ACME Trading
Company Catalog – "Keycode" and "Customer Number"
Updated February 2005
PS-159 (343.2.2)
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 Standard 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) 343.2.2* material containing
personal information may be subject to First-Class or Express Mail
postage. Personal information is any information specific to the
addressee. Printed matter may be eligible for entry as Standard 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 Standard 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 the
Standard Mail rates of postage.
*See also DMM 243.2 and 443.2.
(Signed)
Sherry Suggs Manager
Mailing Standards
United States Postal Service Washington DC 20260-3436
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