DATA PROTECTION AND MARKETING
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1 DATA PROTECTION AND MARKETING 13 February 2014 Janine Regan Solicitor
2 Our Team Speechly Bircham is an ambitious, full-service law firm with over 250 lawyers, headquartered in London. We work with business and private clients across the UK and internationally and focus on the financial services, private wealth, technology, real estate and construction sectors We have offices in Paris, Luxembourg, Zurich and Geneva Our Data Protection & Information Law team provide a range of expertise on data privacy audit, compliance, risk management, information security and data breaches We are listed in Chambers 2014 and Legal 500 as a leading law firm for Data Protection and have advised on this area of law since 1983 What I liked was the fact that the team was very willing for us to see itself as an extension of our existing in-house team. I like the way it integrated members sat alongside and guided us. That was what impressed. Robert Bond and his team have always provided comprehensive, practical advice on a timely basis. Their knowledge of the EU regulatory scene, including experience with specific agencies, as well as privacy issues globally has been instrumental in establishing our privacy policies and procedures. 2
3 Janine Regan CIPP / E Janine advises on global data protection compliance and outsourcing projects for multinationals in sectors such as financial services, pharmaceutical, construction and marketing and advertising. She advises on filings with relevant data protection authorities, processor / controller agreements, trans-border flows of personal data, data breaches, data protection provisions in outsourcing contracts and has provided tailored training for clients and for PDP training. Janine is a regular presenter on Speechly Bircham's data protection webinars and contributes regularly to internal and external publications such as Data IQ, the Society of Corporate Compliance and Ethics, the Society for Computers and Law and Bloomberg BNA. She also possess the Certified Information Privacy Professional (Europe) (CIPP/E) qualification. 3
4 TOPICS Consumers and privacy - The Spook factor - Dispelling the myths Current position - Data Protection Act PECR Future position under the proposed dp regulation - Legitimate interest - Consent - Profiling - Purpose limitation - Children - Data Protection Compliance Certification - Iconography US CAN SPAM Act Canada s anti-spam law Top 5 things you can do now! 4
5 CONSUMERS AND PRIVACY Do people care about their privacy? 5
6 CONSUMERS AND PRIVACY Polling Question What is the most important factor when deciding whether or not to share your personal information? - I get special offers on goods/services - I trust that the organisation will protect my personal information - It s a well known brand - Friend/family/online recommendations - I receive adverts that are of interest/relevance to me 6
7 CONSUMERS AND PRIVACY 58% of people cite trust as being the most important factor when deciding whether or not to share their personal information highlighting that The understanding and application of privacy is not an academic exercise; it has a measurable impact on corporate risk and customer relationships 7
8 CONSUMERS AND PRIVACY The Spook Factor Recently I had an eerie online experience after spending some time surfing the web. I received an from a company who s website I had visited earlier in the day. Thanks for stopping by :) was the subject line of the . (And yes, the emoticon was included.) Kudos to them for at least catching my attention as I was immediately curious to where I had stopped by, since I was glued to my computer screen all day long. With my interest peaked, I continued reading, Thanks for stopping by our website and checking out our resources Instantly the 1984 Rockwell song Somebody s Watching Me comes to mind. Yes, there are definitely benefits to web analytics and knowing where traffic is coming from, but if you re improperly using that information to contact (or stalk) visitors, you re going to come off more creepy than genuinely helpful. - Shoutoutstudio 8
9 CONSUMERS AND PRIVACY V 9
10 CONSUMERS AND PRIVACY Dispelling the myths Data protection compliance = business prevention = can t do anything The proposed data protection regulation = going to make everything EVEN worse 10
11 CURRENT POSITION Implied consent Opt-out Marketing calls Marketing texts and s - The soft opt-in - B2B Buying and selling marketing lists Example of implied consent and opt-out: By submitting this registration form, you indicate your consent to receiving marketing messages from us. If you do not want to receive such messages, un-tick this box: 11
12 CURRENT POSITION Cookie Law Express v Implied consent? Enforcement action by the Spanish data protection authority against two companies for non-compliance - Triggered by complaints by individuals - Cookies used not uncommon - Takeaway: the level of detail required to be contained in cookie statements is high otherwise consent will not be valid - Total amount of fine EUR 3000 but - It is believed that the Spanish DPA is currently investigating 19 other companies for cookie law non-compliance 12
13 POLLING QUESTION Which law states that passive/soft opt-in consent (i.e. where there is a preexisting relationship between individual and organisation) expires after a certain period of time and has to be renewed? - Canada's anti-spam law - US CAN SPAM Act - Privacy and Electronic Communications Regulations - The proposed general data protection regulation - Data Protection Act 1999 (Ley Orgánica 15/1999 de Protección de Datos de Carácter Personal) 13
14 POLLING QUESTION How concerned are you about the impact that the proposed data protection regulation will have on your organisation s marketing activities? - Very concerned - Somewhat concerned - I don t know yet if we should be concerned - I m not that concerned 14
15 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 7 main areas for consideration: 1. Legitimate interest 2. Consent 3. Profiling 4. Purpose Limitation 5. Children 6. Data Protection Compliance Certification 7. Iconography 15
16 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 1. Legitimate Interest 6 grounds - Consent - Performance of a contract - Legal Obligation - Vital interests - Public interest - Legitimate interest of the controller or in the case of disclosure, by the third party to whom the data is disclosed, and which meet the reasonable expectations of the data subject based on his and her relationship with the data controller 16
17 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 1. Legitimate Interest The legitimate interest of the data controller may provide a legal basis for processing, provided they meet the reasonable expectations of the data subject based on his or her relationship with the controller The processing of personal data for the purpose of direct marketing for own or similar products and services or for the purpose of postal direct marketing should be presumed as carried out for the legitimate interest of the controller, or in case of disclosure, of the third party to whom the data is disclosed, and as meeting the reasonable expectations of the data subject based on his or her relationship with the controller if highly visible information on the right to object and the source of the personal data is given This would need careful assessment in particular where the data subject is a child, given that children deserve specific protection 17
18 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 1. Legitimate Interest The processing of business contact details should be generally regarded as carried out for the legitimate interest of the controller, or in case of disclosure, of the third party to whom the data is disclosed, and as meeting the reasonable expectations of the data subject based on his or her relationship with the controller The same should apply to the processing of personal data made manifestly public by the data subject. Does this mean data controllers have more flexibility to use personal information that is publically available on social media?? 18
19 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 2. Consent Consent must be explicit and opt-in Pre-ticked boxes or continued use or a service are not indications of freely given consent - What to do in practical terms? - Review your consent boxes - Make sure none are pre-ticked and that all provide a link to the privacy policy 19
20 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 2. Consent It shall be as easy to withdraw consent as to give it - What to do in practical terms? - Do you have opt-out consent mechanism at the bottom of your mailshots? - Does it work? - Does your website have a contact number to the DPO? Click here to unsubscribe from this list or to update subscription preferences 20
21 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 2. Consent Data protection policies should be as clear and transparent as possible. They should not contain hidden or disadvantageous clauses - What to do in practical terms? - Ask your non-legal spouse / teenage child to read and see if they understand the privacy policy - If they don t it needs to be re-drafted - Anything even slightly disadvantageous should be drawn out and express consent obtained from the data subject Lorem ipsum dolor Lorem ipsum dolor sit amet, Speechly Bircham ( ut secundum usum esse in nostra website ), cuius tactus est in rebus sit. Maximus alio notitia ad nos obsequentes / aut quod sub alio notitia Adnuite Aenean ut uos, qui in modum et processit ad fines de quibus in sequentibus. Aliquam lacus ac tituli secreto servato policywe informatio commissa te ad nos. Hic describit ipsum dolor sit amet, vitae moribus ac de alio notitia et notitia collecta, in sensu proprio de te per se, et / vel etiam ad ipsum. Termini ' alio notitia et notitia hominum sensus, se refert ad vos mauris Data Protection Actus MCMXCVIII quod definitur. Nam in hoc, de quo agitur, ut dolor, vel elit, in quibus, vel sensitiva notitia, ut habetur Num. Mutationes commentationum quae huic vitae significetur continue policywe meliori modo communicandi et novis features ut lobortis elit, et quae meritis nostris. Iens mutationes ex illis mutatio nulla lex et natura mutabilis nostra tempor mutabit consuetudines notitia protectione. Mauris elit ac si quando mutantur, nos te certiorem. Hortamur vos Lorem ipsum dolor saepius. Aliquam quis elit in risus addressesyou etiam eligere ad consilium, opera, a nobis nec velit. Aut si quis instituat, rogamus ut indicabunt tibi nomen Praesent oratio, ut inscriptio et telephonium numerus identitatem notitia requiritur ad comprobandum usum pecuniam lavare. Vel potest dici, interrogate quis in ministerio ad eiusmodi notitia ut enable nos ad vos. Tincidunt vel electronice aut providere repono notitia. Supplementum adipiscing interdum personis, quae ex notitia. Nam, si vel millia Praesent zip codes, recipiantur, ut alium usum software ut clavis 21
22 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 2. Consent Consent can not be given for the processing of personal data of third parties - What to do in practical terms? - Review where in the business you collect personal data from third parties and how this policy can be adapted to be compliant with the regulation 22
23 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 2. Consent Additional personal data that are not necessary for the provision of a service should not be required for using the service. - What to do in practical terms? - Review which fields in forms you asterix Name* Address* Position* Marital status* address* Number of children* Annual household income* Likes marmite* 23
24 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 3. Profiling Data subjects have the right to object to profiling in a highly visible manner Profiling which leads to measures producing legal effects only if: - Necessary for contract - Expressly authorized by a MS - Data subject s consent What exactly are legal effects?? Profiling that has the effect of discriminating against individuals on the basis of race or ethnic origin, political opinions, religion or beliefs, trade union membership, sexual orientation or gender identity, or that results in measures which have such effect, shall be prohibited 24
25 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 4. Purpose Limitation Consent shall be purpose-limited and shall lose its validity when the purpose ceases to exist - What to do in practical terms? - Check your privacy policy does it list every purpose for which you process personal data? - Are people provided with a link to the privacy policy whenever their personal data is collected? - Set up a customer record provenance field stating when and how personal data was collected and agreed purposes 25
26 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 5. Children Offering goods or services - directly to a child - below the age of 13 Privacy policy must be in age appropriate language Requires consent of child s parent of legal guardian 26
27 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 6. Data Protection Compliance Certification Certification that the processing of personal data is in compliance with the Regulation known as: - Voluntary - Affordable - Transparent and not unduly burdensome process - Available to controllers and processors - Valid for 5 years - Electronic register of all valid and invalid certificates - Third party regulator accredited auditors - Data transfers New revenue stream for the regulators? Highlights Christopher Graham s statement at launch of ICO general report last year: Privacy is a competitive advantage 27
28 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 7. Iconography What do you think these icons mean?? 28
29 THE PROPOSED DATA PROTECTION REGULATION AND MARKETING A DETAILED ANALYSIS 7. Iconography No personal data are processed for purposes other than the purposes for which they were collected No personal data are collected beyond the minimum necessary for each specific purpose of the processing No personal data are retained beyond the minimum necessary for each specific purpose of the processing 29
30 OUTSOURCING MARKETING Ensure the usual preventative and protective steps are taken if outsourcing mailshots etc Security audit at beginning and during contract term Must be reviewed from DP perspective Privacy Impact Assessment Mandatory data protection provisions in contract Additional data protection and security provisions in contract including NO EXCLUSIONS FOR LOSS OF DATA Address any data transfer issues 30
31 US CAN SPAM ACT Controlling the Assault of Non-Solicited Pornography And Marketing Act 2003 Recipients of unsolicited commercial must be able to opt out of receiving future solicitations. The Federal Trade Commission provides complaint forms for consumers to report violations of the CAN SPAM act Can be fined up to $300 per by the Federal Trade Commission for noncompliances 31
32 CANADA S ANTI-SPAM LAW Canadian Anti-Spam Legislation Comes in to force on 1 July 2014 Covers all commercial electronic messages, which are any electronic message that encourages participation in a commercial activity, regardless of whether there is an expectation of profit Potential fines of up to $10million Requires explicit opt-in consent in most circumstances If able to rely on implied consent, it will expires after 6 months / 2 years 32
33 TOP 5 THINGS YOU CAN DO NOW 1. Privacy Policy and Cookie Review 2. Eliminate pre-checked boxes 3. Review your vendor contracts 4. Create customer record provenance field for all new customers 5. us for our Data Protection Health Check Questionnaire to obtain a free assessment of how your organisation can start to prepare for the Regulation and what we can do for you 33
34 RELEVANT PUBLICATIONS Top 10 things marketers need to know about the latest draft of the regulation Outsourcing the processing of personal data 10 steps to take (relevant if you are engaging a third party marketing company) 34
35 FURTHER INFORMATION For more information on our services, please contact: Janine Regan
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