in TPG’s strategy for growth is to offer a greater scope of supply chain consulting services in North America and globally, with one vision, and one name.

Bruce Strahan, President of The Progress Group, stated, “After more than a quarter century as The Progress Group, we’re proud to announce we will now be known as Crimson & Co. While we take the official name of Crimson & Co, our experienced local team and commitment to high quality and service will not change.”

Richard Powell, CEO of Crimson & Co, based in London, said “In 2014 we started our global partnership and it has proven valuable for our clients by enhancing our capabilities worldwide, as we continue to work towards our strategic vision. We are pleased to be taking this next natural step in solidifying our global brand, especially with The Progress Group team.”

Strahan continued, “By working as close partners with Crimson & Co over the past two years, we have learned that our global reach and combined industry experience offers our clients a significantly enhanced depth of value. We look forward to continued growth for Crimson & Co.”

Crimson & Co NA, formerly The Progress Group, provides a range of services including strategic planning, facility and operations design, cost reduction, process improvement and program management and its expertise includes design through implementation of supply chain initiatives and supporting IT solutions.

About TPG, now Crimson & Co NA:

Crimson & Co North America (formerly The Progress Group) is a management consultancy specializing in supply chain management and logistics. Established in 1991 and based in Atlanta, Georgia, they provide services to Fortune 100 as well as mid-market clients. Crimson & Co NA offers services ranging from strategic planning, facility and operations design, cost reduction, process improvement to program management. Expertise includes design through implementation of supply chain initiatives and supporting IT solutions. Crimson & Co NA is part of the global brand, Crimson & Co. For more information, please see their global website at http://www.crimsonandco.com/and the NA website at http://www.crimsonandco.us/.

About Crimson & Co:

Crimson & Co is a global supply chain consultancy that thinks differently. It stands shoulder to shoulder with clients as it develops outstanding supply chains, using deep operational experience and broad-based business skills to challenge, guide and implement. Its strength is its consulting team, which it nurtures with care, and it has an approach and culture that its clients believe is unique.

The company was founded in 2003 as a breakaway from one of the major consultancies and its scope spans supply chain strategy, planning, procurement, manufacturing, logistics and customer channels. It operates on all continents, with offices in London, Atlanta, Mumbai, Melbourne, São Paulo and Singapore, and typical clients are blue-chip organisations such as Sony, Diageo, Carlsberg, BAT, GSK, Tesco and Merck.

For more information, please see: www.crimsonandco.com