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.
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