A new government report says the U.S. Postal Service isn’t doing enough to monitor the use of its national change of address (NCOA) files to prevent them from being used to create new-mover marketing lists.
The report was prepared for the House Postal Subcommittee by the General Accounting Office (GAO), the investigative arm of Congress. The GAO recommended legislative action if the USPS fails to act within a reasonable amount of time to tighten its controls over the NCOA program, which is used by 23 licensed companies to ensure mailing list accuracy.
NCOA operational rules are not always followed or are unevenly enforced by postal workers, according to the GAO, which recommended the USPS develop and implement written NCOA program oversight procedures. “Until these program oversight and enforcement procedures are effectively documented” the USPS will not really know if the rules and regulations governing the NCOA program are being properly followed by the 23 licensees and its employees, the report stated.
But in a statement that was included in the report, Postmaster General William J. Henderson said the USPS is implementing a number of program recommendations by the GAO in 1996, when it last reviewed the NCOA program.
They include tightening the controls and monitoring of the 23 list companies licensed to access NCOA files; suspending the licenses of firms failing to adhere to file use regulations; including the use of seed or dummy mailings to check for violations; and improving internal communications to report violations of NCOA licensing agreements and regulations.
Henderson also disputed a GAO claim about federal privacy laws preventing the customers of the 23 licensees from creating new-mover lists based on NCOA corrections to their files.
The USPS “has neither the legal authority nor the practical ability to regulate how the owners of mailing lists may use those lists once they have been matched against the NCOA database,” he said, adding that list owners “have always been free to sort, divide or otherwise manipulate their lists to create other, more specialized lists.”
The fact “that these lists necessarily contain some corrected addresses,” he continued, “does not diminish the fact that the lists are the property of the list owners [and] without an effective way to enforce a prohibition on the creation of new movers lists, such as sending postal inspectors into mailers’ plants, revising the acknowledgement agreement form to explicitly prohibit their use would be an empty gesture.”
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