Key takeaways from recent ICO enforcement action on invisible processing for marketing
The ICO stresses harm caused to vulnerable people by nuisance calls. By Katie Hewson, Martha Hampton and Jonathan Howie of Stephenson Harwood LLP.
The Information Commissioner’s Office (ICO) issued on 4 October two Monetary Penalty Notices(1) (MPNs) against Easylife Limited (Easylife) in relation to breaches of Article 5(1)(a) of the EU General Data Protection Regulation 2016/679 (GDPR)(2) and Regulation 21 of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), fining the household products catalogue retailer:
- £1.35 million for failing to process customer personal data lawfully, fairly and in a transparent manner (the GDPR Fine); and
- £130,000 for making over 1.3 million “predatory” unsolicited direct marketing calls to subscribers (the PECR Fine).
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