GDPR and Job Function Email Databases: What You Need to Know1. GDPR Applies to Personal Data
Under GDPR, email addresses tied to an identified or identifiable person (e.g., [email protected]) count as personal data.
Job function info linked to that email makes it personal data enriched with professional context.
2. Lawful Basis for Processing
To use job function email databases legally, you Forex Database need a lawful basis under GDPR, typically:
Consent: The person has explicitly agreed to receive marketing emails.
Legitimate Interest: Your company has a genuine business interest in contacting the person, balanced against their privacy rights.
For cold outreach with job function data, Legitimate Interest is often used, but requires a strict assessment.
3. Legitimate Interest Assessment (LIA)
You must conduct an LIA to prove:
Your interest is legitimate.
Your outreach is necessary.
The individual’s rights and freedoms don’t override your interest.
Document this assessment carefully.
4. Transparency & Privacy Notices
When collecting or using job function emails, be transparent about:
Who you are.
Why you’re contacting them.
How their data will be used.
Their rights (e.g., to unsubscribe or request data deletion).
5. Right to Object & Unsubscribe
Recipients must be able to easily opt out of marketing communications.
Honor opt-outs promptly to avoid complaints and fines.
6. Data Accuracy & Minimization
Keep job function email databases up-to-date to avoid contacting wrong or outdated recipients.
Only use the minimum data needed to achieve your marketing goals.
7. Data Processor & Controller Responsibilities
If you buy or rent job function email lists from a vendor, clarify who is the data controller and data processor.
Ensure your vendors comply with GDPR and have appropriate data processing agreements in place.
8. International Data Transfers
If your job function email data crosses borders (e.g., from EU to US), comply with rules on transfers outside the EEA.
Use approved mechanisms like Standard Contractual Clauses (SCCs).
9. Keep Records & Be Ready to Respond
Maintain records of data sources, lawful basis, and communications.
Be prepared to respond quickly to data subject access requests (DSARs).
10. Penalties for Non-Compliance
GDPR violations can lead to fines of up to €20 million or 4% of global turnover.
Non-compliance also risks brand reputation damage.
Summary Table
GDPR Requirement What It Means for Job Function Email Use
Personal Data Job function emails = personal data
Lawful Basis Consent or Legitimate Interest required
Transparency Clear privacy notices and contact reasons
Right to Object Easy unsubscribe options
Data Minimization Use only necessary data
Vendor Compliance Ensure third-party GDPR adherence
International Transfers Use legal frameworks for cross-border data flows
Documentation & Records Keep clear records of processing activities