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It isn't enough anymore to put this into a PP. If the subscribers did not gave consent for this it cannot be tracked (at least I think).

by tibu 8y ago

adulau 8y ago
If a data-subject subscribes to a mailing-list by giving your email and you have a "request for consent shall be presented in a manner which is clearly distinguishable from the other matters" which can be clearly describe in your privacy policy, you are totally inline with the article 7 for the condition of consents.
DanBC 8y ago
Consent is only one reason for data handling. There are others. Consent doesn't always need to be given. https://twitter.com/bainesy1969/status/995370110587154433 https://twitter.com/bainesy1969/status/995370110587154433
- stingraycharles 8y ago
  Only if it is strictly necessary in order to conduct business, and no longer than that. E.g. using cookies for managing a session’s shopping cart. Obviously tracking emails for marketing purposes is not allowed.
  - adulau 8y ago
    Tracking emails for marketing purposes can be seen as a legitimate interest. As long, it's describe to the data-subject and they give their consent, it's allowed. Recital 48 is giving some explanation: "The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest." https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679&from=EN https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CEL...
    - stingraycharles 8y ago
      I really think the answer to this question at the moment depends upon the person asking. All I read in recital 48 is that PII might be shared within a group of companies that fall under the same holding. IANAL, but I spent the past 2 years as CTO of an EU-based analytics company becoming compliant with GDPR, and consider myself quite informed on the topic. I would tread more carefully than what you are suggesting.

It isn't enough anymore to put this into a PP. If the subscribers did not gave consent for this it cannot be tracked (at least I think).

by tibu 8y ago

It isn't enough anymore to put this into a PP. If the subscribers did not gave consent for this it cannot be tracked (at least I think).

adulau 8y ago

If a data-subject subscribes to a mailing-list by giving your email and you have a "request for consent shall be presented in a manner which is clearly distinguishable from the other matters" which can be clearly describe in your privacy policy, you are totally inline with the article 7 for the condition of consents.

DanBC 8y ago

Consent is only one reason for data handling. There are others. Consent doesn't always need to be given. https://twitter.com/bainesy1969/status/995370110587154433 https://twitter.com/bainesy1969/status/995370110587154433

stingraycharles 8y ago
Only if it is strictly necessary in order to conduct business, and no longer than that. E.g. using cookies for managing a session’s shopping cart. Obviously tracking emails for marketing purposes is not allowed.
- adulau 8y ago
  Tracking emails for marketing purposes can be seen as a legitimate interest. As long, it's describe to the data-subject and they give their consent, it's allowed. Recital 48 is giving some explanation: "The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest." https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679&from=EN https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CEL...
  - stingraycharles 8y ago
    I really think the answer to this question at the moment depends upon the person asking. All I read in recital 48 is that PII might be shared within a group of companies that fall under the same holding. IANAL, but I spent the past 2 years as CTO of an EU-based analytics company becoming compliant with GDPR, and consider myself quite informed on the topic. I would tread more carefully than what you are suggesting.