Member

In Committee, the Minister, the noble Baroness, Lady Jones of Whitchurch, was clear that using OER data on its own would not require prior notification; so far, so good. However, she was less reassuring where OER data is combined with any other data; she implied that notification of intended use would then be required. Let me give your Lordships a practical example. I think this means that, if I want to send direct marketing to everyone in a particular postcode area who is in the open electoral register, that is fine. However, if I want to combine the OER data with additional data—for example, telling me who in that area likes jazz music, in order to market a jazz concert at the local music venue—I would in theory have to pre-notify that I intend to combine the OER data with the additional data to create a tailored campaign. That is before I actually send the direct marketing. It is really hard to see how that is good for anyone. It does not seem to be proportionate. While you could argue that it increases transparency, in practice it will mean that people receive more untargeted communication or, worse, a very strange communication about potential communication. I can see I am losing my audience already.