In a recent decision, the Icelandic Data Protection Authority (DPA), Persónuvernd, upheld the legitimate interest of companies sending customer satisfaction surveys and cross-referencing caller information. The case involved the insurance company VÍS and one of its customers and addressed whether a data controller could lawfully cross-check a (anonymous) caller’s phone number with its customer database […]
legitimate interest
Unsolicited Email Marketing – Ensuring compliance worldwide
In today’s interconnected world, businesses increasingly depend on email marketing to effectively expand and engage their international customer base. However, when sending unsolicited emails internationally, balancing data protection obligations and the requirements of local laws is crucial for maintaining compliance. This article delves into best practices, outlines the most appropriate legal bases, and examines the […]
Legitimate Interest: new CJEU ruling challenges Dutch Authority’s strict interpretation
On October 4, 2024, the Court of Justice of the European Union (CJEU) issued a ruling in the case C-621/22, addressing whether purely commercial interests can qualify as a legitimate interest for processing personal data under Article 6 para. 1 lit. f of the General Data Protection Regulation (GDPR). This decision challenges the strict stance […]
Digital marketing as a legitimate interest? Dutch DPA clarifies.
On the first of November the Dutch DPA (Autoriteit Persoonsgegevens) has tried to shed some more light on the subject of the legitimate interest as a lawful ground of processing. Besides reconfirming the common understanding and best practices, the Dutch DPA clarifies the legal basis for direct marketing if and to the extent, that the […]