What is enrichment transparency and how to disclose it?
Enrichment transparency means being open about how you obtained and expanded contact data. Under GDPR, this isn't optional.
What to disclose:
That you have their personal data
Where the original data came from
What additional information you added through enrichment
Why you're contacting them (your lawful basis)
How they can access, correct, or delete their data
When to disclose:
At first contact with the individual
Or within one month of obtaining the data, whichever comes first
If you obtained data from a source other than the individual directly
How to disclose:
Brief explanation in the email itself
Link to your privacy policy with full details
Contact information for data-related inquiries
Example language:
Your contact information was obtained from [source]. We're reaching out because [reason]. You can learn how we handle your data or request deletion at [privacy policy link].
Transparency builds trust and demonstrates compliance. Evasiveness triggers suspicion and potential complaints.
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