How to avoid violating GDPR when using lead lists?
- Using purchased or third-party lead lists under GDPR requires careful compliance work:
- Verify the source:
- How did the provider collect this data?
- Was consent obtained for third-party marketing?
- Can they provide documentation of consent or lawful basis?
- Reputable vendors provide this information; evasive answers are red flags
- Establish your own lawful basis:
- You cannot rely solely on the vendor's basis
- Conduct your own legitimate interest assessment if using that basis
- Document your analysis and reasoning
- Provide transparency:
- When contacting list recipients, explain where you got their data
- Explain why you're contacting them
- Provide privacy notice access
- Honor rights:
- Respond to access requests (what data you hold)
- Process erasure requests (right to be forgotten)
- Remove people who object to processing
- Data quality:
- Outdated lists are both legally risky and deliverability hazards
- Verify data is current and accurate
- Purchased lists often contain spamtraps and invalid addresses
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