How Strong is your explicit consent when collecting data?
There is allot of talk at the moment both in Ireland and the UK about opt in, opt out, explicit consent, does the original consent match the actual data usage, is it relevant, have you explained the definition of third party usage clearly enough etc etc
There are seminars, debates, events, meetings and allot of chat about Data Compliance and the impending EU Wide legislation coming down the track in the next year or so.
Whatever way we want to interpret the compliance requirements the bottom line is transparency around explicit consent is going to get allot of attention over the coming months and you can either wait to see what happens and be told your data is not useable or you can do something about it now.
Here are a few suggestions:
Add a dynamic link in your consent statement listing third party brands or industry sectors that may use the data in the future. Yes it could run to allot of brand names but at least the user has the choice to review the brand names before ticking that opt in box.
Legacy Data – You or your third party clients are contacting the data all the time so include a dynamic link of third party brands in the contact touch points and again request further consent.
We have found very little drop off from using the techniques mentioned above.
The decisions around compliance are ultimately yours to make but our view is not to wait until the legislation tells us to do so anyway.
Please note these are only our views, we are not data protection consultants but as Ireland’s leading Data Collector, since introducing the dynamic link process we have not received one complaint from a data subject.