Do REaD Group need to name all of its clients in its Fair Processing Notices?

Do REaD Group need to name all of its clients in its Fair Processing Notices?

No, it would be impossible for REaD or any other organisation in the industry to do this. However, REaD takes a number of steps and has implemented various safeguards to ensure the highest level of transparency for data subjects, including providing a comprehensive fair processing notice that makes clear that their personal data will be processed for the purposes of direct marketing by both REaD and the third parties accurately and comprehensively described. It is important for clients to bear in mind, however, that upon receipt of a list from REaD, the recipient is considered a data controller and must takes steps to comply with its own legal obligations as a data controller. This could include, for example, ensuring it has considered and decided upon an appropriate legal basis for handling and use of the personal data, using the information received from REaD in an appropriate and reasonable manner (and one expected by the data subject bearing in mind the information provided in the REaD fair processing notice) and by providing the data subject with its own fair processing notice when first making contact.