Email Data Policy

We are conducting a campaign of direct marketing within the meaning of the Data Protection Act 2018, s.122(5), in which you are a recipient.

The protection of personal data and the delivery of marketing by email are governed in the United Kingdom by separate but related laws. In addition to data protection legislation such as the GDPR and Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003, also known as "PECR", is the principal law that covers direct marketing by email.

In terms of the PECR, the subscriber is the individual or legal entity that is party to a contract with a provider of public electronic communications services. It specifically defines a corporate subscriber as, essentially, an incorporated company. This is different to the usual meaning of “subscriber” when discussing mailing lists. ICO guidance clarifies that this includes public bodies and Scottish partnerships, but not sole traders or members of an ordinary partnership, as they are not incorporated. In terms of email, the subscriber is held to be the individual or organisation for whom the email service is operated. Any of a corporate subscriber's email addresses would be a corporate email address. If a corporate email address contains a person's name or distinctive job title, it is known as a personal corporate email address. This is not the same as a strictly personal email address pertaining only to a private individual.

Your email address has been identified as pertaining to a "corporate subscriber" within the meaning of PECR Regulation 2. Regulation 22 prohibits the delivery of unsolicited marketing messages by email to "individual subscribers", with certain exemptions such as for existing customers. However, this does not apply to corporate subscribers. The UK's data protection supervisory authority, the Information Commissioner's Office or ICO, has published guidance clarifying that consent is not required to email business email addresses. Data protection laws still apply to any personal data being stored or used in relation to that address, such as if your email address contains your name, or a job title through which you could be easily identified. Such personal data is lawfully processed under Art. 6(1)(f) of the GDPR, about which more information is provided below.

We have partnerships with data providers and can provide detailed information about the source of your contact record upon request. You can find contact details for such a request further down the page.

Our direct marketing emails include an unsubscribe link to a page where you can check the email address and request that it be unsubscribed from further such emails.