M

Member

Speaking in the House of Lords on 21 January 2025

Debate

Data (Use and Access) Bill [HL]

Contribution

My amendment seeks to make explicit what good direct marketing best practice actually is in terms of transparency and proportionality. If a direct marketing provider combines open electoral register data with other data in order to create a piece of targeted direct marketing, they must fulfil their transparency obligations when they first acquire the non-OER personal data, so that consumers can exercise their data rights over that data as well as the OER data. They must be further transparent that they are combining data from the OER with other data sources, via their privacy policy and by including a data notification in their direct mail pack. This would enable the consumer to know what is being done with their data and who to contact should they wish to exercise their other data rights, but not to be bombarded with notifications without receiving any direct marketing. It would also allow direct marketing companies to continue to make use of the OER in producing targeted direct marketing campaigns for clients, as they have been doing for decades.

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