What is consent chaining (multiple data collectors)?

Consent chaining refers to the practice of passing subscriber consent from one data collector to another, typically when data is acquired, shared, or sold between organizations. In this scenario, the original collector obtains consent, then transfers the subscriber data (along with the claim of consent) to a second party who relies on that inherited consent to send their own marketing communications. This practice is common in affiliate marketing, lead generation, and data broker arrangements, but it raises significant legal and ethical concerns under modern privacy regulations.

Under GDPR, consent chaining faces severe restrictions because consent must be specific and informed. A subscriber who consents to receive emails from Company A has not thereby consented to receive emails from Company B, even if Company A shares their data. For consent to be valid for a secondary recipient, the original consent must have specifically named or described the secondary recipient and the purposes for which they would process data. Generic language like "our partners" or "selected third parties" is generally insufficient. The usubscriber must understand who will contact them and why before consent can legitimately extend to those parties.

From a deliverability perspective, consent chaining is risky regardless of its legal status. Subscribers who don't recognize your organization, didn't knowingly sign up for your list, and don't expect your emails are far more likely to mark messages as spam, ignore them, or unsubscribe immediately. ISPs and mailbox providers see these engagement signals and adjust inbox placement accordingly. Even if you acquire legally valid consent through proper disclosure, the practical reality is that consent-chained contacts perform poorly. Consent, like trust, doesn't transfer cleanly between strangers-what looks valid on paper may still result in subscribers who don't want to hear from you.