GDPR - Legitimate interest?
GDPR - Legitimate interest?
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moustachebandit

Original Poster:

1,336 posts

173 months

Tuesday 29th January 2019
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Currently swatting on on GDPR in preparation of running some outbound marketing comms (email / DM)

We currently have access to a contact list of around 5k, over 2/3rds of those we have an ongoing business relationship with, and they access our service multiple times throughout the year. Before I came on board a GDPR email went out asking, out of 5k, 2k opened, 1k consented, 3k didn't open at all.

The mail out was a one time only affair, and the accounts who didn't consent / or open the email weren't chased up.

As part of the company's marketing plan I want to implement some outbound comms to supplement the work the sales reps do. The plan is to create a suite of emails for new product launches, product trends, promotional offers, product line closeouts, win backs etc.

Under legitimate interest it appears we are ok to mail these customers, as long as they also have an opt out option? However I want to check my understanding with someone on here who might have first hand experience / understanding on how legitimate interest works.

Last thing I want to do is run a campaign which could cause issues for the business. Whilst I seriously doubt the ICO will give a hoot. As I am setting out the new digital comms process I want to ensure we are compliant and aligned with the guide lines.

Any feedback is appreciated.


Australiam

277 posts

159 months

Tuesday 29th January 2019
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I've pm'd you.

Whoozit

3,882 posts

299 months

Tuesday 29th January 2019
quotequote all
Interested to hear the answer as I have a similar fact pattern last year, although additionally a) it's B2B business and b) every communication since inception has an opt-out. For the record, I received GDPR advice and was told legitimate interest was relevant, although not riskless, also unlikely to be in the ICO's cross hairs.

strath44

1,370 posts

178 months

Thursday 31st January 2019
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+1 Keen to hear any clarification on this!

moustachebandit

Original Poster:

1,336 posts

173 months

Friday 8th February 2019
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Thought I would follow this up. Don't have any hard and fast guidance and still need to make some calls on the matter. However it seems that the soft opt route will suffice, which basically means we give customers the option to unsubscribe from the mailings.

Digging deeper legitimate interest should suffice for us at least - as the customers have ongoing business relationship with us and its B2B.

To ensure I am covering ourselves I am also processing the contact lists to strip out obsolete customers & accounts that we haven't worked with for a few years.

Hopefully that info is of some use to somebody.