By Jay Cline, CIPP

It's an elusive dream for many CPOs: monetizing the value of privacy and consumer trust. But that's what's starting to happen at Countrywide Financial Corporation following its implementation last year of a new enterprise system for managing consumer privacy preferences.

The lift couldn't come at a better time for a company with such a large privacy footprint. Founded in 1969, the Calabasas, California-based enterprise is the largest mortgage originator and servicer in America. At the end of November 2007, Countrywide counted over 9 million loans in its servicing portfolio with an unpaid principal balance of nearly $1.5 trillion. Countrywide's family of companies also provide loan-closing services such as credit reports, appraisals, and flood determinations; banking services such as depository and home-loan products; fixed-income securities underwriting and trading activities; property, life, and casualty insurance; and captive-mortgage reinsurance. Although its business is concentrated in the U.S., Countrywide also operates in India, Costa Rica and the UK.

With customers in so many lines of business, Countrywide's consumer privacy preference management stakes are high. To learn about how the company is navigating this challenge, Inside 1to1: Privacy recently caught up with Countrywide's Chief Privacy Officer, Christine Frye.

Frye and her team of 19 report to Countrywide's Chief Data Security Officer, Steve Taw, who also manages the Enterprise Data Security and Privacy Office as well as the Technology Risk Management, Technology Compliance, and Business Continuity and Disaster Recovery functions.

For her part, Frye's charge is to oversee privacy strategy, policy and standard creation across the enterprise from a regulatory and operational focus.

"Our privacy and preference management program is essential in positively influencing customer trust in the Countrywide brand," Frye said. "A positive consumer experience can lead to increased loyalty and participation in our marketing initiatives."

One of the challenges Frye encountered early in her tenure at Countrywide was a decentralized set of business processes for managing consumer opt-out requests. She also struggled with a legacy system that did not have the flexibility to keep pace with business needs, and a flurry of new laws and regulations for telemarketing and email marketing. These situations often culminated in translating an opt-out request into a blanket opt-out across all communications channels and all Countrywide products.

"Not being able to maximize our communications with customers while still honoring their privacy preferences resulted in losing consumer participation in our marketing initiatives," Frye said.

So, four years ago, Frye championed the development of an integrated, one-stop shop for managing consumers' privacy choices. The system, known internally as the Enterprise Preference Management System (EPMS), launched in March 2007, and is already generating results.

"We've reduced staff time, improved the quality of our compliance controls and reporting, and expanded the choices available to consumers," said Ryan Barker, First Vice President, who reports to Frye and oversees consumer privacy preferences.

EPMS enables Countrywide to store a consumer's information-sharing and marketing preferences and honor those preferences in its marketing campaigns. Consumers can choose whether to opt out of marketing communications via email, phone or postal mail. Consumers even have the ability to choose to receive direct mail at one address but not another, or only receive certain categories of marketing offers. Through this granular level of preference management, EPMS has increased the number of consumers eligible for campaigns to market other Countrywide products.

The new approach also has helped staff by sending automated alerts when do-not-call and other suppression lists should be loaded into the system. In addition, the system's reporting function has enabled Countrywide's marketing department to learn which campaigns fared better or worse at generating opt-out requests. In one recent telemarketing campaign, for example, the company discovered that its consumers who'd designated a cellphone as their preferred contact point for certain communications had lower opt-out rates.

"Privacy is a top priority for Countrywide," Barker explained. "Not just from a regulatory standpoint, but from a customer experience perspective."

"Our customers expect that we will use their information according to their preferences," he added. "The overarching theme of Countrywide's approach to privacy preference management is one of brand protection consistent with an understanding of the business need to effectively market products and services. EPMS helps us in this effort."
This brand-approach to privacy may be paying off. In the Ponemon Institute's 2007 Most Trusted Companies for Privacy Study, Countrywide was one of four new companies joining the top 20 rankings.

"We believe this increase in trust is based on the enhancements we've made to the privacy program and our proactive risk assessment process," said Frye.

Editor's note: As we were going to press with this article, Bank of America announced its intention to acquire Countrywide, a transaction expected to be completed late this year. The merger will join two of the country's more mature privacy programs and create one of the largest financial institutions in the world.

Cline is President of Minnesota Privacy Consultants and can be reached at cline@minnesotaprivacy.com


If you want to comment on this post, you need to login.


Related Posts


Board of Directors

See the esteemed group of leaders shaping the future of the IAPP.

Contact Us

Need someone to talk to? We’re here for you.

IAPP Staff

Looking for someone specific? Visit the staff directory.

Learn more about the IAPP»

Daily Dashboard

The day’s top stories from around the world

Privacy Perspectives

Where the real conversations in privacy happen

The Privacy Advisor

Original reporting and feature articles on the latest privacy developments

Privacy Tracker

Alerts and legal analysis of legislative trends

Privacy Tech

Exploring the technology of privacy

Canada Dashboard Digest

A roundup of the top Canadian privacy news

Europe Data Protection Digest

A roundup of the top European data protection news

Asia-Pacific Dashboard Digest

A roundup of the top privacy news from the Asia-Pacific region

IAPP Westin Research Center

Original works. Groundbreaking research. Emerging scholars.

Advertise in IAPP Publications

Find out how to get your message in front the people you want to reach. Download a media kit now.

Get more News »

Find a KnowledgeNet Chapter Near You

Network and talk privacy at IAPP KnowledgeNet meetings, taking place worldwide.

Women Leading Privacy

Events, volunteer opportunities and more designed to help you give and get career support and expand your network.

IAPP Job Board

Looking for a new challenge, or need to hire your next privacy pro? The IAPP Job Board is the answer.

Join the Privacy List

Have ideas? Need advice? Subscribe to the Privacy List. It’s crowdsourcing, with an exceptional crowd.

Find more ways to Connect »

Find a Privacy Training Class

Two-day privacy training classes are held around the world. See the complete schedule now.

Online Privacy Training

Build your knowledge. The privacy know-how you need is just a click away.

The Training Post—Can’t-Miss Training Updates

Subscribe now to get the latest alerts on training opportunities around the world.

New Web Conferences Added!

See our list of upcoming web conferences. Just log on, listen in and learn!

Train Your Staff

Get your team up to speed on privacy by bringing IAPP training to your organization.

Learn more »

CIPP Certification

The global standard for the go-to person for privacy laws, regulations and frameworks

CIPM Certification

The first and only privacy certification for professionals who manage day-to-day operations

CIPT Certification

The industry benchmark for IT professionals worldwide to validate their knowledge of privacy requirements

Certify Your Staff

Find out how you can bring the world’s only globally recognized privacy certification to a group in your organization.

Learn more about IAPP certification »

Get Close-up

Looking for tools and info on a hot topic? Our close-up pages organize it for you in one easy-to-find place.

Where's Your DPA?

Our interactive DPA locator helps you find data protection authorities and summary of law by country.

IAPP Westin Research Center

See the latest original research from the IAPP Westin fellows.

Looking for Certification Study Resources?

Find out what you need to prepare for your exams

More Resources »

GDPR Comprehensive: Registration Open

New! Intensive two-day GDPR training led by the sharpest minds in the field. It's a can't-miss event.

The Congress Is Cancelled

The IAPP Europe Data Protection Congress 2015 is cancelled. Click through to learn more.

Sponsor an Event

Increase visibility for your organization—check out sponsorship opportunities today.

Exhibit at an Event

Put your brand in front of the largest gatherings of privacy pros in the world. Learn more.

More Conferences »

Become a Member

Start taking advantage of the many IAPP member benefits today

Corporate Members

See our list of high-profile corporate members—and find out why you should become one, too

Renew Your Membership

Don’t miss out for a minute—continue accessing your benefits

Join the IAPP»