In this Customer Support Ruling, a case study of a financial
institution’s mailing clarifies what is considered “personal
information” when determining what may be mailed as Standard Mail and
what is required to be mailed as First-Class Mail. The mailer in this example has requested
to pay Standard Mail prices on the mailing.
The Domestic Mail Manual
(DMM) provides that mailpieces containing personal information must be
entered at First-Class Mail prices with limited exceptions. For example, personal information may not
be included in a Standard Mail mailpiece unless three conditions are met:
the mailpiece contains explicit advertising for a product or service for
sale or lease or an explicit solicitation for a donation; all of the
personal information is directly related to the advertising or
solicitation; and the exclusive reason for inclusion of all of the personal
information is to support the advertising or solicitation in the mailpiece.
The determination whether a mailpiece contains personal
information is based solely upon examination of the mailing. If information which generally would be
considered personal in other contexts is the same in each piece in the mailing it will not be considered
“personal” for determining whether the mailpiece is eligible
for Standard Mail.
In this instance, not all pieces in the mailing are
identical. Information such as
Consumer Reporting Agency, Address, Toll-free Telephone Number, Decision
Date, and Dealer Name, vary within the mailing resulting in a preliminary
determination that mailpieces within the mailing do contain personal
information. However, upon further
consideration, the facts in this case reveal that there are at least 200
identical pieces of each particular variation within the mailing. Accordingly, since the volume requirement
for Standard Mail is 200 or more pieces or 50 or more pounds of mail, the
mailer could prepare separate mailings for each variation that would
qualify as Standard Mail. However,
if the mailer consolidates the separate mailings into a single mailing,
there is a processing efficiency for the Postal Service, therefore, the
mailer’s request to enter the mailing as Standard Mail is approved.
also DMM 333.2, 433.2, 343.2, and 443.2.