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Direct Marketing Policies & Client Relationship Databases in Recruitment

on Thursday, 05 November 2020.

Direct marketing is crucial - keeping in touch with those on your database and making sure you have contacted any potential leads. It's likely that your database will need a refresh to take account of changes to people's circumstances.

However, ensuring that your database is compliant with the GDPR and ensuring your marketing approaches are consistent with the Privacy and E-Commerce Regulations (PECR) will ensure your business is seen as professional and isn't tarnished by the poor practice of some in your industry. Not to mention ensuring you are not subject to any fines for non-compliance.

While we wouldn't recommend that you rely on consent for processing personal data under your privacy notice, other than in two tightly defined circumstances, the PECR requires businesses to collect GDPR standard consent from individuals if you want to e-market to them. This includes calls, texts, messages on social media as well as sending emails.

Consent must be:

  • informed
  • specific
  • freely given

The person can change their mind and withdraw their consent at any time.

Coronavirus Legal Advice

When Is Consent Not Required?

  • If you are contacting a person via their business address or contact details (but not a sole trader) about something which is related to their role.
  • If the person has previously and recently used your services. These two exceptions are not generally seen as best practice.

You should keep clear records of consent and refresh lists frequently so as to ensure those who have recently opted out do not receive unsolicited contact.

Another tip is to check you are adhering to the best practice in your marketing communications by giving the person the choice to opt out every time you contact them with unsolicited marketing (ie information about your brand that has not been specifically requested).

If you need more detailed advice on your marketing approaches or how to obtain consent, feel free to contact us on the details below.


If you require specialist advice relating to your direct marketing policies or management of client data, please contact Sarah Thorley (07387 025 970) or Rose Lucas (07384 813 073) in our Recruitment team, or complete the form below.

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