How to legally process scraped or enriched contact data?

Scraped and enriched data presents significant legal challenges under modern privacy frameworks.

Public doesn't mean freely usable: Data being publicly available (LinkedIn profiles, company websites) doesn't automatically provide legal basis to process it for marketing. GDPR requires lawful basis regardless of data source.

Scraping risks:

May violate website terms of service

Could breach Computer Fraud and Abuse Act (US) or similar laws

Violates robots.txt directives in many cases

Platforms actively pursue scrapers legally

Enrichment considerations:

Combining data from multiple sources creates new processing

Each data element needs lawful basis

Aggregated profiles may reveal more than individuals intended

Documentation requirements:

Document where each data element came from

Conduct legitimate interest assessment

Prepare to explain and justify your basis if challenged

Transparency obligations:

Under GDPR, individuals have right to know how you obtained their data

Scraping LinkedIn may not satisfy recipient expectations

Be prepared to answer and potentially delete data on request

Consult legal counsel before building programs on scraped data.