Unsolicited direct marketing. It’s vexing because it is the last sentence in an otherwise well-defined section. In essence, your argument presupposes that the e-Privacy Directive exists and therefor it would not be possible under GDPR to legitimately collect email without an opt-in. Through those processes you can demonstrate clear and specific consent. But if you think that you're reading this the wrong way round. Recital 47 of the GDPR states that “[t]he processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest.” Thus, legitimate interests can be used to satisfy the GDPR’s legal basis requirement—but there is more to the story. Unsolicited direct marketing is essentially marketing contact with you that was not sought or requested by you. Is legitimate interest an opportunity for direct marketing? If you have marketing consent, that marketing consent may already cover that behavioural profiling: The question to ask is: If you don’t have marketing consent what is your justification (the legitimate interest that you can prove) for collecting and processing personal data? That’s usually because if done right, it works. Progressive Media Group Limited Our Advertising Where the direct marketing involves electronic communications, however, is where things get muddy. Should you rely on consent or legitimate interest for the purpose of #directmarketing emails under the #GDPR? As with the pre-GDPR laws, GDPR creates a general principle of permitting Direct Marketing if the Legitimate Interest is shown to be valid, such as there is a reasonable expectation from the recipient, and is essentially fair. Direct marketing is broadly defined as sending information about future events, or newsletters or other information promoting an activity, product or service to individuals and specific rules apply if this is sent electronically and to people that the University does not have an existing relationship with (this will usually apply to third parties such as prospects, customers, visitors, people you think may be … As PECR does not cover postal marketing, does that mean that I can collect personal data for DM without consent? ... for use in direct marketing and for the purposes of scientific and historical research and statistics. Direct Marketing: It’s well liked. And like consent, legitimate interest is one of them. Even though it may look like GDPR compliance brought marketers many troubles, in fact, it helped to solve them. Direct marketing You must check if customers want to be contacted by fax, phone, post or email, and give them the chance to object. The Data Protection Act 2018 (DPA) defines direct marketing (DM) as: “the communication (by whatever means) of advertising or marketing material which is directed to particular individuals” This includes marketing communications sent by post, email, text messages and telephone. Under the GDPR, your data processing must meet one of the lawful bases of the processing. Sending direct marketing messages No matter which method you use for sending direct marketing messages the GDPR … GDPR is a new EU regulation to replace Directive 95/46/EC. It’s vexing because it’s easy to ignore the rest of the GDPR recitals and articles and read that sentence as “you don’t need consent for email marketing because it’s a legitimate interest”. Clearwater is a Certified Information Privacy Professional (CIPP/US) and is a licensed privacy attorney in Maine and Massachusetts. Privacy Policy Does the GDPR apply to business-to-business marketing? Direct marketing is a legitimate interest and there for does not need an opt-in - full stop, crystal clear. It also addresses the transfer of personal data outside the EU and EEA areas. Consent has historically been one of the most common legal bases relied upon for the processing of personal data. Amazon UK provides two helpful examples of this. checklist. Direct Marketing & GDPR Be compliant and build trust. Consent and legitimate interests are the legal bases most likely to be relied upon to justify direct marketing. Direct marketing is a common purpose of processing, and it includes a number of different activities—e.g., collecting personal data from potential customers, creating profiles about those potential customers and their preferences, and then sending personalized communications to them. "Legitimate interests" is a sensible concept. The principle of accountability enshrined in the General Data Protection Regulation (GDPR) is reflected in a UK regulator's proposed new code of practice on direct marketing. Brian received his JD and Certificate in Information Privacy Law with honors from the University of Maine School of Law. This is a difficult question to answer, and as most lawyers will tell you: “it depends.”. If GDPR was the only law of the land then we would be back to the wild west days of opt-out email rather than the current opt-in regime. In the UK, for example, “you can email or text any corporate body (a company, Scottish partnership, limited liability partnership or government body)” without first needing to obtain consent.6. Therefore, reliance on legitimate interests requires a certain level of comfort with uncertainty. GDPR however, is not the only European law or regulation that covers the email marketing industry. If the data subject objects, the controller only has to stop the processing for marketing purposes, but can still process the data for other purposes, e.g. This means, that in most cases, even if you are relying on legitimate interests to satisfy the GDPR, the ePrivacy Directive would still mandate consent. In fact, 11 EU member states actually allow for business-to-business (B2B) e-marketing on an opt-out basis at any time, regardless of whether it is in the context of a sale (for details, see this report by Fieldfisher). I generally think you got to the right place but I am not convinced by how you got there. Sure, GDPR does sound intimidating and the fines issued by the ICO are enough to make you rethink your entire marketing strategy. 1 The data subject shall have the right to object, on grounds relating to his or her particular situation, … GDPR and Direct marketing white paper demystifies the GDPR and ePrivacy for both DPO and a CMO, with real-life examples and useful information About He also provides public policy analysis in the areas of privacy, data security, information policy, and technology transactions. According to the GDPR, if personal data is used for direct marketing, the data subject has the right to object against such processing. Please note, direct marketing is the promotion of aims and ideals as well as the sale of products and services. This is really interesting, I've been researching the same thing. Privacy Center First of all, direct mail doesn’t require the consent of end-users. Under the GDPR, BPM can carry out direct marketing (B2C or B2B) if it has justifiable grounds for doing so. In fact, 3 household brands have already been fined. While that is true, should the e-Privacy Directive go away, then GDPR would not enforce an opt-in. However, there is an exception—marketing emails may be sent on an opt-out basis if the recipient’s details were collected “in the context of the sale of a product or a service,”5 but this exception has also been implemented differently by the EU member states. Out of all six legal bases for processing offered by the GDPR, two in particular have stood out—consent and legitimate interests—and a question we have commonly heard at OneTrust is: which of these should I rely on for the purpose of sending direct marketing emails? In determining whether to rely on consent or legitimate interests, data controllers should also take into account that, according to the Article 29 Working Party, they are “not allowed to retrospectively utilize the legitimate interest basis in order to justify processing, where problems have been encountered with the validity of consent.”8 This suggests that data controllers need to think hard about the legal basis they rely on as “it is not possible to swap between one lawful basis and another” in the event that things do not work out.9. At OneTrust, we have discussed the topic of legal basis with countless organizations as they have prepared for, and implemented, the GDPR. send direct marketing to their new address – such tracing takes away control from the individual to be able to choose not to tell you their new details. for the performance of a contract. Terms of Use. The exception is where you have bought something, given the organisation your details, and did not opt out of marketing messages. GDPR and Direct Marketing Wednesday April 4, 2018 With 25 May fast approaching – and with it the implementation of the General Data Protection Regulation (GDPR) - it’s time to talk about an activity that is key to most charitable organisations, direct marketing. 9 WP 259. This means that you have to show that you have a lawful basis under Art 6 to conduct direct marketing, and this lawful basis does not necessarily have to be consent-based. 21(2), (3) GDPR the data subject always has the right to object the processing of personal data for direct marketing purposes. It means that when you look at the overall needs and rights of data controller and data subject, there will be times where you don’t need to ask for consent to collect, store, use, disclose, process, destroy or otherwise “process” personal information. 4 WP 259. You can make plans for your direct mailing initiatives without panicking about explicit consent, as long as your data processing meets the GDPR regulations and you can demonstrate the potential benefits to the end consumer. Under Article 4(11) of the GDPR, consent is defined as “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.”, Additionally, under Article 7(1), data controllers must also be able to “demonstrate that the data subject has consented to processing of his or her personal data” and according to the Article 29 Working Party “[c]ontrollers are free to develop methods to comply with this provision in a way that is fitting in their daily operations.”2. What this statement is doing is actually reiterating that there are higher permission standards for digital marketing. Learn from their mistakes before you schedule your next marketing campaign. Direct marketing is a sales technique used by many companies. Consent vs L… We all know how effective direct mail can be. Andrew Clearwater serves as Director of Privacy at OneTrust. Emarsys UK Ltd 6 https://ico.org.uk/for-organisations/guide-to-pecr/electronic-and-telephone-marketing/electronic-mail-marketing/ The EU General Data Protection Regulation is finally here, and while its arrival has been long awaited, the discussion on how to implement its requirements does not end here. Contact Direct marketing . 2 Article 29 Working Party, “Guidelines on Consent” (WP 259), 28 November 2017, http://ec.europa.eu/newsroom/just/document.cfm?doc_id=48849. However, under the GDPR, additional conditions will need to be met, making consent more difficult to rely on as a legal basis for processing. This must be taken into account regardless of whether personal data processing was carried out prior GDPR. Let me explain: You have a collection of signup process for your marketing program. To comply with GDPR, we share a marketing checklist that we have used, which includes 9 practical tips to help you get closer to meeting those EU requirements. If GDPR was the only law of the land then we would be back to the wild west days of opt-out email rather than the current opt-in regime. To begin with, marketing under the GDPR (whether postal, phone, e-mail, SMS or any other form of marketing) is regulated exactly like any other data processing activity. Unsolicited direct marketing is essentially marketing contact with you that was not sought or requested by you. 7 GDPR, Article 21(5). In this role, Clearwater provides counsel, leadership, and guidance on all legal issues relating to OneTrust’s corporate environment. Since the introduction of the GDPR, attention to direct marketing has increased, as it has received a lot of questions about data protection. Are there any exceptions? Direct marketing can currently be carried out following a variety of opt-ins or opt-outs, but under GDPR the rules become more challenging because giving consent (or opting in) to direct marketing has specific requirements. 1 GDPR, Article 6(1)(f). Within the GDPR text one single phrase has vexed me for months: The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest. It's not saying that legitimate interests is a basis for direct marketing activities without consent. Of course there may be an option to use third-party payment services, sign up for an account, save details, sign up to marketing and more. The Information Commissioner's Office (ICO) opened a consultation on a new draft direct marketing code last week in which it has encouraged businesses to plan their direct marketing activities. Under the GDPR, marketers would need to re-establish consent (or another lawful basis) to use an individual’s email address or any other personal data for another purpose. Do not sell my information, Direct Marketing Under the GDPR: Consent vs Legitimate Interests. Think of web browsing and purchase data, linked to an individual: If you record page and product views, the device used and the location of the browsing; and you build up a profile based on this location and behaviour and it’s linked to an individual – this is a common scenario convered by the GDPR. 2 3 Contents Purpose4 The Laws 4 Marketing and Service Messaging 5 Email Marketing Basics 6 Sources of Data 8 Cookies etc. Under the GDPR, one of the ways in which personal data may be processed is where the “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”1 Implicit in this legal basis, and in combination with Article 5’s ‘accountability’ principle, is the need to document a legitimate interests assessment (LIA). Full stop! If you notify a company that you object to them processing your personal data for direct marketing purposes, it means they must stop, or not begin, sending you marketing material or contacting you for marketing purposes. Direct marketing. Put another way sending an email in the UK without an opt-in would not contravene GDPR but would contravene PECR. In fact, this is likely to be the start of an ongoing discussion for years to come, especially given the risk-based approach to compliance that is mandated by the GDPR. Obtaining consent for marketing We use opt-in boxes We specify methods of communication (eg by email, text, phone, recorded call, post) We ask for consent to pass details to third parties for marketing and name those third parties We record when and how we got consent, and exactly what it covers Cookie Policy To put it simply, consent is a data subject’s indication of agreement to the processing of their personal data, and thus putting control in the hands of the data subject. 8 WP 259. If you receive direct marketing when you have not provided your information to an organisation, or did not provide it for the purpose of marketing, this is known as unsolicited direct marketing. Direct Marketing Under the GDPR. GDPR requirements for Direct Marketing When conducting direct marketing communication, there are certain baseline requirements dictated by the GDPR and call for full compliance with: • Lawfulness, fairness and transparency principle 3 WP 259. According to Art. If a business ‘does’ marketing, it’s likely to do direct marketing of some description. At this point PECR rears its head again and tightens up exactly how Legitimate Interest can be used in some situations. Under GDPR it is usually up to you to make a positive choice to agree to further direct marketing communications by email, such as ticking a box or agreeing over the phone. If you receive direct marketing when you have not provided your information to an organisation, or did not provide it for the purpose of marketing, this is known as unsolicited direct marketing. The UK Information Commissioner’s Office (ICO) breaks this down into a three-part test: The completed LIA can then be used to demonstrate to a supervisory authority, if necessary, that full consideration was given to the interests of all affected parties, including to the potential benefits and harms that could stem from the activity. News, insights and resources for data protection, privacy and cyber security professionals. Start typing to see results or hit ESC to close, Microsoft Discovers A Second Hacking Team Exploiting SolarWinds Orion Software, As Final Stage of Brexit Approaches, Facebook Moves UK User Data to California to Escape EU Privacy Rules, Solarwinds Backdoor Affected 18,000 Customers; Microsoft Warns 40 Actively Targeted Organizations, FTC Expands Its Probes Into Big Tech’s Dealings; Nine of the Biggest Must Share Detailed Information About Data Practices. Direct marketing is defined in section 122(5) of the Data Protection Act 2018 as: “the communication (by whatever means) of advertising or marketing material which is directed to particular individuals”. Amazon UK provides two helpful examples of this. GDPR came into effect on 25 May 2018 and so you will start to see some changes in how we handle your calls and queries so that we comply with the new rules and make sure you understand what we are doing with your personal information. However, this could prove difficult from an operational standpoint. BPM will have justifiable grounds for direct marketing emails when it either: (i) has the consent of the recipient; or (ii) has a legitimate interest in sending direct marketing emails to the recipient, which are not outweighed by associated prejudice to the recipient's privacy. This means if you can identify an individual either directly or indirectly, the GDPR will apply - even if they are acting in a professional capacity. The GDPR applies wherever you are processing ‘personal data’. Through those processes you have contact details and other data provided by your customers and prospects which you use to generate or populate that marketing. Guide to Direct Marketing The General Data Protection Regulation (GDPR) comes into force on 25, May 2018, and requires anyone collecting and using personal data such as email addresses, to provide those people with details about what we are using their data for. According to the WP29, one way of doing this is to “keep a record of consent statements received” in order to show how and when consent was obtained, what information was provided to the data subject, and the workflow behind ensuring that the consent included each of the requisite elements.3 This could mean “retain[ing] information on the session in which consent was expressed, together with documentation of the consent workflow at the time of the session, and a copy of the information that was presented to the data subject at that time”4 and consent management tools can assist with generating and managing such records. Article 21 of the GDPR states that “where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing” and that “where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.” even if opt-in consent is not required before sending marketing emails, the GDPR … You need a legal basis for collecting, storing and using personal data. GDPR and Direct marketing white paper demystifies the GDPR and ePrivacy for both DPO and a CMO, with real-life examples and useful information Therefore, the decision-making process should include multiple stakeholders, including legal, privacy, marketing and executive management, to name a few, as cooperation between these groups will be vital to success. First Move operates under strict legislation policies. Includes consent and bought-in marketing lists, and telephone, email, text and postal marketing. About Where the direct marketing involves electronic communications, however, is where things get muddy. In other words, even if opt-in consent is not required before sending marketing emails, the GDPR nevertheless requires that the recipient always be provided with an opportunity to opt-out of receiving such emails. 5 Directive 2002/58/EC, Article 13(2). This will ensure we have one data protection law and increase individual rights Over the last year, the legal team at the Direct Marketing Association have been working to decipher the GDPR to ensure that marketing companies are aware of the new rules and can remain compliant. At this stage, you might be thinking that GDPR has a negative impact on the the way you do business today. Especially, in regards to postal marketing. From data capture, storing information and distributing direct mail campaigns, GDPR compliance is ensured every step of the way. But, there’s no real need to worry. We’re ready and waiting for your call. GDPR is a golden opportunity for marketers. Head of Deliverability. You must be able to prove you’ve done this. GDPR does not itself deal directly with direct marketing (other than to provide for an unqualified right to opt out of it (at Article 21(3)) and a statement in recital 47 to the effect that the processing of personal data for the purposes of direct marketing may be regarded as carried out for a legitimate interest). EU e-marketing rules can be difficult to navigate, and deciding whether to rely on opt-in consent, legitimate interests, or a combination of the two, is no easy task and can have immense impact on business operations. Privacy Policy Our Advertising He is CIPP/US, CIPP/E, CIPM and CIPT certified, and is a licensed attorney in New Hampshire. We’re here to help, contact us on 01825 983033 or email us on info@mailingexpert.co.uk Contact Us Brian Philbrook serves as Privacy Counsel at OneTrust, a software platform that helps privacy professionals operationalize data privacy compliance and Privacy by Design. Lead qualification over the phone provides a more intelligent and strategic approach that can be carried out by sales specialists, freeing up your most valuable sales resource to focus on the closing stage. Direct marketing is the Old Faithful of the marketing comms mix. Consent, on the other hand, can provide a great deal more certainty. Direct marketing under the GDPR is treated the same as any other data processing – you will need to show that you have a lawful basis for collecting and processing data from customers, with consent being one such lawful basis. Terms of Use So, this means that a company with B2B customers could potentially rely on legitimate interests for sending e-marketing to recipients in certain countries, while relying on consent in others. Data Protection Manager. Under Article 21 of the GDPR you can make a request to an organisation to stop processing your data for the purposes of direct marketing. Direct marketing is the Old Faithful of the marketing comms mix. The General Data Protection Regulation (EU) 2016/679 (GDPR) is a regulation in EU law on data protection and privacy in the European Union (EU) and the European Economic Area (EEA). For example, during an online purchase you have to provide contact, payment and address information, and the seller will have to record your transaction. But some basic information is necessary to fulfil a transaction, and is both “legitimate”, expected and should not be obstructed by a consent statement. Failure to comply with GDPR can lead to hefty fines. It would be unnecessarily obstructive, annoying and off-putting for the seller to have to explain this and to obtain a record that the purchaser understood and agreed to this data collection and use. In this way, one can perfectly attract new customers or inform existing customers of its products and services. Direct electronic marketing (e-marketing) is currently regulated under the ePrivacy Directive, which generally requires opt-in consent before engaging in such activity. Outsourcing your direct mail solves some big problems – namely ensuring you stay GDPR complaint. Recital 47 of the GDPR says: “The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest.” And that’s where it ends; the teaser at the end of the credits. Hear from the Customer Data Council’s Thought Leadership and Best Practice Hub about the wider implications of the, Why phone-qualified leads are the key to revenue creation, DMA Customer Data Council: Responding to the ICO'S Experian Enforcement Notice. Unsolicited direct marketing. Comply to GDPR with our Direct Mail Marketing Services. As with the pre-GDPR laws, GDPR creates a general principle of permitting Direct Marketing if the Legitimate Interest is shown to be valid, such as there is a reasonable expectation from the … Assess your business in the area of direct marketing in line with the Privacy and Electronic Communications Regulation (PECR) and data protection legislation. To OneTrust ’ s no real need to worry are processing ‘ personal data for DM without consent into! Ensuring you stay GDPR complaint Next marketing campaign convinced by how you got to the right but... Philbrook serves as Privacy counsel at OneTrust you are processing ‘ personal data because it is Old... 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