The effects of technology on employee privacy were at the centre of a number of complaints before the Office of the Privacy Commissioner of Canada. In her deliberations, the Assistant Privacy Commissioner spelled out the acceptable purposes for the use of Global Positioning Systems (GPS), and cautioned organizations about "function creep" and the negative cumulative effects of various forms of technology on privacy.
Several employees of a telecommunications company complained to the Office when they learned that their employer was installing GPS in their work vehicles. They believed that the company was improperly collecting their personal information, namely their daily movements while on the job. The employees contended that their employer had not obtained their consent to the collection of this information, and that the company had failed to identify the reasons for the collection or state why the information was needed, how it would be used, and how long it would be retained.
The Assistant Commissioner accepted most of the company's purposes for collecting and using personal information gathered by GPS and found that implied consent was present for these purposes. Her primary concern rested with using such data in managing employees. The company agreed to develop and communicate a policy on the utilization of such data in this context, and committed to training its managers on the appropriate use of GPS. The Assistant Commissioner was pleased with this outcome and considered the complaints resolved.
The system in question allows the company to view and track the location of its vehicles in real-time and to produce reports using historical data. The company's goal is to have GPS installed in all of its installation and repair, and construction vehicles.
Noting that GPS is not new and is used in a variety of service businesses, the company indicated that in order for it remain competitive, it needed to change the way it conducts business. For this reason, it decided to install GPS in vehicles typically used by field employees. It cited the need to manage workforce productivity, ensure safety and development, and protect and manage assets as its reasons for installing the technology.
Some of the affected employees are home-based, meaning they are allowed to take the work vehicles home at the end of each shift, while others report to a compound at the start and end of their shift. The employees who are home-based are required to comply with the company's vehicle use policy, which clearly outlines the conditions under which an employee may use a company vehicle. Personal use is prohibited.
According to the company, GPS will be used to locate, dispatch and route employees to job sites. Information on the start and stop times of the vehicle and its location will be used in capacity planning, productivity analysis, and performance management, as required. The company was of the view that GPS allows it to manage field employees in a more efficient manner, based on knowledge of their current work locations and assignments. The company states that, in the past, employees were often dispatched to job sites that were not close to their physical location. This resulted in a lack of efficiency in dispatching work, and time wasted on traveling. The company planned to integrate an automated dispatch system at some point in the future. The company believed that increasing dispatch efficiency will result in enhanced service levels to customers – an ongoing requirement in an increasingly competitive environment.
Some employees affected by this decision expressed concern that GPS is being used to monitor work performance and punish employees. They believed that their employer will use GPS to show that they are not productive.
The company indicated that, for many years, the employees who operated company vehicles enjoyed a considerable degree of unsupervised freedom as their whereabouts at any given time were not available to the manager. This situation differs from that of office workers, who are often co-located with their managers. The company, however, rejected the notion that managers will spend time monitoring employees via GPS. According to the company, managers are on the road and at work sites, reviewing work and meeting with employees most of the time. GPS does not automatically notify managers if an employee is, for instance, exceeding a speed limit. In order to glean such information, a manager would have to generate a report. GPS does not have any system that notifies a manager if an employee is violating its vehicle use policy.
The company acknowledged that a manager would be inclined to use GPS to investigate or monitor situations regarding an employee when problems are reported about shoddy work, not showing up to job sites on time, or when complaints are made about the individual's driving habits. The company stated that, in some cases, GPS may help to refute allegations regarding an employee.
As for after-hour use of vehicles, the company stated that once an employee parks the vehicle at his or her residence, it has no need to monitor its activities using GPS. The company's Vehicle Use Policy clearly outlines the conditions under which an employee may use the vehicle. The company stated that it would only monitor the employee's use of the vehicle after hours if complaints were received about an employee using the vehicle for personal use or if the company had other reason to suspect that the employee was contravening the Vehicle Use Policy.
In the company's view, GPS only provides an additional tool for management to use. It stated that managers use a variety of methods to assess an employee's performance – time sheets, work completed, customer complaints. GPS is not used on its own to measure performance, but it could be used in conjunction with other methods. Managers can now review GPS to address concerns and to have factual information on which to base decisions.
According to the company, GPS will be used to determine if a vehicle has remained stationary for an inordinate amount of time and could provide an indication that the employee's safety may be at risk. As well, the information gathered by GPS may identify those employees who may require defensive/safe driver training or individual coaching based on speed statistics.
The company stated that information gathered by GPS on a vehicle's location could be used to retrieve it in the event that it is stolen, abandoned or scheduled for maintenance. According to the company, since the installation of the system, asset management of its vehicles has improved to the extent that it has been able to reduce the number of vehicles in its fleet. The company also reported that the number of kilometers driven by its vehicles has decreased and fuel consumption reduced.
The company contended that GPS does not collect employee personal information, but rather collects GPS information related to a vehicle, and not location information associated with a particular individual. Anyone viewing the system will see a vehicle identifier, not the driver's name. The company stated that it is only when the identity of a particular operator is associated with that vehicle, and then only when the vehicle is in use, that there may be personal information collected regarding the location of the driver.
As for whether the company considered the possibility of using less privacy-invasive methods to obtain the information it requires to meet its purposes, it stated that it does not regard GPS as privacy invasive. While it acknowledges that GPS enhances a manager's capability to ascertain the whereabouts of employees and to monitor certain aspects of their use of company vehicles, it contends that in an office setting, managers are usually able to keep much closer tabs on the whereabouts and behaviour of staff, which in its view, is not an invasion of privacy. The company further stated that, with GPS, field employees are only "visible" to their managers when they are in their vehicles, and even then to a much lesser extent than if they worked in the same location as the manager.
What information does GPS collect?
We attended demonstrations of GPS. The system captures vehicle start and stop times, speed, location, mileage, and off-shift parking location. This data is collected by a GPS modem located in the vehicle and is transmitted to a central application. Vehicle users cannot turn the GPS off. Once a vehicle's transmission is turned off, the modem for the GPS goes into "sleep mode" after a period of time, and only the vehicle's last known location is reported.
Certain groups within the organization have access to "real-time" (current day) information and others have access to both real-time and historical data based on specific needs. The vehicles are identified by a number and not by an employee's name. The manager is the only individual who knows the identity of the driver.
By using real-time data captured by GPS, a manager can relay information to staff. The operator of the vehicle can also use GPS to determine the location of his/her next work assignment and the location of company's facilities. The operator cannot, however, access information regarding other vehicle locations.
The company's GPS Policy (which will be considered later in this report) outlines the specific groups that have or will have access to GPS. Such access is based on their job requirements. The company can prepare a number of reports using the data collected by GPS, including reports on travel time and distance, last known location, first departure of the day and so on. The company indicated that it could not customize the reporting capability.
The company sent a memorandum to affected employees, informing them of the rationale for implementing GPS. It also held meetings with all employees who would be operating vehicles that had GPS installed in them, and provided a copy of its GPS Policy.
The policy outlines what information is being collected and the purposes for this collection. It indicates which business units within the organization will be given access to real-time information, and which ones will have access to historical data. As for safeguards, the policy states that all users will have restricted access to real-time data, historical data, or both, based on their user-specific profile. The policy indicates that the company manages all user profiles, which are set up with certain security safeguards. All employees who have access to GPS must complete the company's privacy course and be familiar with the company's ethics policy. The company also informed us that the information on the system is maintained behind firewalls.
Finally, the policy covers the disclosure and retention of information collected via GPS. Specifically, it states that personal information will not be disclosed outside of the company except if required by law or as permitted under relevant privacy legislation. As for retention, the policy states that personal information will be retained for one year unless special circumstances warrant retention for a longer period of time (for example, where a vehicle has been involved in an accident and there are claims against the company, or to satisfy Workers' Compensation Board reporting requirements).
Application: Section 2 of the Act states that personal information means information about an identifiable individual, but does not include the name, title, or business address or telephone number of an employee of an organization. Principle 4.3, 4.3.5, 4.3.6, and subsections 7(1) and 7(2) of the Act make clear that an organization must not collect or use an individual's personal information unless consent from the individual is first obtained. Principle 4.3 states that knowledge and consent are required for the collection, use, or disclosure of personal information, except where inappropriate. Principle 4.3.5 provides that, in obtaining consent, the reasonable expectations of the individual are also relevant. Principle 4.3.6 speaks to the manner in which organizations seek consent. It states that the way in which an organization seeks consent may vary, depending on the circumstances and the type of information collected. An organization should generally seek express consent when the information is likely to be considered sensitive. Implied consent would generally be appropriate when the information is less sensitive. Subsections 7(1) and 7(2) make clear that collection and use of personal information without knowledge or consent can occur only if one of the specified preconditions set out in these subsections has been met.
Principles 4.2, 4.4, and 4.5 are also relevant to collecting and using personal information with consent. Principle 4.2 states that the purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected. Principle 4.2.3 states that the identified purposes should be specified at or before the time of collection to the individual from whom the personal information is collected. Principle 4.4 states that the collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Principle 4.5 states that personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law.
Principle 4.7 states that personal information shall be protected by security safeguards appropriate to the sensitivity of the information. Principle 4.8 requires an organization to make readily available to individuals specific information about its policies and practices relating to the management of personal information.
Finally, subsection 5(3) of the Act states that an organization may collect, use, or disclose personal information only for purposes that a reasonable person would consider are appropriate in the circumstances.
The first issue to address was whether the information being collected via GPS is personal information as defined in section 2. As the information can be linked to specific employees driving the vehicles, they are identifiable even if they are not identified at all times to all users of the system.
She therefore determined that the information in question is personal information for the purposes of the Act.
The employees alleged that the company collects their personal information by way of GPS, installed in a service vehicle that they use in the course of performing their duties, without their knowledge or consent. They also contended that GPS collects more information than is necessary and that the company failed to specify to them the reasons for installing the system, its uses and retention of information collected.
As in previous cases brought before us on the issue of employee consent to some perceived privacy-invasive measure introduced by an employer, the Assistant Commissioner considered whether the purpose for the collection is appropriate in the circumstances and whether consent is present.
She first addressed the question of consent, whether the exceptions to consent apply and whether consent is present in this situation, before turning to the purposes for installing GPS.
Could the company have relied on the exceptions to consent to collect personal information outlined in section 7? In her view, the answer was no.
Admittedly, GPS could collect information for a purpose that falls under an exception set out in subsection 7(1).
For example, if an employee is thought to be breaching the employment contract, personal information could be collected via GPS for investigative purposes, where obtaining knowledge or consent would compromise the accuracy or availability of the information.
But GPS is collecting the personal information of all vehicle drivers – not just the one thought to be breaching some agreement or contravening a law. Given the nature of the technology and the fact that it is installed on all vehicles, reliance on subsection 7(1) is inappropriate.
Similarly, if the personal information was not collected for any of the purposes outlined in subsection 7(1), it cannot be used without knowledge or consent for any of the purposes provided under subsection 7(2).
Therefore, the company was obliged to obtain employee consent.
The company confirmed that its intent was to have GPS installed in all of its trucks. However, she noted, if all trucks are GPS-enabled, and the use of GPS-enabled vehicles becomes mandatory for all employees, including existing employees who accepted employment on different terms, the question of consent and choice becomes problematic.
Principle 4.3.6 allows an organization to seek consent in different ways, depending on the circumstances and type of information collected. If the information collected is sensitive, then express consent is recommended. If it is less sensitive, then implied consent may be appropriate. When considering the reliance on implied consent, Principle 4.3.5 should also be considered. This principle stresses the relevance of the individual's reasonable expectations, and presents as guidance, a scenario wherein the individual's consent can be implied for certain purposes but not for others. In short, where consent is being implied, it should only be implied for the purposes for which the employee could reasonably expect that the data would be used.
The company provided a number of purposes for installing GPS: the need to remain competitive, workforce productivity, safety, and asset protection and management. Though not explicitly stated, the Assistant Commissioner contended that another of its purposes is that of employee management.
She has previously considered the argument about the need to remain competitive and the consequences such a need has on employees in a complaint regarding the collection of biometric data.
As she had stated at the time, if a company cannot make money and remain competitive, it cannot stay in business, and employees are soon out of work. The question, however, is whether that need and the measures used to meet that need have been balanced against the privacy rights of employees. The loss of privacy must always be weighed against the benefits, and purposes for the measure must be grounded in a defensible need.
The company stated that GPS will help it remain competitive by allowing it to manage workforce productivity, to ensure safety, and to protect and manage its assets. The company also noted that its competitors use GPS.
With respect to workforce productivity, GPS will be used to dispatch, locate and route employees to job sites. As the system will be integrated with its dispatch system, it was easy to understand how GPS could improve efficiency, by minimizing the amount of time employees spend on the road getting to work sites.
The Assistant Commissioner believed it is reasonable to assume that such improvements could lead to better service to customers. Thus, the measure clearly meets a specific need and does so effectively.
She then questioned the privacy-invasiveness of the measure. The answer to that question, in her view, depended on the purpose under consideration.
There is no question that, generally speaking, there is some loss of privacy attached to the use of GPS in a vehicle that an employee uses in the course of carrying out his or her duties. Whereas before, the employee's whereabouts at any given moment were not necessarily known, with GPS they are, relatively speaking. At least what is known is the location of the vehicle the employee is using.
Within the context of using GPS for dispatch purposes, she was of the view that the loss of privacy is proportional to the benefit gained and there is no less privacy-invasive way of achieving the same end.
The Office had informed the company that we had concerns with respect to some of its proposed purposes for installing GPS. For example, the safety purpose for equipping GPS in vehicles seemed somewhat of an afterthought. We questioned whether the company had shown that employee safety is generally at risk and wondered how the company would know that a field employee's safety is at risk because the vehicle has not moved.
The company provided us with additional information and examples. It contested our view that an unmoved vehicle may not indicate that an employee's safety was at risk, and pointed to the occasional use of GPS during a recent labour dispute to support its view. The company also gave us a hypothetical scenario in which a spouse contacts it to report that the employee had not returned home or made contact as expected, and GPS is used to locate the vehicle and, it is hoped, the employee.
The company believed that the use of GPS for safety purposes is one that employees generally support. Although it could be argued, from the Office's perspective, that using GPS to identify those employees who require defensive or safe driver training or individual coaching properly belongs under the purpose of employee management, the company noted that organizations have an obligation to provide a safe workplace and, in the case of any organization that has company vehicles in use, an obligation to investigate allegations from the public about poor driving. GPS information could contribute to the safety of the employees in the workplace, as well as public safety, through appropriate actions associated with the information. It believed that requiring an employee to take a defensive driving course or otherwise improve his or her driving skills is neither punishment nor an invasion of privacy.
The company stated that GPS information has been used to refute allegations of dangerous driving, and noted a motor vehicle accident, involving a company truck and a pedestrian, who was fatally injured. The driver of the vehicle was suspected of speeding, but GPS information demonstrated that this was not the case.
Upon consideration, the Assistant Commissioner accepted the use of GPS for safety purposes. She noted that it can be, and has been, used to meet the need of ensuring the safety of employees and the public, and is reasonably effective in doing so. The loss of privacy is proportional to the benefit gained, and, she could accept that GPS is not, in this particular instance, a particularly privacy-invasive measure.
The company also cited asset management as a reason for installing GPS. Again, we questioned it on this point and indicated that we did not think the company had adequately demonstrated a pressing need in this regard. The company noted that since installing GPS, there have been at least four cases where trucks had gone missing and GPS was used to locate them.
It also noted that the use of GPS information for asset management does not involve linking that information to specific individuals. It stated that if the company used GPS to locate a stolen vehicle, it is concerned with the location of the vehicle, not the identity of the employee who normally drives it. While the company would like to be able to use GPS to link the vehicle to the thief, GPS does not provide that capability. It is therefore the case, according to the company, that the use of GPS to locate a stolen vehicle does not involve any personal information.
The Assistant Commissioner noted, however, that in the case of an employee using a vehicle, the driver is "identifiable" and GPS is therefore collecting personal information.
She pointed out to the company that employees already provide odometer readings and presumably inform maintenance employees of any problems regarding the operation of the vehicle, and that a less privacy-invasive measure already existed to meet this particular need. Less time wasted in dispatch might translate into savings in terms of fuel and vehicle maintenance, but we noted that this point was already covered as an incidental benefit of an improved dispatch process.
The company pointed out that if it uses GPS to obtain the odometer readings for vehicle maintenance purposes, it is concerned with how far the vehicles have been driven, not with who was driving them. It went on to state that using GPS information for the purpose of asset management does not involve the linking of that information to specific employees and therefore does not infringe upon the privacy of those employees in any meaningful way.
While the Assistant Commissioner did not agree that such information is not linked to specific employees, she contended that GPS does not link such information to specific employees to any greater degree than the current system does, in which a specific employee reports the odometer readings of the particular vehicle he or she is driving.
She was therefore persuaded that using GPS for asset management is not more privacy invasive than the current method. She also agreed that GPS would be, and is, very effective in locating a stolen vehicle.
On the whole, she was satisfied that asset protection and management is an appropriate purpose under subsection 5(3) and one for which implied consent is present.
The company stated that information collected on start and stop times, speed, and location will be used in capacity planning, productivity analysis, and performance management, as required. It was this last point that is probably of most concern to some employees. They feared that such information will be used to monitor their performance and to discipline them.
In its representations, some aspects of the arguments the company put forward, under the headings "workforce productivity" and "safety" seemed to speak to a fourth purpose for which it intends to use GPS: employee management.
For instance, the company claimed that part of "workforce productivity" will include "performance management" purposes. Similarly, under "safety," the company argued that information gathered by GPS may identify those employees who require defensive/safety driver training or individual coaching based on speed statistics. This strongly suggested to the Assistant Commissioner that GPS data will be used for employee management.
She acknowledged that performance measurement of some kind is part of the employment context. A manager has an obligation to ensure that employees are performing their duties and a certain amount of employee personal information forms part of performance management. On the one hand, employees rightly have some expectation of privacy in the workplace. At the same time, employers have legitimate requirements for a certain amount of employee personal information. She also acknowledged the company's responsibility to ensure that its employees who use its vehicles are driving safely, for their own sake and for the public's.
The question then remained how privacy invasive is GPS when considered within the context of employee management? The company pointed out that in an office situation, the manager can see the employees at work, which it argues could be considered more privacy invasive than GPS.
The Assistant Commissioner agreed that GPS, in and of itself, is not highly privacy-invasive, because it only tells "part of the story." In other words, if, for example, a vehicle is parked and the employee is at lunch, GPS does not tell the employer exactly where the employee is. It may indicate how long an employee is at lunch, but then again it may not. It was this very "imprecision," however, that concerned this Office.
We informed the company that we were troubled by the potential to evaluate the performance of an individual based on inferences drawn from GPS data. We believed that using GPS for such purposes is no longer so much about tracking the location of company vehicles as it is about measuring the performance of an individual based on assumptions made from GPS data. In our view, such a use would shift the balance significantly towards the "loss of privacy" end of the spectrum.
While using GPS to track a vehicle is not overly privacy invasive, routinely evaluating worker performance based on assumptions draw from GPS information impinges on individual privacy.
While the Assistant Commissioner could accept its use in certain situations, which are defined and communicated to employees beforehand, GPS data should not be used as a matter of course in employee management situations. Should the company contemplate using GPS for such employee management purposes, we asked that it be clear to employees about such purposes and establish a policy outlining an appropriate process of warnings and progressive monitoring. We asked that the company ensure that only through that process should GPS data be collected and used for employee management purposes.
The company provided us with a copy of a policy on GPS data utilization for performance management. This document spells out the situations in which the company will use GPS data for performance management. These include investigating a complaint from a member of the public; investigating concerns raised internally; and addressing productivity issues.
Under productivity issues, it noted that productivity is measured in various ways (other than by GPS) and reported and reviewed on a regular basis. If an individual is found to have below-standard metrics, the manager is expected to address the issue. According to the policy, in exceptional cases, further investigation may be required before arriving at any conclusions, and GPS data may provide information and assist in addressing a productivity issue.
It also noted that GPS will be used to provide high-level vehicle utlilization reporting at senior levels to allow comparison and analysis of productivity. GPS information may be used by the manager to address productivity concerns with specific team members as required.
The company also committed to train all managers to ensure that they use GPS appropriately and not for continual monitoring of individuals' locations.
On the basis of this, the Assistant Commissioner was satisfied that the company's use of GPS data was for an appropriate purpose, as per subsection 5(3), and that this use will be clearly explained to employees beforehand, as required by Principle 4.8.
As for identifying the reasons for the system, its uses, and retention, she was satisfied that the company did highlight this information to its employees – albeit after the installation of the equipment had begun. It conducted meetings with affected individuals and developed a GPS policy, which it distributed. While some complaints were filed with this Office shortly before the company's communications efforts began, the company did undertake to inform its employees about the system and how it will be used.
She did remind the company that, in future, it should provide appropriate information to employees prior to the roll-out of a particular program, not afterward, in order to be in compliance with Principle 4.2.3.
To conclude, the Assistant Commissioner found the use of GPS to improve the dispatch process to be compelling and an acceptable purpose under subsection 5(3). She was satisfied that implied consent is present and appropriate for such a purpose as the collection meets the reasonable expectations of the individual and, for this purpose, is not overly privacy invasive. Likewise, she was persuaded by the need to use such a system for safety and asset management, and would agree that implied consent is present and appropriate for such a purpose. As for employee management, given that the company took measures to limit the use of GPS for such a purpose, would be informing its employees accordingly, and was implementing training to ensure that managers are aware of the appropriate use of the technology, she was satisfied that use of GPS for such a purpose is appropriate in certain limited, exceptional, and defined circumstances, as per subsection 5(3) and Principle 4.8, and that implied consent is present.
Accordingly, the Assistant Commissioner concluded that the complaints were resolved.
With respect to limiting the collection and use of information, the Assistant Commissioner noted that, generally speaking, "function creep" is not acceptable. In other words, the purposes and uses of a particular technology should be precisely specified, and that technology should be restricted to its intended purposes.
She stated that, organizations, in their quest to be proactive, often resort to technology in anticipation of problems or as a means of maintaining competitiveness. In addition to the problems that arise from function creep, the individual's rights are slowly eroded by the cumulative effects of measures intended to meet the bottom line. She cautioned all organizations subject to the Act that the effects on the dignity of employees of all of the measures in place – taken as a whole, not just as one measure alone – must be considered in balancing the rights of the individual to privacy and the needs of organizations to collect, use or disclose personal information for appropriate purposes. She was pleased that the company at the centre of these complaints had taken steps to recognize the dignity of its employees by instituting the policy on the use of GPS with respect to employee management. Such a measure, she noted, helps maintain that balance in the workplace.


Reach out to the family at home with this lovely array of classic blooms artistically arranged in a beautifully woven basket. They'll be deeply touched.
The impressive bouquet includes red roses, white alstroemeria and red carnations, accented with assorted greenery. Delivered in a 6" natural pot basket.


text:
About Martin Roll
Thought-Leadership
Facilitating & Mentoring
Brand Glossary
Charles & Keith – A Truly Successful Asian Global Fast Fashion Retail Brand
Founded in Singapore in 1996, Charles & Keith is a fast-fashion retailer of high-quality, stylish footwear and accessories including bags, eyewear and costume jewellery catered to modern Asian women. The brand is recognised for its curated collections of relevant fashion designs available at affordable and accessible price points.
A lifestyle brand that embraces a culture of innovation, the brand has established a presence in prominent fashion cities such as Seoul, Shanghai and Dubai. The brand has also begun its foray into locations such as Macau's The Venetian and pop-up stores in Galeries Lafayette in Paris in the past three years. In the last quarter of 2018, it launched an e-commerce hub in the UK as its first push into the European market. Today, Charles & Keith continues to inspire and excite with its experimental and unparalleled designs.
Within a mere 22 years of inception, it is operating more than 600 stores with over 5,000 employees across Asia-Pacific, the Middle East, Europe, Latin America and Africa, and is today earning annual revenues of more than USD 300 million.
How did Charles & Keith manage to grow its company operations and global brand so quickly? This article serves to unravel this amazing and unusual journey.
Charles & Keith brand history
Starting out as a ladies footwear store in Singapore's Amara Shopping Centre in 1996, brothers Charles and Keith Wong ran the store just like any other shoe store – procuring China- and Malaysia-made shoes from the same wholesalers as their competitors and then retailing them in-store. However, just after a few months of running the business, they quickly observed that while selling wholesale shoes provided a cost advantage, the lack of uniqueness meant limited growth.
This made them realise the potential of designing their own in-house products and creating a brand that consumers could identify with – leading to the creation of the Charles & Keith brand.
The brothers opted to design their own shoes while selling them at affordable prices. Keith was responsible for designing the shoes while Charles managed sales. The brothers also made the business cost-efficient by buying directly from manufacturers instead of wholesalers. To retain the exclusivity of their products, the brothers ensured that these manufacturers would not produce and sell their shoes to other retailers. By 2000 and within just 4 years, all its products were designed in-house. As the business grew, the company cut out the middleman and began working directly with production factories.
The brand also strategically planned and rapidly executed its global expansion strategy. In 1998, just 2 years after its store opening, it began its international operations by opening its first overseas store in Indonesia. In 2001, it opened its second overseas outlet in the Philippines. In 2004, Charles & Keith started expanding into the Middle East: first with Dubai, followed by Bahrain, Oman and Saudi Arabia. By 2008, Charles & Keith was already gaining revenue of USD 97 million, and this was expected to grow by 30% for the next 5 years before its acquisition.
The company's big break-through came in 2011. Amidst offerings from various private equity funds and high-net worth investors, the brand sold a 20% stake in the company for more than USD 23.5 million to L Capital Asia (later change name to L Catterton Asia), a private equity group owned primarily by French luxury conglomerate LVMH Group and Groupe Arnault, the private holding company of Bernard Arnault, LVMH's chairman and CEO. Founded in 2001, L Catterton Asia is currently a USD 70 billion luxury conglomerate managing brands such as Christian Dior and Bulgari, with a recent leadership mandate to invest in "affordable luxury" below the price points of LVMH's brands. The deal valued Charles & Keith at almost USD 158 million. When this sale was completed, the world has started to take notice of Charles & Keith.
LVMH has helped the company expand into the vast Chinese market where it now runs 95 outlets with plans to add 30 to 50 stores a year for the next few years. With more than 500 stores across Asia-Pacific, Europe and the Middle East today, Charles & Keith is looking to conquer China, the United States and Western Europe to become a global aspirational fashion brand by utilizing the expertise of L Catterton Asia and their sponsors.
Today, it is well-known among fashion-conscious shoppers for their distinctive designs and quick in-season turnaround that offers 20 – 30 new designs in stores every week. The brand produces an average of 1,000 new designs each year – over 750 footwear designs and over 300 bags and accessories designs. Charles & Keith has expanded its product range to also include bag, belts, shades, tech accessories and bracelets, evolving from a footwear brand to a lifestyle brand. The group has also created Pedro, a line of men's and women's footwear and accessories. Today, Pedro operates 100 stores across Asia Pacific, Middle East and China.
The company has received several awards including the Singapore Retailers Association's Excellent Service Award 2002 and the Enterprise Award at the Singapore Business Awards 2008.
The brand founder and Managing Director of the brand, Charles Wong has also been recognised with numerous honors, including the ASEAN Youth Award 2005 by the National Youth Council, Entrepreneur of the Year 2008 by the Rotary Club and the Association of Small and Medium Enterprises, Entrepreneurship Award 2012 by the Spirit of Enterprise, and the Young Achiever Award 2013 by the Business China.
Brand architecture
Charles & Keith caters apparel to mainly 2 customer segments: Women and Kids. The brand architecture is divided into four sub-brands separated by style but housed under the same Charles & Keith store, within which it showcases its collections:
Shoes: The brand's shoe collection includes a wide selection of heels, flats, boots, espadrilles, loafers, mules, pumps, sandals, sneakers and wedges. The quick in-season turnaround ensures that it captures as much of the market (women between ages of 16-55) as possible.
Bags: The brand offers a variety of bags including cardholders, trendy backpacks, crossbody bags, clutches, handbags, shoulder and tote bags, satchel bags, wristlets and wallets. The designs of its bags are edgy and minimalistic in nature and feature bold colours like black, white, nude, grey, bright orange, cobalt blue and forest green.
Accessories: This range of products was added on to the collection later on but features unique designs of bag straps, belts, earrings, necklaces, rings, sunglasses, technology accessories (e.g. mobile phone cases) and key chains.
Kids: Found just within the past 3 years, the brand has launched this line to target babies, toddlers and young girls. This collection includes shoes and bags which are inspired by runway trends yet still being appealingly age-appropriate. The recent Disney Tsum Tsum collection which launched in 2017 proved to be a hit with both young girls and their mothers.
Brand strategy of Charles & Keith
According to its brand profile on the Charles & Keith website, the brand's purpose encapsulates a clear message: to transform the latest trends into accessible fashion. Its vision is to be the most admired fashion-forward company and its mission is to offer high quality products and services with a commitment to perfection. True to its core, the brand has indeed come a long way and is well known for its trendy yet affordable designs that are fresh off the runway.
In addition, affordability has always and continues to be a commitment from the brand to its customers. As such, Charles & Keith positions itself in the "affordable luxury" market, where trend-conscious, low-, medium- to high-income consumers are able to pay for the brand's products, often purchasing products in large quantities and multiple styles. In addition, the brand is one of the first few global fashion brands that managed to fill the gap in the market by focusing on shoes and bags.
Charles & Keith provides an unrivaled physical shopping experience by curating a pleasant in-store sensory experience, inculcating a positive culture of world-class fashion design and innovation, and by impeccably managing its supply chain.
Some of the key brand success factors for Charles & Keith include the following:
Delivery system supporting a clear brand promise: Two of the biggest challenges for any brand is to define a clear brand promise and to consistently deliver effectively on its brand promise across all touch points of the customer experience journey. Successful brands are those that create supportive organizational and operational structures that facilitate the implementation of strategies to deliver on the brand promise. On one hand, Charles & Keith has managed to successfully define a clear brand promise for itself to provide high quality, stylish fashion at affordable prices. On the other hand, it has also created a strong delivery system to deliver on this brand promise.
The company's product planning, design, manufacturing and distribution capabilities are all in-house, which means that it is able to stay close to customer needs based on what customers are buying in their stores. This allows it to save costs on overproduction or unnecessary overheads, driving affordability and serving its brand promise well. New designs can reach stores within a matter of weeks and current designs can be replenished within a matter of days.
Despite its soaring success, Charles & Keith has always stuck to its brand promise of affordability. A quick look on its online stores reveal that shoes sold under the Charles & Keith label range from USD 20-80 a pair, while the more upmarket Pedro label retails between USD 30-100.
Culture of design: Co-founder Keith Wong currently leads a design team of 70 designers – mainly Singaporeans, Malaysians and Chinese – who churn out almost one shoe or accessory design a day for Pedro and more than 1,000 new shoe and accessory designs annually for Charles & Keith. The designers are in China, close to where most of the shoes are made.
The brand places a huge focus on maintaining the high standards of its designers, ensuring that they are well-trained and well-informed of consumers' changing demands and tastes. This is demonstrated through the fact that the company spends 3% of its annual revenues on training its designers through sending them regularly to Europe and the U.S. to attend fashion shows and conduct market research.
The company also ensures that its staff are well in touch with the market tastes and preferences – the median age of Charles & Keith's staff is 27. The brand also ensures that it hires local staff in its overseas markets, in order to better understand the overseas markets.
Digital e-commerce strategy: In 2004 when e-commerce was still new, Charles & Keith was the pioneer and first retail company in Singapore to launch an e-commerce store. Being the first mover in the e-commerce market was a huge advantage for the brand, as it started to reap revenues from online as a fast-growing customer segment, including tapping into other countries which the brand did not have a retail presence in. Demonstrating its commitment to e-commerce, it closed all its stores in Japan in 2016 to focus on its e-commerce strategy.
Currently, Charles & Keith ships to more than 70 different countries worldwide. A dedicated e-commerce team manages the entire operation to make sure that products are packaged neatly and shipped out efficiently. The user-friendly website allows shoppers to easily filter their search by sizes, colours, materials and prices, finding the style they want quickly. Shoppers can also view products from different angles and its zooming feature allows a close-up look at the details of each item, closely mimicking the physical store experience.
Currently, Charles & Keith's online store only caters to certain markets. To fully capture the online segment, it is important for Charles & Keith to ensure that its online retail shopping experience can cater to all countries around the world.
Supply chain management: Merely having a large number of styles is not enough for a fashion brand to be successful. Equally important is for the brand to be able to quickly bring its products from the drawing board to its stores to reach its consumers. Charles & Keith has mastered this capability as its stores never fail to be restocked weekly with its new designs. In addition, the brand relies on its ability to control its supply chain to ensure that their manufacturers would continue to produce shoes exclusively for the company, hence reducing the risk of imitation or counterfeit products.
Sustainability at the core of operations: Sustainability has been a hot topic in business for the last decade and is now quickly becoming a must-have hygiene factor for companies that want to resonate with and win the loyalty of its global customers. For Charles & Keith, this means having a commitment to humanity, people and the environment.
Humanitarian Causes: Through the years, Charles & Keith has collaborated with international organizations such as United Nations Entity for Gender Equality (UNWOMEN) and Breast Cancer Foundation in support of various philanthropic causes. For example, for International Women's Day 2018, in line with the theme 'Time Is Now', Charles & Keith launched an exclusive collection that features a light grey quilted crossbody bag and light grey quilted wallet to support the peaceful but urgent press for female empowerment. 20% of the proceeds from the sale of these items went to the Singapore Committee for UN Women to fund the organization's programs and initiatives
Human Excellence: In June 2017, in line with World Environment Day, Charles & Keith collaborated with a fair-trade business, Freeset to create an online exclusive capsule collection, Floral Days. Using 100% organic cotton, every product features a tote bag, pouch and key ring illustrated with blossoming flowers, symbolizing the women of Freeset's newfound liberty and promise of a new beginning in life. With this campaign, the brand aims to increase the voice and visibility of marginalized women, and support their choice to learn valuable skillsets in a fair and healthy working environment
Environmental Initiatives: Since 2010, the brand has initiated the use of Forest Stewardship Council (FSC) certified paper to reduce its carbon footprint. It also participates in various environmental initiatives including Earth Hour.
Made in Singapore: As one of the local brands from Singapore to quickly launch itself on the global fashion scene, Charles & Keith also believes strongly in giving back to the community and supporting local talent. The brand is one of the few local firms in Singapore to award scholarships to candidates under IE Singapore's Young Talent Programme, to help groom local talents for global roles. Charles Wong had won the ASEAN Youth Award 2005 for his contributions in promoting youth employability in 2006. In addition, Charles & Keith also provides support to students, young designers and young graduates through internships, product sponsorships and career opportunities.
Charles & Keith brand communication strategy
Until the digital age started to gain rapid global momentum, Charles & Keith has traditionally relied on printed flyers and TV commercials as its primary means of advertising. Today, it uses a plethora of methods to communicate its brand position and ideals, including its unique in-store environment and store locations, product spreads, brand campaigns and digital and social media marketing.
In-store environments and store locations: One of Charles & Keith's main brand communication methods is its in-store environment. Through its minimalist colours, clean lines, marbled walls and flooring, wide aisles, giant mirrors, bright lights and appealing product presentation creating a comfortable and welcoming shopping experience, Charles & Keith communicates its design philosophy of chic and bold.
The brand is also famous for using scent marketing – all of its stores use the same perfume to create the same sensory shopping experience no matter which Charles & Keith store a customer may step into. It also leverages on a professionally curated sound ambience in stores, elevating the shopping experience. New launches are always placed on display at the front of the stores, showcasing its quick in-season turnaround of styles. Shoes on sale are also on display on another rack, communicating its affordability to the masses.
Compared with other fast fashion competitors whose stores are jam-packed with shoes and do not have a specific focus on customer service, Charles & Keith's in-store experience stands out and contributes heavily to effective communication of its brand philosophy.
Importantly, Charles & Keith also invests in prominent and accessible store locations. Its stores are always found in major shopping districts in stand-out locations that are easily accessible. For example, in Singapore, retail outlets can be found in the iconic ION Orchard and The Shoppes At Marina Bay Sands shopping malls, but also in the heartland malls.
Advertising and events: From the start, the brand had adopted a very niche marketing strategy – all their fashion photo spreads and advertising materials in print and online only featured European models donning the brand's products. This has allowed Charles & Keith to successfully build a couture, high-fashion image and perception amongst its following to its advantage as a fashion brand selling trendy products.
Events is another channel through which Charles & Keith communicates its brand appeal. Its first large scale event was in 2013 when it staged a fashion show to launch their Fall 2013 Collection at Ngee Ann City Civic Plaza, Singapore. The star-studded event was graced by Singaporean A-list celebrities such as Fann Wong and Zoe Tay, and international celebrities including the first Asian Victoria's Secret Model Liu Wen and K-Pop sensations Korean-American actor Daniel Henney and SNSD Girls' Generation. The brand even flew in famous fashion bloggers Bryan Boy and Han Huo Huo business class with Singapore Airlines just for this event. These events, although costly, are a wise marketing investment as it has catapulted Charles & Keith onto the international fashion runway.
In September 2016, British actress Maisie Williams was seen carrying 2 Charles & Keith wristlets to the Emmy Awards – a black Evening Wristlet bag on the red carpet and a white Prism Minaudiere clutch to the HBO after party. Within a day, both designs were sold out on the brand's online store. Consequently, Charles & Keith is also increasingly exploring events as a way to feature and communicate its products.
Brand campaigns: Charles & Keith launches a new brand campaign every season, similar to how luxury couture brands launch their high fashion collections. This helps to solidify the perception of Charles & Keith as a high-quality fashion brand fully in sync with couture runway trends. Since the start, each brand campaign is launched with a series of high quality, glossy-magazine-worthy photos and a video published on the brand's YouTube channel. In the 2000s, the brand hired celebrity fashion photography duo Chuando & Frey to shoot their ad campaigns, immediately elevating perceptions of the brand. The content is typically inspired by social issues relevant to its target consumer.
For example, in its Spring/Summer 2018 brand campaign, the brand launched a video titled Garden State, examining the increasingly complex role of the mass media in society, challenging society's growing dependence and addiction to it, while emphasizing the collective desire to return to Mother Nature and immerse ourselves in her simple delights. The video features models staring intently at blank TV screens in an avant-garde style, before the TV screens turn on to reveal models in a grassland and a lily pond, wearing fashion pieces from the collection.
To support its brand campaigns, the brand also manages a blog "Charles & Keith Says" which is linked to its website. The blog content features style write-ups on fashion bloggers wearing Charles & Keith outfits, fashion and trend advices from fashion influencers, write-ups on the brand's collections, and features of Charles & Keith products in other media channels. The content has a strong focus on communicating via visuals and less text, again contributing to the high fashion and luxury perception.
Social media & digital: Charles & Keith was one of the forerunners of the social media adoption movement as it was one of the first fashion brands to start advertising on Facebook. The brand has a strong social media following, with more than 1.4 million likes and followers on Facebook, more than 782k followers on Instagram, and a subscription of over 2.9k followers on its YouTube channel as at December 2018. The Charles & Keith Instagram feed is sartorially curated, projecting an extremely fashion-forward image. Square-cropped pictures of Charles & Keith merchandise clad on models walking the busy streets of Manhattan or relaxing in a Parisian sidewalk cafe are not uncommon sights. Pictures of fashionistas and influencers flaunting their Charles & Keith shoes and accessories on social media are also popular, with the hashtag #CharlesKeith.
However, having a large following is just the first step toward an effective marketing communications strategy. The team understands this, as evident from its efforts to engage with its followers over social media. For example, a picture of fashion icon Rumi Neely garnered about 1.7k likes, with fans raving over the shoes she wore. Charles & Keith promptly responded to eager fans, letting them know that Rumi was wearing the Cage Stilettos from the latest collection, available in black and burgundy.
Other social media engagement methods that the brand communications team uses are its features of influencers wearing Charles & Keith products on its blog and social media through the hashtag #ImWithCharlesKeith. It also encourages its followers to upload pictures of themselves wearing Charles & Keith through the hashtag #CharlesKeithCurates, further building hype and excitement towards its brand.
Future challenges for Charles & Keith
Despite its huge success so far, Charles & Keith faces its own global business and brand challenges. In the follow are some of the strategic business considerations Charles & Keith needs to have in mind in its strive for global business growth:
Intense competition in the retail market: The fashion retail market today is more competitive than ever before. Today, the shoes and bags industry are dominated by large fashion players all the way down to individual indie fashion stores. For Charles & Keith specifically, the main direct competitors include Aldo, Nine West and Steve Madden which targets the same psychographic segment of customers:
Aldo: A brand for the trend-conscious, self-aware shopper with a chic and bold fashion sense between ages 16-45. The brand stays updated with the latest trends from the fashion capitals around the world with an emphasis on quality and craftsmanship
Nine West: A sub-brand of the American fashion designer brand, The Jones Group and is positioned as a trusted fashion advisor in every category from shoes to accessories, translating runway looks to everyday real-life fashion. It is well known for its 'Hot 9' selection of "must-haves" of the current season
Steve Madden: An American designer label with a vision to give young, fashion forward women a unique way to express their individuality through style. The brand is positioned to embrace fashion while retaining the unconventional independence that originally defined the brand, and offers shoes, bags and accessories
Despite this stiff competition from its competitors, the brand's core target market – women – still serves as an opportunity for the brand. Regardless of an economic downturn, there is still some degree of purchasing power for shoes and fashion accessories, due to the nature of the product category as a necessity. In order to stay ahead of the curve, it will be important for Charles & Keith to define a true purpose and brand promise for its brand and work tirelessly towards delivering on that brand promise.
Differentiation through innovation: As Peter Drucker said, innovation and marketing are the only two functions of any organization. Innovation refers to a continuous, organization wide process that allows companies to simultaneously make incremental improvements to existing products and/or services, while investing in the development of breakthrough and significant inventions. Given such a nature of innovation, it is a fundamental building block of iconic brands. Leading brands design their corporate strategies with an inherent strategic element encompassing innovation.
Brand strategies that are envisioned with innovation as one of the core elements affords the brand a long-lasting competitive advantage that would even withstand system level shocks such as recession.
For Charles & Keith, innovation should not just be limited to bringing new fashion experiences, but should be extended to encompass many internal functions such as innovation in channel communication (with customers and other stakeholders), innovation in organizational cultures (work practices and internal brand practices) and innovation in implementing cost-cutting and efficiency-enhancing strategies. Such an inclusive notion of innovation provides strong support to a brand's competitive advantage. Most of the above-mentioned are not new processes for Charles & Keith to administer but there is a need for consistent implementation across its global operations.
Charles & Keith is well known for its culture of innovation that permeates throughout the organization. Apart from innovation in its product designs, innovation is also reflected in its business strategies and operations. In 2004, Charles & Keith was the first local retail company in Singapore to launch an e-commerce site. This allowed the company to sell its products to countries where it did not have retail presence.
The brand was also the first retail company to do advertising on Facebook. Charles & Keith needs to continue to identify innovation opportunities like this to consistently wow its consumers moving forward.
Focus more on quality, less on price: For Charles & Keith to effectively compete and maintain its strategic advantage and differentiation, the focus needs to shift away from price but towards quality. Even though the brand enjoys high levels of appeal, evident by the serpentine queues outside its stores when it launches in new markets, there is still a need for Charles & Keith to start investing in building a strong brand positioning on the quality of its fashion products and aggressively communicate this. It has successfully done this with its sister brand Pedro, which is highly known for encapsulating modern luxury and contemporary style through elegant and sophisticated product designs.
Country of origin: Most of the well-known brands in the world have a favorable country to validate and enhance their brand identity. The country of origin effect is very influential and important for building strong brand equity. Singapore is positively viewed in the global arena for its political stability, infrastructure, talented workforce, extensive network of Free Trade Agreements, and is known for being a service-oriented, efficient, clean and caring country. Charles & Keith's regional and global success has indirectly had a positive effect on the "Made in Singapore" brand. Choosing to further emphasize its "Made in Singapore" trait may benefit Charles & Keith and help to further boost its brand image and equity.
This could be done through partnering with International Enterprise Singapore (IE Singapore), a government institution tasked with internationalizing domestic businesses. Charles & Keith could identify more ways to leverage on the national branding programs spearheaded by IE Singapore, hence helping to raise the profile of its brand overseas.
Global expansion: Global expansion has always been an important business growth strategy for Charles & Keith. Back in 1998, it had begun global expansions of its operations by venturing into Indonesia. By 2015, they had 40 stores across the island. In 2001, Charles & Keith opened an international venture in the Philippines, where by 2015, they had more than 30 stores. They debuted in the Middle East in 2004 with a store in Dubai, and another in Saudi Arabia in 2005. In 2011, the brand had over 230 stores across the world mostly based in the Middle East and Asia. By 2013, Charles & Keith had grown to over 400 stores worldwide, including Africa and Japan, where they opened a flagship store in Harajuku, Tokyo and also other shops in Yokohama and Osaka. In 2015, the brand expanded further into Cambodia, Panama and the Dominican Republic.
Moving forward, the brand has plans to venture further in China, the US Europe and Russia. For Charles & Keith to successfully penetrate these global markets, it needs to take into account localization as part of its strategy. For example, its footwear collection primarily targets Asian sizing, which means that the shoes come in smaller sizes and narrower cuts.
To capture a share of the Western markets like the U.S. and Europe, it is imperative for the brand to include wider cuts and also include seasonal collections and various materials for cities with certain weather requirements.
Succession planning: Although both founders of the brand, Charles and Keith Wong are still young, it is important for the brand to start thinking about their strategy in succession planning in the decades to come. Long-term success of family firms is not a given, and it is definitely not an easy task. There are many complexities involved when ownership, management and family roles tend to overlap, Given the ambitious expansion plans of the brand, the owners need to consider if their next generation family members are the best suited to own the business and take it forward, compared to external investors or new owners like private equity companies.
A different ownership set-up may sometimes help the business as the family gets access to capital, valuable know-how, global market access and a diversity of leadership views.
Conclusion: Charles & Keith has demonstrated that Asian brands can go global
Charles & Keith is definitely a classic example of how an Asian brand can become successful in the region and globally, by disassociating itself with low cost and instead adhering to brand building principles and focusing on carving a unique brand identity. It is indeed impressive how Charles & Keith has managed to transform from a single shoe store in the Singapore heartlands to a global fast fashion company located in several fashion cities.
One of the secrets behind its success is its strong delivery system supporting a clear brand promise, and its relentless commitment to innovation. By clearly defining its brand promise to provide high quality, stylish and affordable fashion at affordable prices, and by running a robust and efficient supply chain to produce its footwear, bags and accessories, the brand has created an environment where it continually exceeds customers' expectations. Building and sustaining a brand that is relevant and one that resonates with the customer base is one of the most difficult aspects of building a strong brand today. Charles & Keith, with its presence in diverse markets, has managed to hold up well to this challenge of building a relevant and resonant brand personality.
There are indeed many opportunities that Charles & Keith can leverage in order to reach its goal of becoming the most admired fashion company. In particular, the company plans to focus on growing the brand internationally and expanding online sales. With its commitment to innovation, culture of design and proven consistent financial growth in the past 22 years, it is no doubt that the Singaporean fast fashion retail brand is on the right path to global success.
The next branding leap for the brand would be to venture into the luxury space. One of the true marks of a successful luxury brand is to have consumers buy into the entire brand experience and not just the product itself. With the sale of a 20% stake to luxury behemoth LVMH and the opportunity to tap into LVMH's vast experience and knowledge in luxury, it will be exciting to see how Charles & Keith would plan its foray into luxury in the next few years.
Insights links
About the author: Martin Roll – Business & Brand Strategist
Read about ZARA: The Secret of Zara's Success: A Culture of Customer Co-creation
Read about Forever 21: Forever 21 – Fast Fashion Retail Brand With An Edge
Read about Uniqlo: Uniqlo – The Strategy Behind The Global Japanese Fast Fashion Brand
Read about Asian brand building: 10 Steps To Build A Successful Asian Brand
Read more: Insights & Articles
Branding, Consumers, Country of Origin, Family Business, Fashion, Iconic Brand, Retail
Uniqlo: The Strategy Behind The Global Japanese Fast Fashion Retail Brand
Forever 21 – Fast Fashion Retail Brand With An Edge
10 Steps To Build A Successful Asian Brand
Brand Guardrails – How To Keep Successful Brands On Track
Net-A-Porter – Revolutionizing Global Fashion Retail
Asian Brand Strategy provides key insights and knowledge about the rising Asian brands incl. model frameworks, brand cases and checklists on Asian branding. Download sample chapter.
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Home > > TUI plans to take on local online booking players with $1 billion revenue goal
TUI plans to take on local online booking players with $1 billion revenue goal
05/17/2019| 9:46:34 AM| Skift 中文
In the new markets, TUI will ape online travel agencies, selling dynamic packages with the aim of getting to one million customers and $1.1 billion in revenue by 2022.
While it might not be having the easiest time in its core European markets at the moment, TUI has still got its eyes on global expansion.
The travel giant flagged Wednesday the possibility of entering new markets in 2017 and the plans are still on track.
To execute its strategy, TUI will behave differently. In its current core markets — the United Kingdom, Germany, and others — it has 21 million customers, who purchase a pre-packaged vacation product and fly to their destination on TUI aircraft.
In the new markets, TUI will ape online travel agencies, selling dynamic packages with the aim of getting to one million customers and $1.1 billion (€1 billion) in revenue by 2022. Markets TUI is targeting include China, Brazil, and India, all of which already have strong local online travel players including Ctrip, Despegar, and MakeMyTrip.
Despite these strong incumbents, TUI CEO Fritz Joussen is relaxed about the competition and if anything, he believes the original target of one million was too "conservative".
So far the company is up to 200,000 passengers per year, double the amount it had in 2018.
"We have asymmetric conditions because the OTAs need to make money by being OTAs right, and we make money by selling hotels. So…we can put some of the traffic into our own hotels and if we just got 10 percent of our traffic in our hotels the platform is paying for itself," Joussen said on a media call after the release of the company's first-half results on Wednesday.
He added: "OTAs need to earn money with the platform and the sales…we can use vertical integration." The idea being for TUI to use these new markets to top up any space it might have in its own-brand hotels, using a relatively cheap and risk-free model.
To facilitate the expansion TUI will use what it calls a new GDN-OTA (Global Distribution Network-Online Travel Agency) platform.
TUI's explanation of its strategy comes at a challenging time for the European travel industry with competition in key markets such as Spain, Brexit and the after effects of last year's summer heatwave.
All of these factors put pressure on TUI's first-half performance. The Hanover-based company made a first-half loss of $426 million (€381 million), up 47.5 percent on the prior year. Slipping further into the red isn't necessarily a problem for such a seasonal business, as European travel companies like TUI make most of their money when people actually go away on vacation over the summer months.
Still it has been a pretty tough year and TUI also has had to contend with the 737 Max aircraft grounding, which has so far cost it $5.6 million (€5 million).
At the moment TUI assumes the grounding will cause a one-off impact to earnings of $224 million (€200 million) but this is based on the Max returning to service by mid July at the latest – something that is not guaranteed.
TAGS: TUI | Thomas Cook
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Jackpot City is a part of Digimedia Limited business registered in Malta. The company has acquired the license through LGC Agency, a governmental organisation focusing on gambling legalisation in the country. The casino trustworthiness is confirmed by the fact it holds eCOGRA certification, an international non-profit organisation ensuring the business is conducted fairly and transparently, and sticks to Responsible Gaming program, supporting self-exclusion, handy time and money tracking and many more.
The gambling house has been established in 1998, operating without interruptions since the day of its establishment. Jackpot City pays close attention to mobile gaming, so to ensure seamless experience it has released a lineup of mobile-focused gaming solutions (mobile website, applications for your smartphone, etc.) to ensure second to none experience for smartphone and tablet users.
Jackpot City is powered by the worldwide known Microgaming Corporation, a top class gambling game developer holding the leadership position due to stunning visualisation, advanced functionality and intuitive design. Dotted localisation efforts have resulted into the fact that the ecosystem now works with up to 20 languages and accepts 7 currencies. Another strong suit of the company is the adaptability of the products for both business owners and common players: thus, to install and setup a client you'll need just a couple of minutes and no advanced PC user skills.
Jackpot City is all about wide variety of games that has recently conquered the 400 products height, the number is growing on a constant basis. Apart from protozoan 3-reels 1-line gambling classics, you can enjoy way more sophisticated options with progressive jackpots, myriads of extra rounds and bonus games on board. Gambling rookies will certainly like to check the training regimes, while the seasoned players can put their skills through a test at tournaments organised on a regular basis.
Jackpot City doesn't skimp on rewarding their players; however, the offer terms may vary from region to region. Thus, the company provides you with a juicy bonus up to $500 released with your first deposits. Canadians can now take advantage of an exclusive offer implying doubling the amount of the first 4 deposits (the total bonus amount up to CA$1,600).


The controversial audio clip allegedly contains a conversation between BJP's state president Yeddyurappa and JD(S) MLA Nagangouda Kandkurs son Sharanagouda. In the clip it had been alleged that MLAs could resign without any fear because speaker Ramesh Kumar had been paid Rs 50 crore.
Kumartoday ordered Kumaraswamy to constitute a Special Investigation Team (SIT) to probe theaudio clipincident. He has directed that the probe in the connection should be finished within 15 days.
Just a few hours before presenting the state budget in the KarnatakaAssembly on Friday, Kumaraswamy had held a press conference and told media persons about theaudio clipwhile targeting Prime Minister Narendra Modi of horse-trading.


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Q: Can an SVN client break the repository? Is it possible for an Subversion client to break a repository in any way? This could be any sort of destructive disruption, but it must be such that it cannot be recovered from without restoring the repository from a backup.
Obviously, deleting everything and then checking that it is easy to fix simply with a rollback, so I am looking for something more than that.

A: A Subversion client can either talk to a server to access the repository, or it can use a file:// URL to access the repository directly. In the first case, the server is responsible for the repository so the client cannot directly "break" it. In the second case, the client is responsible for the repository so bugs in the client can affect the repository.

A: In theory, it cannot corrupt the repository, as Subversion uses atomic commits (bugs in Subversion notwithstanding).
However, ignoring access control, clients can of course move/copy/delete the contents of the repository in new revisions. Old revisions continue to exist. You can, in theory, always recover to these old revisions, either with judicious use of svn commands or by the administrator removing later revisions.
In general, it's pretty safe, but do look at access control: http://svnbook.red-bean.com/en/1.5/svn-book.html#svn.serverconfig.httpd.authz
Note: as Greg has intimated, it's slightly more complex when using a local repository as the client has direct filesystem access to the repository. Essentially, you have to trust Subversion.

A: If a client can break the repository in any way that requires a repository restore it's considered a very serious bug by the Subversion folks.
A quick look on their bug-tracker shows that they do occasionally have repository corruption bugs, but in the absence of a bug, it's not possible for a client to completely break the repository.

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In part 3 of this series on landing your ideal job, you'll learn how to feel confident and well prepared for your next interview.
What makes a confident interview candidate?
Imagine interviewing you are interviewing someone for a job who clearly has little idea what it is that your business does?
What kind of impression would that candidate make with you?
You might remember them, but for all the wrong reasons.
To stand out as the ideal candidate, it pays to do some research. The more you know about your new employer and their business, the better.
Importantly, when you're well prepared and have a solid understanding of the role you're applying to, you'll be able to approach an interview with confidence.
Each of these steps will build your knowledge, improve the quality of your answers and importantly make you feel really well prepared and confident.
How much do you enjoy talking about yourself? Can you confidently share your experiences and demonstrate your range of skills?
Confident candidates can give and concise examples which showcase their background and the key skills needed for the new role.
Situation (25%)– What were the circumstances you faced? What were the biggest challenges and opportunities you identified? What was the goal you set for yourself?
Actions (50%) – What specifically did you do to achieve these goals? What actions did you take? What skill(s) did you use to do that?
Results (25%) – What specifically were the results? How were they measured? What was the feedback? What did you learn as a result?
Situation: I was managing a team of 5 people helping a particularly grumpy client to design a new controls system for their company. At short notice, the client requested a 100 page draft report about their receivables system finished in 3 days. All my team were at full capacity on the existing project work and I didn't have the expertise available to fulfil this request.
Action: I enlisted the help of 4 appropriate colleagues from a different team in my company. I drew up a work-plan and allocated the work between the team based on their skills and experience. I briefed each team member and set a deadline to have their section ready in draft within 48 hours. I set clear reporting expectations and solved a problem for one of the team who couldn't get the appropriate information from the client. After careful review and revision of the draft work, I used the most skilled 2 colleagues to help me pull together and produce the 100 page report.
Results: The report was delivered 4 hours ahead of deadline and including additional analysis the client had not requested. The results of the report highlighted some key efficiency savings which have helped the client save over £1m per quarter from their £50m receivables. The client was delighted with the work and extended the project for another month.
As you can see from the examples, each section of the story should contain as many specifics as possible. Interviewers love specifics as it gives them evidence to justify their selection for the successful candidate. The story is short snappy and full of information.
These examples also highlight other skills (in this example: problem solving, working to tight deadlines, creating a strong team, developing relationships with clients).
To develop confidence and be well prepared for interview, take time to create an example for each of your core skills and attributes.
When you have developed the stories, practice them on friends, family, and anyone tolerant enough to listen. Seek feedback.
You should feel your confidence grow as you pull each story together and get comfortable telling it.
When it comes to interview, you'll be able to confidently outline your key skills and experience.
Preparation and practice help make perfect. Through background research and being able to articulate your skills, you'll feel confident in any interview and be prepared to land your ideal job.


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The Captain Charles Plumb: 6 year POW and Top Gun Pilot
byMpdawg
Known as The Captain, Charles Plumb piloted an F-4 Phantom and flew 74 successful combat missions against Vietnamese...
forces and became a top gun pilot. Listen to his stories of being a prisoner of war for six years and coming home as a war hero. Learn how he packed his mental parachute to survive the wars of his life.
Resources Mentioned in This Episode:
Charles Plumb
I'm No Hero
CharliePlumb.com
The Amazing Emily Farkas: Surgeon, Humanitarian, Mountaineer! Wow..
Dr. Emily Farkas is a Yale-trained Cardiothoracic surgeon and the first female accepted to the program at Yale University School of Medicine.
Mpdawg
Justin Osmond, son of one of the famous Osmond brothers talks about overcoming hearing loss
Justin Osmond was born with profound hearing loss into a musical family. After 12 years of intense speech and listening therapy, he can now speak with passion and through modern-day technology, hear with conviction.
Editor Nov 5, 2017
Country Music Star Steve Azar talks about overcoming adversity VH1 Storyteller style
Steve Azar is a singer and songwriter that marries country, rock, and blues influences to create "Delta-Soul." Inspired by the state of Mississippi, Steve wrote many successful tracks that topped the country charts including "Waitin' On Joe," "I Don't Have to Be Me," and "Sunshine."
Editor Sep 22, 2017
jonclimbs Sep 22, 2017
Thanks for the insights and history of this musician.
Dianette Wells on Conquering the Seven Summits to Overcoming the Tragic Loss of Her Amazing Son
Dianette Wells is a mountain climber and adventure racer who immerses herself in new experiences as a form of therapy. She has currently climbed seven summits, including Everest and Denali. After the passing of her son, Dianette found that she had been doing the right thing all along by influencing
Editor Oct 9, 2017
Mike Vowels: A World Class Skier's Return To Paradise...
There is no expiration date to do great things in our lives.
Editor Feb 13, 2018
Colin O'Brady, from burned victim to becoming the first person to do the Grand Slam in 139 days!
Colin O'Brady was born in the Northwest and attended Yale University. After graduating from Yale, Colin made the decision to travel around the world; however, while in Thailand, Colin endured a serious accident with a kerosene jump rope, burning 25 percent of his body.
Tom Flick on his Enter and Exit to the NFL, Overcoming Hardships, and Becoming a Public Speaker
Former NFL Quarterback Tom Flick, has garnered a reputation around the world as an authority on leadership by helping organizations like Google, Starbucks, Boeing and the Pentagon develop leaders, lead change effectively, recognize opportunities for growth, and increase teamwork and organizational..
Cory Procter on Developing Grit, Dealing with Hardships and Stories From NFL
Cory Procter is a former American football guard in the National Football League, who played mostly for the Dallas Cowboys. I met him in Tanzania through the Waterboy foundation. Cory is one of the sincerest guys I know and it comes through in this episode.
Sparsh Shah: Combining Indian Classical Music with Hip Hop
They say that the eyes are the window to the soul. That has never been more true than when Sparsh Shaw looked....
Editor Apr 5, 2018


text:
Q: LINQ - Multiple Nested Selects I have the following LINQ query which selects some Navigation Property's properties.
var nodes = await dbContext.MonProfiles
    .Include(x => x.Nodes)
    .SelectMany(x =>
        x.Nodes.Select(y =>
            new {y.NodeNativeId, y.NodeClassId, y.NodeName, y.NodeClass.ClassName}))
    .ToListAsync();

I would like to also be able to select another Navigation's Property's properties so that it is a single round trip to the database.  Below is what I have tried, but it did not compile:
var nodes = await dbContext.MonProfiles
    .Include(x => x.Nodes)
    .SelectMany(x =>
        new
        {
            x.Nodes.Select(y =>
                new {y.NodeNativeId, y.NodeClassId, y.NodeName, y.NodeClass.ClassName}),
            x.CasAttributes.Select(y => new {y.AttributeName})
        })
    .ToListAsync();

A: Your description was a little unclear, but I think what you want is something like the following:
var nodes = await (from profile in dbContext.MonProfiles.Include(x => x.Nodes)
                   select new {
                       Nodes = from node in profile.Nodes
                               select new {
                                   node.NodeNativeId,
                                   node.NodeClassId,
                                   node.NodeName,
                                   node.NodeClassName }
                       CasAttributes = from attribute in profile.CasAttributes
                                       select attribute.Name
                   }).ToListAsync();

I'm not sure if this will work with your specific database provider, but the issue with the code you provided was the anonymous type didn't know what name to use for the fields.  Sometimes it can infer it, if it's simple enough (for example, just accessing a property), but when you call a Select statement or something you have to specify the names of the fields.


Laurie's dress was absolutely stunning. All the layers on the train made it look like she was almost floating – it was just gorgeous!
The girls got ready at the Ritz which has beautiful city views. It made for the perfect backdrop for her beautiful brooch bouquet which included a special family brooch.
Let's give the handsome guys some love with this serious action shot! These guys mean business.
I absolutely LOVED the boutonnieres.
The ceremony was held at Byrons in the Atrium and I loved the set-up.
Laurie and Matt giggled here when he stomped on the glass. It was a sweet and charming moment for the happy couple.
Byrons has the most perfect brick alley for post-ceremony photos. The wedding party had such a fun time posing and looked totes professional.
How many bridesmaids does it take to do a bustle?!
Look at how pretty this photo is – they look like bride and groom models! And I have to say, I LOVE the bustle. Some bustles look weird. This one looked perfect.
Byrons was set up beautifully for the reception. The flowers from Jay at In Bloom were gorgeous!
Oh… the cake. Made by the grooms sister, Haines from For Goodness Cakes, this was a stunner.
I love their guestbook where guests wrote directly on the "P" for the couples last name. So creative!
Their perfect party getaway was lined with glo-sticks!
The couple left the party on the light rail and the photographer got some amazing shots of them waiting for the light rail and on the light rail! I loved these photos because I never got to see this part in person and they are so, so sweet!
I love the photos when Laurie is wearing Matt's jacket. So gentlemanly!
Here comes the light rail!
Here they are just chilling with other folks on the light rail. Wouldn't you be delighted if you saw this happy couple on your way home? Side note, look at her cute shoes peeking out!
This couple was such a blessing to get to know, and I know Laurie and I will be friends for a long time to come. In fact, we recently spent a delightful evening together eating sushi and drinking wine with her sister who is also fabulous. It's like I got to be friends with the whole family! I love when that happens.
This weekend is a doozy for me. I've got a fancy baby shower I'm setting up for tomorrow and then I leave town for my mini-triathalon right after that. Eeek! Can you say nervous?! I hope I finish and don't drown, crash or fall. Ha!
And here are my tri-training partners with our sweet goggles.
Wish me luck this weekend – can't wait to report back next week!
Sometimes it's felt like so long since I've written a blog I don't know how to start. So I'm going to start with some random thoughts.
August is a super busy month for me so I'm feeling a bit crazed. Again, more on that later.
In the meantime, I'm going to show you the beautiful baptism for my 2nd adorable niece, Claire.
One of my favorite parties I ever planned was for my older niece Brooke's baptism. It was just so simple and sweet!
For Claire's baptism after-party (yup that's right, she had an after-party), we obv stuck with pink but added in gold chevron and burlap elements. It was a lovely affair to celebrate a truly precious little babe!
It's a baptism fact that you can't have a true baptism without a Mimosa Bar. It's true.
Little Claire's picture and her fabulous invitation by Party Box Design were displayed.
Here I am with the little babe. I have to say she is the most smiley, happiest baby I've ever met! She let basically everyone at the baptism hold her and she just smiled the whole time. What. A. Doll.
This month is cray for me, with a big event this weekend, fancy baby shower, mini-triathalon and a wedding. Yikes! But it's all good, I like being busy and go a little crazy when I'm not busy. Just ask Mr. Fo.
This weekend's event is a really cool event; a Film Festival that raises money for pediatric cancers. It's been a lot of work over the past year and I'm looking forward to seeing it come together. You can read about the event HERE.


Sleep has the biggest influence over our health and wellbeing. It's more important than exercise, income and friends. We spend one third of our life asleep and we tend to take it for granted rather than spending any time making sure it's the best sleep we can get.
There are four stages of sleep and we spend around 90 minutes in each stage; we wake between each cycle whether we are aware of it or not.
Stage One – Drowsiness and falling asleep.
Ask yourself, 'do you fall asleep within 20 minutes?' To fall asleep easily we rely on our brain to switch off from wakefulness and activate our sleep centres. If you are overly active before bed, it can affect how easily you fall asleep.
Deep, regular breathing can help.
Making a list of all that needs to be done the following day can empty your mind in preparation for sleep.
Ensuring you have enough time to wind down post exercise is helpful.
Staying off of screens for 30-60 minutes before bedtime is also useful.
We spend around 50% of the night in light sleep, we periodically move to Stage One to shift our position, but most of us don't notice this small amount of wakefulness.
This stage is the most fleeting and is where our brain slows down and allows us to deepen our sleep.
REM is the deepest level of sleep and is called this due to the Rapid Eye Movement that occurs during this stage. During this phase our brain is highly active and is where our dreams occur. We usually drift back to Stage 2 and repeat the process during the night.
If you have a sleepless night then experiments have shown that your body tries to make up the deficit the following night. Sleep becomes an issue if your lifestyle habits don't allow you to catch up on any sleep deficit. This can lead to irritability, fatigue, memory issues and dependency on stimulants such as caffeine to give us the boost we need to get through the day.
Having a good pre-bed wind down process can really help with our sleep habits.
Stretching is a good way to get your body ready for sleep.
Meditation helps to prepare the mind for sleep.
A warm bath and a good book are great ways to relax.
A herbal bedtime tea can also help to relax and prepare you for bed.
Staying off screens immediately before bed will stop the brain from becoming over stimulated.
Why not look at your bedtime routine and if you struggle to get off to sleep then try one of these techniques to help you get to sleep .
" I wanted to get fit and lose weight. The class is fun and friendly but we work hard too. It's adaptable to your individual needs and you work out with friends. Just give it a go and find out how much fun exercise can be. "


Two Network member organizations are among the recipients of more than $852,000 in grants recently made by the Lucile Packard Foundation for Children's Health to improve systems of care for chronically ill children in California.
Support for Families of Children with Disabilities, based in San Francisco, will train families of chronically ill children to advocate for health system change. The Lucile Packard Children's Hospital in Palo Alto will continue its work with a group of medical directors for California Children's Services to coordinate their work and to standardize care and eligibility standards for children served by CCS.
* Develop better ways to evaluate how well providers coordinate children's care.
* Explore creation of an online claims clearinghouse for providers who serve children with chronic health problems.
For more detailed information on all of the grantees and their projects, click here.
Network members also will play a key role in a new project, the California Community Care Coordination Collaborative (5Cs), also funded by the Foundation. This learning collaborative of six community coalitions will help enhance coordination of care among community service providers. Participants will identify areas of shared need, discuss emerging challenges in care coordination, receive technical assistance and learn from one another. For more information and a list of the organizations involved, click here.
California State Senator Ed Hernandez (D-West Covina) is planning to introduce legislation to expand the scope of practice of mid-level health care providers, including nurse practitioners and physician assistants. The legislation is designed to improve access to health care services by increasing the number of health workers able to provide care. By allowing some mid-level practitioners to be designated "providers of medical homes," this legislation could expand the availability of medical homes to more California children with special health care needs.
The conference offers health care providers, administrators, staff, patients & families a regional opportunity to connect and share challenges, solutions and successes related to patient and family-centered care. Contact Libby Hoy at Libby@pfccpartners.com or Mia Arias at MArias@nhfca.org.


Amangamek-Wipit Lodge #470 has pursued a number of opportunities to educate Order youth about the benefits of outdoor recreation and environmental stewardship as well as to provide service to its Council camps at Goshen Scout Reservation. The lodge formed its first Goshen Order of the Arrow Trail Crew (GOAT) in June 2002 to take advantage of such opportunities. "GOAT" as it is called in our lodge is modeled after the Philmont OA Trail Crew program that has been in operation for many summers.
The GOAT Program offers an innovative leadership and high adventure opportunity. The program challenges older Order youth and adults to experience, first-hand, the interrelationship between outdoor recreation and environmental stewardship. The Trail Crew Program combines the spirit of adventure with an interactive back country program into a two week experience.
Experiencing fun and inner satisfaction from a unique high adventure experience with lifetime memories.
After crew selection and formation, two adult crew overseers will accompany the crew(s) to Camp Baird on one of the start dates. From Monday through Friday, the GOAT Crew will interact with various trainers on topics related to outdoor ethics and back country conservation so that the youth crew may apply these newly learned skills across the entire breadth of the Lenhok'sin Trail system. (Second crew is Tuesday through Friday.) The GOAT Crew will be introduced to Goshen's newest COPE [Challenging Outdoor Personal Experience] course that helps youth to plan, organize, and lead outdoor adventure activities. In addition, crew members can expect to be exposed to advanced outdoor skills, techniques and strategies. Examples of such skills include: Search and Rescue (SAR), fire suppression and back country risk management. Also, each participant may earn certification in Leave No Trace (LNT) ethics.
Order of the Arrow members selected as GOAT Crew participants pay a total program cost of $170. This amount covers the costs for the fourteen (14) day high adventure experience at Goshen. Second crew program cost is $140 for the twelve (12) day program. Camperships are available – use the information form on the back side of the brochure.
Download the brochure and applications below.
Do you know names of Order youth or Order adults in your unit who may be interested in participating as Goshen OA Trail Crew members? May we use your name as a resource and means to contacting these members?


Helen offers face to face readings for small groups either as a gathering of family and or friends for 90 mins. Minimum is 7-8 people (not including the hostess) at $50.00 per person. The Hostess does not pay if 8 or more when being held at your location. she will only travel up to 1 hr from Burlington, Ontario.
If you have a Group of 10 but no location, you can arrange to hold it out of Helen's location.
Group Skype is also available up to 4 people maximum. Please see under "Booking ".
**A $50.00 non-refundable deposit is required to secure your date and can be paid via Etransfer to [email protected] or Paypal.
Please note that Helen does not guarantee that everyone will receive a "message" ( in a group) but the experience alone is amazing. Please email to discuss dates.
Can be in person for 45 mins. or via Skype or Telephone.
A non-refundable deposit ( unless given 48 hrs.) is required or full payment to secure your spot.
Book Helen for your next Conference, Live Event, Retreat Centres or for Groups of 10-20 people. Helen has addressed over 200 people and clearly and accurately performed readings for the crowd. Helen is also available for Media Interviews as well as VIP and Fan Meet & Greets before or after each event.
An action-packed emotional roller coaster ride. The evening will start off with a much needed relaxing meditation, followed by energetic music that will have everyone up and dancing to raise the levels of vibration in the room. Helen will then share messages from loved ones who have passed that will bring healing, comfort, validation and lots of joy.
It is an evening of CELEBRATION !!
Helen does not record the sessions but you are welcome to record with your phone.
Guests must be 19 years of age or older, or 14+ and accompanied by a parent/guardian.