Business media sources for qualified nonpaid circulation
Definition and Reporting
Circulation classified as “Direct Request from Recipient’s Company” represents nonpaid circulation requested by a company’s management for specified employees in writing, over the phone, online, or via email. The company’s management has verified the qualification of the recipient to receive the publication. This class of circulation also includes requests from authorized assistants for more than one employee.
In paragraph 3B Age of Source, the publisher discloses nonpaid circulation by source and age of request.
As an option, a publisher may disclose the source in more detail by including the method used to obtain the request.
Written (Including Internet and Email)
Written (including Internet and email) represents nonpaid circulation requested by a company’s management for specified employees in writing, online or via email. The company’s management has verified the qualification of the recipients to receive the publication.
All circulation classified as Direct Request from Recipient’s Company – Written (including Internet and email), is acceptable if all of the following criteria are met:
- Requests must be obtained in writing, online, via email or other electronic means.
- Requests must be from a company for specified employees.
- Recipients must be in the publication’s field served.
- Recipients must meet the definition of a qualified recipient.
- Requests must be dated and not older than 36 months.
- For print requests, the letter or form must:
- Identify the request as from the company for specified employees (i.e., on company letterhead).
- Include a statement acknowledging desire for employees to receive the publication (i.e., “Please send XYZ Journal to the following employees:”)
- List intended recipients identified by name and title or function.
- Include the name of the authorized individual making this request (i.e., department head, general management, etc.)
- Include the signature and date of authorized individual.
- For email requests:
- The request must also present a personal identifier question for which only the authorized requestor is likely to have an accurate response (since a signature cannot be obtained). Examples of such questions include month of birth, mother’s maiden name, state of birth, first school attended, etc. Different questions must be used for renewals.
- For Internet requests:
- If the requestor is required to use a unique username and password provided by the publisher to access an Internet request form, nothing further is needed.
- If a request can be completed without a username and password, a personal identifier question is required. Examples of such questions include month of birth, mother’s maiden name, state of birth, first school attended, etc. Different questions must be used for renewals.
- All records to support the request must be maintained for auditor review.
Telecommunications
Telecommunications represents nonpaid circulation requested by a company’s management for specified employees via inbound or outbound phone call. The company’s management has verified the qualification of the recipients to receive the publication.
All circulation classified as Direct Request from Recipient’s Company –Telecommunications, is acceptable if all of the following criteria are met:
- Requests are obtained via inbound or outbound phone call.
- Requests are from a company for specified employees.
- Recipients are in the publication’s field served.
- Recipients meet the definition of a qualified recipient.
- Requests are dated and not older than 36 months.
- The phone interview must:
- Ask if the publication is desired for employees (i.e., “Would you like this publication sent to some of your employees?”)
- Obtain a list of intended recipients identified by name and title or function.
- Include the name of authorized individual making this request (i.e., department head, general management, etc.)
- Present a personal identifier question for which only the authorized requestor is likely to have an accurate response (since a signature cannot be obtained). Examples of such questions include month of birth, mother’s maiden name, state of birth, first school attended, etc. Different questions must be used for renewals. If the transaction is recorded, confirms the requestor’s identity and the recording is made available for review during the audit, a personal identifier question is not required.
- Include a signature and date from the interviewer (interview form).
- All records to support the request must be maintained for auditor review.
REMINDER: Direct Request from Recipient’s Company includes requests from authorized assistants for more than one employee. If this is the case, telemarketing materials must adhere to the requirements outlined above for telecommunications and must also include:
- A question acknowledging the assistant’s authorization to make this request on behalf of the recipients. For example, “Do you provide administrative support for [list of recipients] that includes authorization to request subscriptions for these individuals? Yes ___ No ___.”