Please note; The existing Privacy and Electronic Communications (EC Directive) Regulations (PECR) continues to apply and runs alongside the GDPR. Click here for information on PECR.
Data leased from Joined Up Marketing is for the sole purpose of B2B (business to business) direct marketing. Our data lists contain business contacts where no opt-out has been made - we do not supply B2C/consumer data.
We regularly screen our B2B data lists both ourselves and via our data supply partner for contacts who are sole traders/partnerships.
In order to comply with GDPR, the B2B data contacts must be processed lawfully by us and by the buyer (lessee) of the list.
Our legal basis for processing these business data lists is 'legitimate interest' for the sole purpose of direct marketing. We consider this to be the appropriate lawful basis, because:
- The processing is of business contact details only and there is a demonstrable low impact on the privacy of the individual;
- The data processed is limited to names of senior managers, directors and proprietors, their job titles, company addresses, business phone numbers (landline only), business email addresses.
- B2B direct marketing is a reasonable and proportionate method of processing to achieve commercial objectives;
- The B2B data subjects might reasonably expect to receive business marketing of a relevant nature to their business email address or place of business
As such, we consider the processing to be transparent and fair.
The data subjects may easily indicate that the data processing is against their wishes, by unsubscribing from marketing emails
Consent (or 'opt-in') may or may not have been obtained for each contact on these lists, however consent is not legally required for B2B contacts of incorporated organisations (direct marketing by email, mail or telephone (live calls)).
We conclude that the rights and freedoms of the data subjects in question are not disproportionately or negatively infringed upon through this course of processing.
Where a B2B contact objects to this processing, we will stop processing for this purpose (GDPR compliance and PECR compliance i.e. 'opting out')
Joined Up Marketing is a member of the Direct Marketing Association and is registered with the Information Commissioner's Office (ICO), data protection registration number Z3082990 (registered March 2012). David Archibald is the designated data controller. .