Sending emails post-GDPR requires REaD Group to consider the requirements of both GDPR and PECR. REaD Group is named in the Fair Processing Notices (FPN) at the point the email address and consent are collected. REaD Group can therefore send emails to individuals in compliance with PECR on the basis of this consent. This means any client email campaign will be sent by REaD in association with the client. REaD Group must be the sender of the campaign as REaD Group holds the consent.
For Performance Marketing campaigns, this means that REaD Group is the Data Controller when the campaign is broadcast and the client becomes a data controller (and holds their own Consent) when an individual registers on the client’s landing page.