Performance Marketing

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.

 

A data controller determines the purpose and means of processing personal data, whereas a data processor is responsible for processing data on behalf of the controller. 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 when an individual registers on the client’s landing page. The data processor would be the email service provider which is processing the campaign on behalf of REaD Group.

REaD Group are named in the Fair Processing Notices (FPN) at the point of data collection.  To ensure there is transparency in accordance with GDPR, REaD Group must be the sender of any communications. It must be absolutely clear to the recipient that the communication are from REaD Group (on behalf of our client/on your behalf).

As REaD Group are the Data Controller and to comply with GDPR, REaD Group run campaigns to be transparent with a clear link from the sender, to the data controller and to the client.  Therefore, REaD Group have taken the view that headers and footers will name both My Data Choices and REaD Group, whilst explaining the link between these sites to the consumer. As the Data Controller, REaD Group must be named first in the from line, in association with the client e.g. From line would be: REaD Group in association with ‘Brand name’.