Q&A with PromoVeritas
Founded in 2002, PromoVeritas is a UK-based company that helps companies worldwide to run promotions. Although their client is the promoter, they feel strongly that by running promotions fairly and securely they are helping to protect the rights of honest consumers from disreputable practices by brands and fellow entrants (or ‘scampers’, as they call them!). PromoVeritas write terms and conditions, judge competitions, select winners for prize draws, oversee distribution for instant wins, and verify voting for TV talent shows. They also contact winners, and arrange prize distribution.
PromoVeritas kindly offered to answer questions posed by SuperLucky fans on the Facebook page, and here are their responses. If you have further questions please do leave them as a comment and I’ll ask PromoVeritas if they are able to respond.
Chris: I wonder about ‘random’ selection of winners. I cannot believe they select a truly random entry as chances are, they may pick a right dog of an entry that would not look good for their brand. It seems some companies just do what they like and pick a decent entry that appeals. Am I right in thinking there is a chance they whittle it down to several good entries and ‘randomly’ pick one of those?
There is good and bad practice in every industry and there is no doubt that some promoters do pick their own winners, and may do so in ways that are less than fair – based on geography, retailer, age or other factors. At PromoVeritas our whole aim is to ensure fairness and integrity in the running of promotions and we follow the CAP Code stringently. When we get asked to conduct a draw for a client, first of all we check the data against any restrictions in the Terms and Conditions (eg. only one entry per day or aged over 21) to ensure compliance and then the data is randomised and allocated an unique ID number. Winners and reserves are selected using our random number generator software that outputs a list of winners and their prizes. We will often be involved in contacting the winners directly and verifying their eligibility. Once completed, the winners list is sent to our client and we monitor their fulfilment of the prizes – to make sure it is done speedily and to the right people. Occasionally we may come across clients who would prefer a different winner was selected but it is our job to make sure that the selection and communication is done completely honestly. Of course we may occasionally recognise a familiar name or two on the winners lists, eg. a comper, but that is not our concern. As long as they have followed the rules they are still winners.
Sarah: Is there a rule about how hard companies try to contact the winner? It seems that more and more often they just write the winner’s name on their page rather than contact them directly or tag them. This makes it easy to miss the fact that you have won.
It all depends on what is written in the T&Cs. The general advice is that there should be reasonable efforts to contact a winner over a reasonable period of time. No specific number of days is specified in the CAP Code, but PromoVeritas always aim for at least 14 days unless there are reasons why it should be less. Some radio stations frequently offer prizes of tickets to the cinema for the next day, so forcing us to hold a prize open for 28 days would be pointless. If it is a short period of time, then it should be make clear to entrants via entry instructions and the terms. As for reasonable efforts to contact, we tend to make at least three phone calls, at varying hours, plus if we have an address we will get in touch via registered post for major prizes. If the terms state that winners will be announced via a social media post and must claim their prize within a set time, the promoter does not need to make any additional effort to contact them. At PromoVeritas we make every effort to make sure a winner is contacted properly – we usually send a Private Message but because this goes into the ‘Other Messages’ folder, not everyone sees them instantly! Ideally we would love promoters to gather proper contact information, eg. email and address, from entrants, but many are put off by the extra cost plus the belief that the more you ask of an entrant, the less likely they are to participate.
Chevaune: Why do some companies name winners and others say that they need to keep it confidential? I have tried over and over to get winners names from some companies without success.
CAP Code 8.28.5 requires that promoters either publish or make available on request the name and county of winners but it also says that they should get permission of the entrants/winners to do so. This is because there is a potential conflict between the desire to show that prizes have indeed been awarded and the privacy of the individual. Imagine if the prize was £1million, you might not like all of your friends and others to know that you had suddenly become very rich! But normally, with low level prizes it is not a problem and promoters either say write to a PO Box after the closing date or they may use our promowinners.com service for a simpler method of ensuring that they are compliant. If there is no mention of winners publicly then you can report them to the ASA – chances are the other aspects of the promotion are being run unfairly.
Hilary: For a recent competition I won, the prize-winners were not treated very well. Do companies really value the PR these comps give them?
It is really sad when prize winners, who should be the biggest advocates of the brand, are not treated well. We estimate that about 20% of prizes are sent out without any notification as to who has sent it, and there are disasters such as the Red Bull VIP Trip to the Belgian Grand Prix that give promoters a bad name. At PromoVeritas we always try to ensure that we treat winners well, from the first phone call or the personally signed letter that is sent with the prize. However some clients prefer to leave it to cheaper fulfilment houses or inexperienced staff and end up with poor results – let them know you’re not happy and resort to social media if you have to!
Angie: If a promotion is being drawn by PromoVeritas do they also deal with it? I have seen a comp recently where they have changed the closing date – is that down to the company themselves or PromoVeritas?
Our main role is the independent verification of promotions – so the drafting of the terms and the selection of the winners. But it is still run by the promoter, and sometimes they make mistakes – eg. promotional packs are not available for the start date, or the prize has to be changed. Under the CAP Code (clause 8.17.4) terms should not be changed once issued, especially if they are against the interest of the consumer, eg. by extending the closing date. However sometimes there are exceptional circumstances – in which case we always recommend that the promoter announces these changes big and bold and seeks to ensure that consumers are not disadvantaged.
Helen: How do companies pick a winner for a “Like/Share” or “RT and Follow” comp?
At PromoVeritas we use one of our specialist software programmes to extract all the data fully from the relevant social media platforms. This may require us setting up the tool in advance or running it several times during the promotion because some platforms only allow us to pull the last seven days data or the last X entrants. When we are satisfied that we have all the entrants, then we can conduct the draw – we treat the data exactly how we treat all prize draw entries, giving each entry a unique code, randomising the data and selecting winners using our winner selection software. Unless promoters have specialist software like ours, it is unlikely that they are selecting the winner from all correct entries. If you doubt the validity of a Facebook promotion you should report it to Facebook AND also to the ASA.
Stacy: I’d like to know more about IP address disqualifications. I have banned my hubby from doing Rafflecopter and Gleam giveaways as I heard it was classed as cheating, even if it’s from different Facebook/Twitter accounts, as we both have the same IP address.
An IP is an identifier for your approximate location and it can be used to control access to promotions – to prevent people entering multiple times even if they claim to be different people, eg by using different email addresses. BUT IP is a fairly blunt instrument, it is not PC specific, it is location specific. So your office might have one IP, but there are 40 people working in that office. So if a promoter uses IP blocking, if you enter, and then your friend does, your friend might be blocked, which is unfair, because they should be able to enter too. PromoVeritas do not use IP blocking, except for some international promotions, where we can use IP to reliably tell us if someone is trying to enter from an eligible country or not.
(In terms of Gleam & Rafflecopter giveaways, when validating a winner the promoter/blogger can see all entries from the same IP address – but it is difficult to determine whether these are entries from one person cheating by using multiple accounts, or genuine entries from different people. I suggest it’s safest to tell other household members to avoid entering the ‘widget’ comps, and stick to doing them yourself! – Di)
Georgie: If promoters are encouraging us to be creative in a comment or submit a picture then why don’t they select the winner on creativity, not at random?
We totally agree! We run many fun and inventive competitions from recipes to photos which really capture entrants’ imaginations. However judging all these entries takes time and money, and it is often much cheaper and quicker to run a simple prize draw! So always read the rules to see whether winners will be selected at random, or by judging. If it’s a draw, then you do not need to waste your time on being creative, it should make no difference. If you see a well known brand running a promotion you think could be done better let them know, they are always open to consumer’s opinions.
Emma: How do promoters choose from Facebook, Instagram and Twitter for the same competition?
We judge lots of photo competitions and we have a variety of software tools that do enable us to ‘scrape’ the data from all the different platforms and then we can judge them all equally, likewise if they are just to be entered into a prize draw they each image will be given a number reference and from those we will select a winner at random using our computer programme regardless of the social platform used.
Ruth: When they choose a winner do they think this is a man’s prize (eg. power tools) or a woman’s prize (eg. jewellery) – I wonder if gender or age affects the choice?
We can honestly say that this is never a factor in winner selection – the process that we use operates with no reference to gender, age, geography or any other factor. It is random, and if a man wins a dress so be it! We work with a leading online fashion brand and I can assure you that when we are involved that all of their prize draw winners are selected randomly from the relevant entries and unless there are specific entry criteria everyone should have the same chance of winning a prize draw regardless of age or demographic.
Stacy: I’d like to know how the text entry comps can charge so much, or so little. How can some companies charge £2+?
Anything other than a standard text charge is regarded as a premium cost to enter a promotion, and under the Gambling Act it will only be allowed if it is either a competition (a genuine game of skill or judgement) OR there is an equal, parallel and well communicated alternative free entry route (eg via email or post). So where there is say a £2 text charge and a pathetically easy question, then in theory there should be a free route. It is important that entries to this free route are treated equally and have the same chance of winning as those who have paid. We hope that occurs but we can only say it does for those where we are directly involved.
Stacy: With email entries, is it better to enter at the start, middle or near the end date? I’ve got some comps in mags with an end date of October/November, so I save them in a file to enter nearer the closing date. Would this make any difference, instead of entering the day I buy the mag?
If the promoter is using a reputable promotional verification service such as PromoVeritas then when you decide to enter the promotion will no difference to your chance of winning. We gather all eligible entries together after the closing date and then winners are selected at random so the chances of winning are completely fair and even! But some promoters may conduct their own draws, and typically it might involve asking a colleague to pick a number between 1 and 900 (if there were 900 entires). Humans being human very rarely go for extremes, so most people would respond with a number between the range of 200 – 700, so those who enter in the middle of the promotion would have a better chance of winning, but I stress, doing it this way is not allowed under CAP. It should be done fairly, randomly and under independent supervision.
Thankyou to Abi at PromoVeritas for answering our questions! You can find out more about their work and clients at www.promoveritas.com.