Verified Circulation Guide

  1. Introduction
  2. Verified Circulation Defined
  3. Quick-Check Qualification Reference
  4. Public Place Verified Circulation
  5. Individual Use Verified Circulation
  6. Reporting of Verified Circulation
  7. For the Audit

Introduction

The classification of verified circulation became effective Jan. 1, 2006, and was reported on the AAM publisher’s statements for the first time in June 2006.

This guide is intended to explain and clarify the rules and guidelines governing copies classified as verified circulation on AAM documents. It includes definitions of the various types of verified circulation, the qualification and reporting requirements, and an overview of the records that should be maintained for an AAM auditor’s review.

This guide is not intended to be all-inclusive, but rather provides general guidance for verified circulation. The rules, policies and requirements identified and explained in this guide are those in effect as of Jan. 1, 2008, and forward. As new rules become effective, these requirements are subject to change. It is the publishers’ responsibility to ensure that their verified circulation initiatives comply with all AAM rules and guidelines in effect at the time they are executed. The most current rules and guidelines can be found on AAM's website.

Upon request, AAM’s Publisher Relations department provides a confidential review of members’ programs. To take advantage of this review or if you are developing an initiative that is not addressed in this guide, please contact your Publisher Relations manager.

No part of this guide may be reproduced without making this forward a part thereof and without the consent of the Alliance for Audited Media.

Verified Circulation Defined

Verified circulation is defined as subscription copies designated by publishers for readership in public places or intended for individual use by recipients who are likely to have a strong affinity for the content of the magazine. See Rule F 15.1 Verified Circulation.

Verified circulation is not subject to Rule F 1.1 Paid Circulation Defined. However, in the explanatory paragraph of AAM Publisher’s Statements, publications have the option to disclose any payments received from a sponsor for verified circulation, provided the payment reported is net of all considerations and adequate records are in place to verify the transaction.

There are two sub-classifications of verified circulation:

  1. Public Place
  2. Individual Use

Public place verified circulation represents copies served to business establishments for use by its patrons in waiting rooms, hotel rooms, or by airlines on-board the planes or in restricted access airline clubs. It is not intended for these copies to be picked up and removed by the individuals, rather the copies should remain at the location for further use by other patrons.

Individual use verified circulation represents copies distributed to individual names at private residences or business offices intended for personal consumption by the addressee. The recipients are individuals whose names were either obtained from a list-type source or who specifically requested a subscription to the magazine.

For list-type source recipients, the source of the list should reflect individuals who have a strong affinity for the editorial content of the magazine. For individually requested copies, the individual must have opted in to an offer to receive the magazine. See also Rule F 15.2 Individually Requested Circulation.

Please note:
The sub-classification of verified individual use may not include copies claimed as paid circulation on a publisher’s statement, then disqualified as such during the AAM audit. 

Quick-Check Qualification Reference

This quick-check qualification list is intended to highlight the key qualification points for each type of verified circulation. However, for complete qualification requirements, please view the section(s) in this guide for each specific type of verified circulation.

Public Place

Waiting Rooms
For waiting room circulation to qualify as verified public place circulation, each waiting room must:

  • Receive at least two consecutive issues.
  • Receive the current issue (back copy service is not permitted).
  • Receive no more than three copies, per issue, of the magazine(s).
  • Be presented with an opt-out notice, at least annually.

(For complete qualification requirements, see the Waiting Rooms section of this guide.)

Hotels (for in-room use)
For hotel circulation (in-room use) to qualify as verified public place circulation, each hotel must:

  • Agree (opt-in) to receive delivery.
  • Receive at least two consecutive issues.
  • Receive the current issue (back copy service is not permitted).
  • Receive no more than the maximum copy limit, per issue.
    • For magazines published monthly or less frequently, the maximum number of copies each lodging establishment may receive is four copies per guest room.
    • For magazines published more often than monthly, the maximum number of copies each lodging establishment may receive is one copy per guest room.
  • Sign a written agreement with the magazine, or its agent, regarding the details of delivery.

(For complete qualification requirements, see the Hotels (for in-room use) section of this guide.)

Airlines
For airline public place verified circulation to qualify as verified public place circulation, each airline must:

  • Agree (opt-in) to receive delivery of the magazine(s).
  • Receive at least two consecutive issues.
  • Receive the current issue (back copy service is not permitted).
  • Receive no more than the maximum copy limit, per issue.
    • No more than two copies times the total number of monthly flights by that airline, not to exceed 8,000 copies per issue.
  • Distribute copies either on-board the planes or in restricted access airline clubs.
  • Have total discretion as to how many copies will be made available at each airline location.
  • Provide an affidavit attesting that all magazine copies were made available to their customers either on-board their airplanes or in restricted access clubs.
  • Sign a written agreement with the magazine(s), or its agent, regarding the details of delivery.

(For complete qualification requirements, see the Airlines section of this guide.)

Individual Use

List-type Source
For list-type source individual use verified circulation to comply with AAM requirements, the following must occur:

  • The source of the list used to obtain the names is consistent with the editorial content of the magazine.
  • The individual must receive at least two consecutive issues.
  • The current issue must be served (back copy service is not permitted).
  • Limit of one subscription per recipient.
  • Recipients must be presented with an opportunity to opt-out of the magazine delivery within 90 days of the start of service.

(For complete qualification requirements, see the List-type Source section of this guide.)

Individually Requested
For individually requested individual use verified circulation to comply with AAM requirements, the following must occur:

  • Recipients must opt-in to receive the subscription before service begins.
  • The individual must receive at least two consecutive issues of the magazine.
  • Limit of one subscription per recipient.
  • Back copy service is permitted for new subscribers.
    • For magazines published monthly or bi-monthly, one issue preceding the one currently being mailed.
    • For magazines published more often than monthly, two issues preceding the one currently being mailed.
  • Request documentation (opt-in) must be maintained by the publication for the AAM auditor’s review.
    • May not be more than three years old.
    • For direct mail pieces, the subscriber must input the date the form was completed and be presented with either a “Yes” and “No” option, sign the form as acknowledgement they wish to receive the subscription, or fill in their name and address information.
    • For telemarketing offers, the interviewer must sign and date the interview record.

(For complete qualification requirements, see the Individually Requested section of this guide.)

Public Place Verified Circulation

Public place verified circulation represents copies served to business establishments for use by its patrons in waiting rooms, hotel rooms, or by airlines on-board the planes or in restricted access airline clubs. It is not intended for these copies to be picked up and removed by the individuals, rather the copies should remain at the location for further use by other patrons.

See also Rule F 15.1 Verified Circulation.

There are three general types of public place verified circulation:

To view how verified circulation is disclosed on AAM publisher’s statements, please refer to the Reporting section of this guide.

Waiting Rooms

This type of public place verified circulation includes copies distributed to waiting rooms such as doctors’ offices, hospital waiting rooms, beauty salons, fitness facilities, etc.

Qualification
For waiting room public place verified circulation to comply with AAM requirements, each waiting room must:

  • Receive at least two consecutive issues of the magazine.
  • Receive the current issue of the magazine (back copy service is not permitted).
  • Be presented with an opportunity to opt-out of receipt of the magazine(s).
  • Receive no more than three copies, per issue, of the magazine, per waiting room location.
    Please note:
    • There may be locations such as a hotels or medical facilities that have multiple waiting room locations, such as the lobby, restaurant, spa, cafeteria, emergency waiting room, surgery waiting room, etc. Controls must be in place to ensure the distribution is executed in compliance with AAM rules (no more than three copies per each waiting room location within the facility).
    • The publisher, or its agent, must also maintain documentation signed by the management of the facility attesting to the number of different waiting room locations within the facility and identify them.

Opt-out Notice
For waiting room copies, the following guidelines apply to the opt-out notice:

  • For locations receiving waiting room copies for the first time, the notice must be sent to the waiting room at the beginning of the service.
  • For all locations receiving waiting room copies for a term exceeding one year, the notice must continue to be sent to the waiting room locations at least once per year (annually).
  • The notice must be a stand-alone notice delivered to the waiting room location by the U.S. postal service. Opt-out notices presented via any other means such as telephone or email are not acceptable.
  • The notice must be devoted to communicating the opportunity to opt-out of delivery of the magazine(s). No other message points are permitted in the notice.
  • The notice must provide, at minimum, at least one of the following methods for the waiting room location to opt-out of the magazine delivery:
    1. Postage-paid postcard
    2. A toll-free phone number
    3. URL to website hosting an opt-out form
    4. A dedicated email address

Examples of acceptable opt-out notices (for waiting rooms):

Offering a toll-free number to call:

Dear Public Place Location:

We hope you are enjoying the delivery of our magazine(s) to your location for use by visiting patrons in your reception rooms.

This delivery is brought to you by our organization. If, for any reason, you wish not to receive our magazine(s), please call 1-800-xxx-xxxx to cancel your service.

Sincerely,
The Reception Room Source

 

Offering a postage paid postcard to return:

Dear Public Place Location:

We hope you are enjoying the delivery of our magazine(s) to your location for use by visiting patrons in your reception rooms.

This delivery is brought to you by our organization. If, for any reason, you wish not to receive our magazine(s), please return the attached postage paid card to cancel your service.

Sincerely,
The Reception Room Source

(Return below portion to cancel service)

-----------------------------------------------------------

Please discontinue delivery of magazine(s) to .
Print Name: ________________________ Address: ______________________
Signature: ________________________   ______________________
Date: ________________________   ______________________

Hotels (for in-room use)

This type of public place verified circulation includes copies distributed to hotels, motels, bed and breakfasts and other similar lodging facilities for in-room use by the guests of the lodging establishment. These copies are for in-room distribution only and are intended to remain in the room for use by future guests.

Qualification
For hotel public place verified circulation to comply with AAM requirements, each lodging establishment must:

  • Agree (opt-in) to receive delivery of the magazine(s) at its establishment.
  • Receive at least two consecutive issues of the magazine.
  • Receive the current issue of the magazine (back copy service is not permitted).
  • Receive no more than the maximum copy limit, per issue.
    • For magazines published monthly or less frequently, the maximum number of copies each lodging establishment may receive is four copies per guest room.
    • For magazines published more often than monthly, the maximum number of copies each lodging establishment may receive is one copy per guest room.
  • Sign a written agreement with the magazine, or its agent, regarding the details of delivery.

Agreement
For hotel copies, the signed agreement must be renewed at least once per year (annually) and contain the following information:

  • The name and address of the lodging establishment.
  • Confirm the hotel’s willingness to receive delivery of the magazine(s).
  • Confirm the copies were distributed to the guest rooms for in-room use only.
  • State the title of the magazine(s).
  • State the total number of subscriptions, per magazine, being delivered.
  • State the term of the subscriptions, per magazine, being delivered (term of distribution).
  • State the total number of guest rooms at the establishment.
  • Contain the printed name, title and signature of the executive at the lodging establishment.
  • Contain the date the agreement was signed.

Airlines

This type of public place verified circulation includes copies provided to airlines for distribution on-board the planes or in restricted access airline clubs. These copies are for use by passengers on the flight or in the clubs and are intended to remain in these locations for use by future passengers (not intended for pick up and removal by passengers).

Qualification
For airline public place verified circulation to comply with AAM requirements, each airline must:

  • Agree (opt-in) to receive delivery of the magazine(s).
  • No inducements (financial or otherwise) may be provided to airline to participate.
  • Receive at least two consecutive issues of the magazine.
  • Receive the current issue of the magazine (back copy service is not permitted).
  • Receive no more than the maximum copy limit, per issue.
    Regardless of a magazine’s frequency, an airline may receive, per issue, no more than two copies times the total number of monthly flights by that airline, not to exceed 8,000 copies per issue. For example:
    • If XYZ Airline has 3,000 total flights per month, then the airline may receive no more than 6,000 copies per issue (3,000 flights x 2 copies per issue = 6,000).
    • If MNO Airline has 9,000 total flights per month, then the airline may receive no more than 8,000 copies per issue (9,000 flights x 2 copies per issue = 18,000, but distribution may not exceed 8,000 copies per issue).
  • Distribute copies either on-board the planes or in restricted access airline clubs.
  • Have total discretion as to how many copies are made available in each airline location (in restricted access clubs, on domestic flights and on international flights). For example, if an airline agrees to receive 2,000 copies per issue, they may choose to place all 2,000 copies on international flights and none in their clubs or on domestic flights.
  • Provide an affidavit attesting that all magazine copies were made available to their customers either on-board their airplanes or in restricted access clubs.
  • Sign a written agreement with the magazine(s), or its agent, regarding the details of delivery.

Agreement
For airline copies, the signed agreement must be renewed at least once per year (annually) and contain the following information:

  • The name of the airline.
  • Confirm the airline’s willingness to receive delivery of the magazine(s).
  • Identify locations where copies are distributed and that the intent is for the copies to remain in these locations (not for pick up and removal by passengers).
  • State the title of the magazine(s) and total quantity and term of subscriptions, per magazine, being delivered.
  • Contain a statement affirming that the airline has not received any inducements to participate in the program.
  • Contain the printed name, title, and signature of the executive at the airline.
  • Contain the date agreement was signed.

Please note:
Copies that do not meet the above qualification requirements for airline copies do not qualify as verified circulation. These situations include, but are not limited to, the following:

  • Copies placed in other airport public locations (such as gate areas, shuttle services, etc.)
  • Copies made available for pick up and removal by the airline customers.  

Individual Use Verified Circulation

Individual use verified circulation represents copies distributed to individual names at private residences or business offices intended for the personal consumption by the addressee. See also rules F 15.1 Verified Circulation and F 15.2 Individually Requested Circulation.

There are two general types of individual use verified circulation:

Please note: Individual use verified circulation may not include copies claimed as paid circulation on a publisher’s statement, then disqualified as such during the AAM audit.

 

List-Type Sources                                            

The list-type source of individual use verified circulation represents individuals who were sent a subscription to the magazine because their names appear on a list or similar source obtained by the publication.

Qualification
For list-type source individual use verified circulation to comply with AAM requirements, the following must occur:

  • The source of the list used to obtain the names is consistent with the editorial content of the magazine.
  • The individual must receive at least two consecutive issues of the magazine.
  • The current issue must be served (back copy service is not permitted).
  • Limit of one subscription per recipient.
  • Recipients must be presented with an opportunity to opt-out of the magazine delivery.

Opt-out notice
For list-type source individual use verified circulation, the following guidelines apply to the opt-out notice:

  • For new subscriptions, recipients must be presented with the opt-out notice no later than 90 days after the start of service.
  • For all subscriptions exceeding one year in term, an opt-out notice must be sent to the recipient at least once per year (annually).
  • The notice must specify the title of the magazine.
  • The notice may be provided to the recipient in one of the following ways:
    • Direct mail via the U.S. postal service
      The notice must be devoted to communicating the opportunity to opt-out of delivery of the verified subscription of the magazine. No other message points are permitted in the notice.
    • Cover wrap or cover mount
      A cover wrap or cover mount notice must be posted in a clear and conspicuous manner. The notice must be at least 12 point type and within four lines of the address label. It is acceptable for cover wraps and cover mounts to contain other messages to the recipient provided the notice of opt-out remains clear and conspicuous to the consumer.
    • AAM will consider email opt-out notices, provided the publisher or agent executing the notification can validate delivery of the emails to the recipients.
  • The notice must provide, at minimum, at least one of the following methods for the individual to opt-out of the magazine delivery:
    • Postage-paid postcard
    • A toll-free phone number
    • URL to website hosting an opt-out form
    • A dedicated email address

Examples of acceptable opt-out notices (for List Source Individual Use Verified Circulation)

Direct Mail (offering a website address opt-out reply:)

Dear Ms. Ann Smith:

We hope you are enjoying the delivery of Proto Magazine to your home.

If for any reason you wish to not receive Proto Magazine, log on to www.proto.com to cancel your service.

Sincerely, 
Management Staff of Proto Magazine

 

Cover Wrap (offering a toll-free number to call:)

(back) (front)
Schoolhouse

Prototypemagazine

To discontinue receipt of this magazine, please call 1-800-123-2345

Ann Smith
123 Main Street
Anytown, ON A1A 1A1

Individually Requested

The individually requested type of individual use verified circulation represents copies served to individual recipients that specifically requested a subscription to the magazine. For individually requested copies, the individual must have opted in to an offer to receive the magazine. See also F 15.2 Individually Requested Circulation.

Qualification
For individually requested individual use verified circulation to comply with AAM requirements, the following must occur:

  • Recipients must opt-in to receive the subscription before service begins.
  • The individual must receive at least two consecutive issues of the magazine.
  • Limit of one subscription per recipient.
  • Back-copy service is permitted for new subscribers.
    • For magazines published monthly or bi-monthly, one issue preceding the one currently being mailed.
    • For magazines published more often than monthly, two issues preceding the one currently being mailed.
    • See also Rule F 7.2 Back Copies.
  • Request documentation (opt-in) must be maintained by the publication for the AAM auditor’s review.

Request Requirements
For individually requested individual use verified circulation, the following guidelines apply to the opt-in request: (See also F 15.2 Individually Requested Circulation)

  • May not be more than three years old.
  • For direct mail pieces, the subscriber must input the date the form was completed and do at least oneof the following:
    • Be presented with and respond to a “Yes” and “No” option.
    • Sign the form as acknowledgement they wish to receive the subscription
    • Fill in their name and address information
    For example, if the form had the consumer’s name and address pre-printed on the mail piece, then either a yes or no option must be presented, or the consumer must provide a signature. If the consumer must fill in their name and address, then a signature and yes or no option are not required. AAM recommends you incorporate at least two of the above elements to ensure the order will qualify when received from the consumer.
  • For telemarketing offers, the interviewer must sign and date the interview record.
  • For telemarketing and Internet offers, a personal identifier question must be asked of the consumer. The personal identifier question must change with each subscription renewal. A personal identifier question is one where the answer from the consumer has only one answer and that answer cannot change, such as the following:
    • Mother’s maiden name
    • Month of birth
    • City of birth
    • State of birth
    • High school from which you graduated
    Examples of unacceptable personal identifier questions would be as follows:
    • Color of your eyes
    • Shoe size
    • Number of siblings you have

Examples of acceptable request forms (for individually requested individual use verified circulation)

Direct Mail Piece (Name and address are pre-printed; Offers Yes/No question and signature):

___YES! Please continue my free subscription to Prototype Magazine.
___NO, please cancel my subscription.

Name: Joe Smith
Address: 555 Main Street
City, State, ZIP: Toronto, ON M5S 1S4

Signature: _____________________ Date: __________________

 

Direct Mail Piece (Offers completion of name and address and signature)

Yes, I would like to receive a free subscription to Prototype Magazine!

Name _________________________
Address _______________________
City, Province, PC _________________

Signature: _____________________ Date: __________________

 

Direct Mail Piece (Offers completion of name and address only)

Yes, I would like to receive a free subscription to Prototype Magazine!

Name _________________________
Address _______________________
City, Province, PC _________________

Date: __________________

Reporting of Verified Circulation

To review a complete prototype of an AAM publisher’s statement inclusive of verified circulation, please click on one of the links below:

Verified circulation is disclosed in the publisher’s statements and audit reports in all appropriate paragraphs.

Paragraph 1

Verified circulation is disclosed as a total average for the reporting period. Verified circulation appears only under the umbrella of “Subscriptions”, as all types of verified circulation requires no less than two consecutive issues of service.

If the magazine claims any rate base or guarantee to advertisers, this rate base is displayed in paragraph 1 of AAM documents. In situations where a publisher elects to make a rate base claim for a segment of circulation, such as paid only or verified only, then the explanatory paragraph may provide this additional disclosure. See also Rule F 11.1 Advertising Rate Base or Circulation Guarantee.

Magpara1

Paragraph 6

Paragraph 6 delineates the total average public place versus the total average individual use verified circulation for the reporting period.

Magpara6

Paragraph 6A and 6B

Paragraphs 6A and 6B disclose the total average verified circulation by source.
Paragraph 6A discloses the total average circulation by source for verified public place circulation for the five distribution locations that generated the highest volume. The remaining verified public place circulation appears under the source of “Other.”

Magpara 6a

Paragraph 6B discloses the total average circulation by source for verified individual use circulation for the five distribution sources that generated the highest volume. The remaining verified individual use circulation appears under the source of “Other.”

Magpara 6b

The source categories appearing in paragraphs 6A and 6B must be those available from a standardized source listing issued by AAM and maintained on the AAM website. Publishers should consult this online listing when assigning codes for AAM record keeping purposes.

Publishers wishing to provide a more detailed disclosure of their verified circulation may do so. The publication should contact their Publisher Relations manager to discuss their specific intentions for additional disclosure.

Paragraph 9 (optional payment disclosure)

Verified circulation is not subject to Rule F 1.1 Paid Circulation Defined. However, in the explanatory paragraph of AAM Publisher’s Statements, publications have the option to disclose any payments received from a sponsor for verified circulation, provided the payment reported is net of all considerations. Adequate records must be in place to verify the transaction.

All Other Paragraphs

In addition to paragraphs 1, 6, 6A and 6B, verified circulation is disclosed in other paragraphs of the AAM publisher’s statement. This includes, but is not limited to, total average verified circulation by issue and by edition (if applicable) and total verified circulation for the analyzed issue by geography (state and ABCD analysis).

Publications that participate in AAM’s Media Intelligence Center and submit data by county are required to provide verified circulation by county.

For the Audit

All circulation data claimed on AAM publisher’s statements must comply with all AAM bylaws, rules, guidelines and policies and be supported by auditable documentation.

Bylaw 2.8 Publisher Duty to Install and Maintain Records states that it is the responsibility of the publisher (AAM applicant or member) to maintain all records necessary for audit, ensure that the records are accurate, and provide those records to the AAM auditors in a timely manner. This bylaw also states:

“Publisher members may sell copies in quantities through agents, distributors and wholesalers, independent contractors or other third parties, however, the publisher shall remain responsible for the accuracy, completeness and accessibility of the records maintained by such organizations…”

For verified circulation, the records made available to the auditor must support the five primary elements of the transaction:

  1. The copies claimed as verified were actually distributed to recipients.
  2. The recipient (individual or public place) was served at least two consecutive issues.
  3. Opt-out requirements were met for:
    • Public Place – Waiting room
    • Individual Use – List-type sources
  4. Opt-in requirements were met for:
    • Public Place – Airline and Hotels (written agreements)
    • Individual Use – Individually Requested (request from recipient)
  5. Circulation was properly classified in the publisher’s statements.
    • In general
    • By distribution location or source (paragraphs 6A and 6B classifications)

The AAM auditor must be granted access to all documentation supporting the five primary elements of verified transactions. During the audit, however, the AAM auditor may also determine additional information or documentation is necessary to complete their validation of this circulation.

The records necessary for the AAM audit of verified circulation include, but are not limited to:

  • Proof that copies were printed—may include print orders, print invoices and proof of payment to printer.
  • Source of names—through third-party verification of list sources.
  • Proof that opt-out notices were mailed—including mailing or distribution records (via the USPS) and responses of opt-outs received.
  • Copies of written agreements for all hotel and airline programs.
  • Original orders—for all individually requested copies (direct mail forms, telemarketing scripts, online orders, etc.).
  • Proof that magazine copies were mailed—either via the USPS or alternative delivery source such as Federal Express, UPS, etc.
  • Proof that a minimum of two consecutive issues were served to each individual and public place recipient.

If a magazine chooses to disclose in the explanatory paragraph that payments were received from a sponsor for verified circulation, documentation must be provided to confirm the payment was reported net of all considerations.

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