WireWheel helps Shoes.com manage consents and preferences—on a compressed timeline
Even under the best of circumstances, getting a clear picture of customer data and setting up a data compliance system can sometimes be a challenge, requiring multiple teams working together to get the job done. Now imagine trying to accomplish this task in the midst of a merger—on a compressed timeline of only six to eight weeks.
This was the situation Shoes.com was facing at the end of 2020. As the footwear retailer was being merged into another company, it enlisted the help of WireWheel to develop a strategy for managing customer data privacy consents and preferences during the merger.
Managing data during an ownership change
Shoes.com had been previously owned by Walmart, which maintained a robust data privacy system and was well-equipped to handle data requests and consents. However, Shoes.com was acquired by a private equity firm in October 2020 and entered into a merger with Running Specialty Group (RSG), an active lifestyle retailer specializing in footwear.
With the merger, Shoes.com needed to migrate off of Walmart’s data privacy platform and get up and running with its own system in a matter of weeks—while at the same time maintaining the old one that Walmart had built. What’s more, Shoes.com also faced the challenge of working with new vendors, new requirements, a new legal team, and a new corporate culture. “We had rules around data privacy previously set up with WireWheel through Walmart,” says Paul Branco, senior director of product management, UX, and analytics for Running Specialty Group. “With the merger, that changed, so we were following a different set of rules as we were migrating off Walmart’s system.”
While it initially seemed like Shoes.com was looking at a relatively straightforward data migration and integration, it quickly became apparent that was not the case—particularly after data privacy issues were factored into the project. “It’s a larger undertaking than we originally anticipated,” says Branco. “We assumed it would just be a single dev team that could crank it out and be able to work on all the integration pieces, but obviously there is a lot more complex than that.”
Tackling integration complexities
To make the transition as seamless as possible, Shoes.com leaned on a development team, tasked with answering system questions as they came up during the integration. That team worked closely with WireWheel to make integration as seamless as possible. “We had the WireWheel team, and then we had our dedicated development team,” says Branco, “and that partnership helped us stand up the integrations with all of our systems.”
Shoes.com began with a systems overview to help them get a handle on the scope of the integration, and during this process, the WireWheel team worked closely with Shoes.com to put a data privacy framework in place. “During the audit, we said, ‘These are the systems that are needed,’” says Branco. “Oracle is the database that we used to house all customer information and then we had a marketing email system and other systems collecting customer data—those are the areas where WireWheel helped us to integrate so that we would then be able to take action on customer data.”
Following the systems’ overview, Shoes.com and WireWheel conducted a vendor audit to determine what customer data is possessed by vendors—such as third-party companies that might handle rewards points. With WireWheel’s assistance, Shoes.com was able to gain a clear picture of who possessed its customer data. “We contacted all our vendors to discuss how requests are handled: Whether the vendor took care of it after being notified, or if we needed to send additional information and help with the deletion,” says Branco. “It was important that we understood the scope of whether they collect customer data or whether they don’t.”
Any data migration is a complex process requiring careful planning and execution. But throw in data privacy requests occurring at the same time, and the potential for chaos increases. “At the same time, we had customers reaching out during the migration wanting to opt out or delete their information,” Branco says. “Where does that information live now? Is it in both systems? Is it only in one? Or is it in the old one or the new one? When a customer reaches out, you need to know where that data lives. So Wirewheel helped us with that part of the tracking, while also figuring out how we take action on this data during the migration.
The legal environment around data privacy is constantly evolving—and trying to keep up with the changes and new requirements can be daunting. “We’ve seen a lot of issues in the gray areas of CCPA, where the wording might mean one thing to one lawyer and another thing to a different lawyer,” he says.
Branco and his team not only relied on corporate counsel but also leaned on WireWheel for best practices and assistance through the legal complexities of data privacy. “We would reach out to WireWheel and say, ‘What have you guys seen with companies that you work with in the past? Can you provide some guidance?’”
Branco notes that conversations with his legal team and WireWheel helped clarify how Shoes.com would approach customer data, and gave the company a solid foundation for creating a strategy for best handling consents, preferences, and customer data. “We discussed where we could ‘cut the fat’ and where we needed to follow guidelines more strictly,” he says.
To that end, Branco and his team elected to take action on all data requests, regardless of jurisdiction, simply because the momentum seems to be building toward a patchwork of data privacy regulations that will vary from state to state. “We decided that we’re just going to take action on everything, because down the line, as new states get up and running with new privacy laws, we’re eventually going to have to process those requests.”
As the legal landscape continues to shift, Branco is confident that his company now has a valuable partner to assist with data privacy compliance across the board. “Massachusetts might handle things differently from Rhode Island, which is going to handle things differently from California,” he says. “So, every time we add a new state or new functionality, we’re going to pull in legal and say, ‘We need guidance here,’ and we’re going to lean on the WireWheel team too and say, ‘What have you guys seen? What is your recommendation?’”
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