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GDPR Update – Third Party Data

As of today there is still no movement on the ICO’s guidance, when it comes to naming the company we’re processing data for. Recital 42 states that the recipient “should” know the identity of the data controller (your client). The important word here is “should”, rather than “must”.


We work very closely with the DMA to ensure we’re 100% compliant when it comes to GDPR. During a recent DMA web conference call, their Legal team suggested that the ICO may still loosen further their final version of guidance for GDPR; keeping it closer to the Data Protection Act’s current form. This means that businesses can opt in prospects to a “narrow band” of topics or subjects (such as Internet Security, or Financial Technology). Their details can then be rented out on a subscription basis. If the ICO changes that “should” to a “must”, you’ll be in need of a serious overhaul when it comes to your business model if you’re using this opt in method. Here are some best practice tips on how to make these changes:


Include Opt In Wording in Call Guides


If your business is using the consent method as part of it’s data strategy, you must ensure that the script / wording around consent and the opt in process is recorded in all communication processes that you use – including call guides when opting in via telephone. This is to ensure that there is a documented record of the entire process, and specifically of what is being said. If you do not record your calls, this will be of particular importance since you need to provide evidence of what your callers are being directed to say.


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Avoid Using Gated Content To Obtain Consent


People need to be given the opportunity to opt in, in a simple process that outlines why their data is being collected and how it will be used. Content should not be withheld if an email address is not provided, which is why the whole notion of gated content may become more difficult to work with over time. It’s advisable to get into good habits now and avoid using gated content, while you still have time to adopt other recommended approaches.


Positively Explain Why You Are Collecting Data


By using a short video or infographic in addition to your Privacy Statement, you can explain why you want to contact your subjects as well as how you will use their data. This is a great way to connect with potential prospects, build trust, and encourage them to opt in whether by consent or legitimate interest.


To ensure your company has made the necessary changes to all methods of communication when it comes to opting in, contact us today.

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