Your CRM Knows the Customer’s Preferences. Does Your Dealership?

A customer tells someone in your dealership they would rather receive a text than a phone call.

The employee makes a note. The CRM may even have a dedicated field for the preference.

But what happens the next time someone in Service, Sales or Marketing contacts that customer?

Can the dealership show what the customer asked for, when they asked, who received the request and what happened afterwards?

Or does the business have a tick in a CRM field and little else?

That distinction matters.

Most dealerships understand the importance of capturing customer details. They invest in websites, lead-generation activity and CRM systems to make sure enquiries become identifiable opportunities.

But capturing a lead and governing the relationship that follows are two different things.

A dealership can have a customer's details, a record of their preferences and a sophisticated CRM, yet still fail to communicate in the way that customer has asked.

The issue is not always a lack of technology.

It is often a lack of process, shared responsibility and management accountability. And increasingly, it is a question of whether the dealership can evidence what it did when a customer changed their mind.

Capturing the lead is only the beginning

When a customer submits an enquiry, the dealership has an opportunity to start building a relationship.

That is the front door.

The next challenge is making sure the relationship is managed properly over time.

A customer's circumstances and preferences can change. They might be happy to receive a call about a vehicle enquiry but prefer email for routine updates. They might be available on their mobile during the day but not want calls at work. They may be content to receive service reminders but have no interest in promotional messages.

These are not necessarily complicated requests. But they need to be recorded accurately, understood by the people who use the information and acted on consistently.

This is the difference between holding customer data and managing a customer relationship.

A CRM record can tell you what someone said at a particular moment. It does not, by itself, guarantee that every relevant employee or department will know what has changed.

A preference recorded is not necessarily a preference respected

In my experience, most dealership CRM systems I worked with had fields for recording customer communication preferences. Many also kept a history of changes, often identifying the employee who made the update.

The technical capability was there.

The weakness was what happened around it.

A customer might tell one employee that they no longer wanted telephone calls, or that they would prefer a text. The employee could update the relevant CRM field, but there was not always a comment or notification to make the change obvious to the next person dealing with that customer.

The record had changed. The working knowledge across the dealership had not necessarily changed with it.

There is an important distinction here between recording a preference and being able to demonstrate what the customer actually agreed to.

The ICO’s guidance on recording consent says that, where consent is given orally, the organisation should record the time and date of the conversation at the time it takes place, retain the script used, including the relevant version, and make a contemporaneous note of how consent was given. The record should also show what the individual was told and whether consent was subsequently withdrawn.

The ICO's example is particularly relevant to dealership CRM practice. It explicitly rejects keeping a tick next to a customer's name to indicate that they verbally consented. A tick is not an adequate record of what happened. The ICO contrasts it with a record containing the time and date of the conversation and the name and date or version of the script used.

That guidance concerns evidence of consent. It should not be confused with the separate obligation to record and act on a customer's objection to direct marketing. But the underlying management question is the same: can the dealership demonstrate what happened, rather than simply point to a field that someone has completed?

The ICO's Evidence Test

The ICO rejects a simple tick beside a customer's name as sufficient evidence of oral consent. A dealership needs a meaningful record of the conversation, including when it happened and the script version used.

If a customer complained, could your CRM show the date, the conversation note, and the script version used?

Consider a straightforward example.

A customer regularly receives calls from Joe in Service. During a separate conversation with Sam in Sales, the customer mentions that they are often busy at work and would prefer a text or email.

Sam updates the customer's preference.

But what exactly has Sam recorded? Is there a dated note of the customer's request? Does it identify the channel they prefer and any restrictions? Does the CRM record who made the change? Has the update reached the system Joe uses? Will Joe see it before making the next call?

If the customer has withdrawn consent, or objected to marketing calls, the distinction becomes even more important. The dealership needs to know what instruction was given and make sure it is respected. A preference update buried in a record, or a tick with no supporting history, may not give the business the evidence or operational control it needs.

The customer has already explained what they want. From their perspective, having to explain it again is a failure of the dealership's process.

And the problem can be more subtle than simply choosing between a call, text or email. A customer may be happy to receive calls at certain times but not at work or at home. A single preference field may not capture that nuance.

The dealership needs more than a place to store information. It needs a reliable, auditable way to make that information useful at the point of contact.

The handover works. What about the rest of the ownership cycle?

Many dealerships have a reasonably structured process for handing a customer from Sales to Service after a vehicle purchase.

The sales paperwork is completed, customer information is transferred and the Service department has the details it needs to begin the ownership relationship.

Where the CRM is designed to support the whole dealership, information can be entered once and made available to different departments.

That is a good foundation.

But the ownership relationship does not stand still after the handover.

Customers contact the dealership. Their circumstances change. They ask questions, make requests and update their communication preferences. Those changes need to travel through the business just as reliably as the original customer details.

In practice, this is where processes can become inconsistent.

Sales may update one system. Service may use another. Marketing may work from a separate database or campaign platform. Even when the systems can exchange information, the dealership still needs to know whether the update has transferred, whether it has been applied correctly and whether the next employee will see it.

A shared customer record is valuable. Shared understanding is what makes it work.

This is not simply a question of whether the dealership has bought the right CRM. It is a question of whether the business has designed and manages a process that works across departments.

When the target gets in the way

There is another issue that technology cannot solve on its own: the way employees are measured.

I have seen how a focus on activity can undermine the very customer relationships a dealership is trying to develop.

In one dealership environment, sales staff were required to make 25 recorded telephone calls each day. Given the size of the team, the total daily call requirement frequently exceeded the number of active prospects in the database. As a result, customers were contacted repeatedly.

Some customers would respond with words to the effect of: "I've told you before, stop calling."

The difficulty was that recording the customer's request properly could reduce the number of people available to call. The daily activity target remained. The immediate pressure was to make the calls.

This is a first-hand illustration, not a claim about any particular manufacturer or the wider motor trade. But it raises a more serious question than whether the dealership's targets are sensible.

Were those calls live direct-marketing calls? Had the numbers been screened against the Telephone Preference Service (TPS) or, where relevant, the Corporate Telephone Preference Service (CTPS)? Had the customers already objected to receiving marketing calls? And if they had, was that objection recorded and applied to the call lists?

Under the PECR rules on live marketing calls, organisations must not make unsolicited live marketing calls to numbers registered with the Telephone Preference Service (TPS) or, where relevant, the Corporate Telephone Preference Service (CTPS) unless the subscriber has specifically consented to those calls. The restriction also applies where an individual has already told the organisation they do not want its calls. Existing customer status does not, by itself, override a TPS or CTPS registration. Organisations must screen against the registers and their own do-not-call lists.

The Management Risk

A call-volume target without a counterbalancing measure for preference accuracy may inadvertently incentivise PECR breaches. The statutory maximum penalty for specified live-call breaches is £17.5m or 4% of worldwide turnover.

The 25-call example does not establish that every call made in that dealership breached PECR. Some calls may have been service-related or otherwise not direct marketing. But if live marketing calls were made to registered numbers without the required specific consent, or to customers who had already objected, the activity could amount to a PECR breach.

That is a very different management risk from an employee missing an activity target.

The ICO actively monitors complaints about direct marketing and uses them to inform its enforcement decisions. It says enforcement is likely to focus on organisations generating the most complaints. Under the enforcement framework now applying to PECR, specified breaches of the live-call rules can attract a penalty of up to £17.5 million or 4% of worldwide annual turnover, whichever is higher. That is the statutory maximum, not an indication of the penalty a particular dealership would receive. The actual outcome depends on the circumstances and the ICO's assessment.

The point for a Dealer Principal or Director is not to assume that a call-volume target creates a breach. It is to establish whether the dealership's call process can prevent one.

If employees are measured primarily on the number of calls they make, the business may unintentionally create a reason not to record information that reduces the available call list.

That is the wrong incentive.

A customer's request to stop receiving marketing calls is not an administrative inconvenience. It is an instruction the dealership needs to capture, communicate and act on. The process should make that easy, and the performance culture should support it.

A dealership cannot talk about building customer relationships while rewarding behaviour that ignores customer preferences.

Five steps to better customer communication management

The answer is not necessarily another system or a more complicated CRM configuration.

It starts with defining how the dealership manages customer communication, who is responsible and how the process is checked.

These five steps provide a practical framework.

1. Define the communication rules

Start by being clear about the different reasons the dealership contacts customers.

A service reminder, an update about an active enquiry and a promotional message are not automatically the same thing. They may have different purposes and different legal requirements.

The dealership should understand what it is communicating, why it is communicating, which channel it intends to use and which business or organisation is responsible for that communication.

It is important not to treat every customer interaction as direct marketing. Equally, a customer's willingness to receive one type of communication should not be assumed to cover every other type.

The legal position depends on the purpose, channel, context and applicable rules. Dealerships should make sure their policies and processes reflect the requirements that apply to their own activities.

2. Maintain a reliable preference record

There needs to be a dependable record of what the customer has asked for.

That record should be more useful than a simple marketing tick box. Where relevant, it should distinguish between communication channels, purposes and restrictions.

It should also show when a preference was changed, how the change was received and who recorded it.

Where consent is relied upon, the dealership should be able to demonstrate who consented, when and how they did so, what they were told at the time and whether consent was later withdrawn. An oral consent record needs a contemporaneous note and the relevant script details. A tick beside a customer's name is not enough.

Where a customer objects to direct marketing or asks for calls to stop, the dealership needs a record of that instruction and a reliable way to make sure it is applied. These are not the same legal concepts, but both require a process that works.

The record should distinguish between a preference, a contact detail and the legal basis for processing or sending a particular communication. These are related, but they are not interchangeable.

Where the dealership cannot establish the status of a preference or permission, it should not simply assume that the customer has agreed.

A reliable process must also preserve objections and withdrawals so that a customer is not accidentally added back into a campaign or contact list later.

3. Make preferences visible and actionable

Recording a preference is only useful if the people and systems responsible for contacting the customer can act on it.

That means considering every relevant part of the dealership: Sales, Service, Marketing, the CRM, DMS, email and text platforms, telephone systems and any external suppliers involved in communication.

The dealership needs to understand where preferences are held, which system is treated as the reliable record and how changes are passed between systems.

It should also be clear who can update a preference, what happens when a customer makes a request verbally and who is responsible if an update fails to reach another system.

A request made to a Service Adviser should not disappear because the Marketing platform has not been updated. A change recorded by a Sales Executive should not be overwritten by an older record elsewhere.

This is an operational process that needs ownership, training and testing.

A useful test is to follow a preference change through the dealership. Ask an employee in one department to record a customer's request, then check whether the relevant systems and employees in other departments can see and act on it before the next communication is sent.

4. Review and measure the process

Customer preferences are not something to record once and forget.

The dealership should review whether its processes are working, particularly when systems, communication purposes or departmental arrangements change.

That does not mean asking every customer to reconfirm everything on an arbitrary schedule. It means making sure the dealership has a sensible process for keeping information accurate, responding to changes and identifying problems.

Useful checks include:

• How often are customer preference records incomplete or inconsistent?
• How quickly are objections and withdrawals reflected across relevant systems?
• Are communications still being sent after a customer has asked for them to stop?
• Are there differences between the preferences recorded in Sales, Service and Marketing?
• Are complaints or repeated requests to stop contact being reviewed for patterns?
• Can the dealership demonstrate who made a change and whether it was acted on?
• Can the dealership retrieve the evidence behind a consent record, rather than just the current status displayed in the CRM?

The point is not to create another reporting exercise. It is to establish whether the process works in practice and whether the business can demonstrate that it works.

5. Align performance measures with customer preferences

This final step is a management responsibility.

If a dealership rewards call volume without considering customer preferences, it risks creating a conflict between the behaviour it measures and the customer experience it wants to deliver.

The same applies to other activity targets. A high number of emails or calls is not necessarily evidence of a healthy customer relationship.

Management should consider the quality and appropriateness of contact, whether customer requests are being respected, how effectively employees follow up and whether the business is creating useful interactions.

Employees should not feel that recording a customer's preference puts them at a disadvantage because it reduces the number of calls they can make.

The dealership's measures should support the relationship, not undermine it.

A customer complaint now requires a proper response

There is another reason for Directors to examine the quality of their customer preference records.

Since 19 June 2026, new data protection complaint-handling duties have applied to complaints received by organisations from that date. Under section 164A of the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025, an individual can complain directly to a controller if they believe their personal data has been handled in breach of the UK GDPR or relevant law enforcement provisions. The organisation must provide a way for people to make those complaints, acknowledge receipt within 30 days, make appropriate enquiries without undue delay, keep the complainant informed about progress and tell them the outcome.

The organisation must provide a way for people to make those complaints, acknowledge receipt within 30 days, make appropriate enquiries without undue delay, keep the complainant informed about progress and tell them the outcome.

Consider what happens when a customer complains that they asked the dealership to stop marketing calls but continued to receive them.

The dealership needs to investigate. Who took the original request? When was it made? Was it an objection to direct marketing, a withdrawal of consent, or a change to the preferred channel? Was it entered into the CRM? Did the update reach the dialler or campaign system? Why did the customer receive another call?

If the dealership has an auditable record, it has something to investigate.

If all it has is a tick beside the customer's name, or a preference field that was updated without a record of the conversation or the systems affected, it may struggle to establish what happened or explain what it did in response.

The new regime does not mean every complaint will result in enforcement action. Nor does it mean a CRM entry is the only evidence an organisation can use. But it does mean that a dealership needs a functioning process for receiving, investigating and responding to data protection complaints.

For a Director, this is an operational governance issue. Can the business reconstruct the history of a customer's communication preferences and demonstrate that it acted on the customer's instructions?

The ICO’s guidance on handling data protection complaints is clear that organisations must have a process for handling these complaints. It is not an optional procedure reserved for larger businesses.

The commercial and regulatory consequence

Direct marketing is an active area of ICO oversight. The regulator encourages people to report concerns, uses complaints to monitor compliance and says enforcement is likely to focus on organisations generating the most complaints.

PECR also carries meaningful financial exposure. Since the Data (Use and Access) Act 2025 changes to the enforcement framework came into force for relevant conduct on 5 February 2026, the higher maximum penalty can apply to specified breaches of the live marketing call rules. That maximum is £17.5 million or 4% of worldwide annual turnover, whichever is higher.

The maximum is not the likely outcome for an individual dealership. The ICO considers the circumstances and seriousness of the infringement. But the change makes it difficult for a management team to dismiss repeated unwanted marketing calls as a minor customer-service problem.

There is a commercial consequence too.

A dealership that repeatedly contacts customers in ways they have asked it to avoid risks damaging the relationship it is trying to build. It can create complaints, reduce engagement and make future communication less welcome.

A dealership that understands how customers prefer to be contacted has a better opportunity to make its interactions relevant and useful.

That does not mean every preference change will generate more sales or that a particular CRM process will automatically improve retention. Those outcomes need to be measured rather than assumed.

But there is a clear management question: how much value is lost when a dealership captures customer information but fails to manage the relationship consistently afterwards?

The answer will vary from one business to another. A sensible starting point is to audit the process, identify where information is lost and measure how often customer requests are not reflected across the systems used to contact them.

That gives the dealership something practical to improve.

A customer record is not the same as a customer relationship

Capturing a lead creates an opportunity.

Managing the relationship determines what happens next.

A CRM can store customer information, record preferences and provide a history of changes. But the technology is only part of the answer. The dealership still needs clear communication rules, reliable records, visible updates, consistent processes and management measures that encourage the right behaviour.

This is what owning the relationship means in practice.

It is not about collecting as much customer data as possible. It is about making appropriate use of the information the customer has shared, respecting their choices and ensuring that the whole dealership works from an accurate understanding.

The first-party lead capture process gets the relationship started. The responsibility to manage it properly begins there.

The question for every Dealer Principal and management team is simple: if a customer says they have already asked you to stop calling, can your CRM show exactly what happened, who was responsible and why another call was made?

About Graham Lower