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MC likely acts as a data processor on behalf of it's clients - therefore from a GDPR perspective consent requirement rests on their clients which would be data
by jtmcmc 9y ago
MC likely acts as a data processor on behalf of it's clients - therefore from a GDPR perspective consent requirement rests on their clients which would be data controllers.
that being said - MC and other reputable ESPs have for awhile been much more concerned about consent for deliverability reasons
- mprev 9y agoProcessors have plenty of liabilities under the GDPR. https://www.taylorwessing.com/globaldatahub/article-obligations-on-data-processors-under-gdpr.html https://www.taylorwessing.com/globaldatahub/article-obligati...
- jtmcmc 9y agoabsolutely - but they do not have to ensure that data they process is properly consented - that is the role of the data collector.