We find that clients often have a large customer database but only contact a section. Do you think that it is reasonable for the client to maintain the accuracy of the whole base and not just the contactables?

We find that clients often have a large customer database but only contact a section. Do you think that it is reasonable for the client to maintain the accuracy of the whole base and not just the contactables?

Article 5 (1) (d) places a high burden on a data controller to ensure that personal data is kept accurate and up to date. All data processed (this includes mere storage) is subject to the same requirement and measures should be in place to regularly screen all data for changes. If a client maintains a name and address on its base then use of REaD’s suppression suite and its associated enrichment products is good evidence of having taken ‘every reasonable step’.