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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