ACME Trading Company Catalog – “Keycode” and “Customer Number”

UPDATED January 2017

PS-159 (243.2.2)

This Customer Support Ruling discusses whether certain information inserted into a mailpiece by computer constitutes “personal information” within the meaning of postal standards governing what may be mailed as USPS Marketing Mail and what must be mailed as First-Class Mail.

At issue is the classification of a printed catalog. In addition to the name and address of the addressee (which are generally not considered to be personal information), the catalog includes items of information generated by computer that are labeled “Keycode” and “Customer ID”.

Under the provisions of Domestic Mail Manual (DMM) 243.2.2 material containing personal information may be subject to First-Class Mail, Priority Mail, or Priority Mail Express postage. Personal information is any information specific to the addressee. Printed matter may be eligible for entry as USPS Marketing Mail as long as it does not contain a bill or statement of account or personal information.

Computer-generated matter is not invariably considered to be personal information. Rather, consideration must be given whether each item is information that is specific to the addressee. These determinations are made based on the specific contents of the mailpiece.

Numbers or other information that is labeled in a mailpiece such as shares of stock are considered to be personal information. However, if that same information is not labeled or otherwise described or identified in the mailpiece, it is not considered personal since an individual reviewing the piece could not determine, solely from the piece itself, what the item conveys.

Other numbers or information might not be considered personal even if they are labeled. These include information bearing an “innocuous” label such as a “Routing Number,” “Account Number,” “IBID Number,” or similar information number that is included in a mailpiece, but is internal to the sender. It is important to note, however, information bearing an “innocuous” label may be considered personal information if it is described elsewhere in the mailpiece, e.g., “…Use your IBID number to identify the number of shares of stock you own.”

In this case, the “Keycode” and “Customer ID” are computer generated and found on the address page of an ACME Trading Company product catalog. This information is used by ACME when taking orders by mail, internet, or by telephone from a customer. The “Keycode” and “Customer ID” are not considered “personal information” for purposes of determining USPS Marketing Mail eligibility. Rather, they are bits of information that enable ACME to simplify the taking of orders for products advertised for sale within the contents of the catalog. The Keycode identifies a catalog edition. The Customer ID identifies to ACME a previous ACME customer.

Therefore, the Keycode and Customer ID in this mailpiece are not considered personal information that would disqualify the ACME Trading Company catalog from entry at USPS Marketing Mail prices.

(signed)

Sherry Suggs

Manager

Mailing Standards

Headquarters, US Postal Service

Washington, DC  20260-3436