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A CharityConnect User Posted 7 years ago

CharityConnect: Monitoring open rates under the GDPR
Does your Organisation monitor when your marketing emails are opened? Who has opened them? Have you tracked to which server your email has been sent to? Or tracked when a recipient has clicked on a link?
By tracking information like which emails are being opened and which are converting, you can see how effective your marketing materials actually are. Your Organisation can use this information to identify what types of offers and campaigns work best for your business and develop your strategy accordingly. However, despite the benefits of tracking emails, if your Organisation continues to monitor open and click-through rates then you could be at risk of breaching the General Data Protection Regulations (GDPR).
Tracking is usually done without the knowledge (and probably consent) of the recipient - two elements that are paramount when it comes to the GDPR. Have you ever been asked to download the images in an email in order to proceed? Well, most modern emails have not had the images loaded into the HTML by default, so when a recipient downloads those images they are subject to tracking and profiling, as everything is linked back to the email address. When the recipient downloads the image content of the email they are not told that this is what is happening to their data.
It’s important for your Organisation to track the success of your email campaigns, however, it is essential for your Organisation to comply to the GDPR - what’s the solution?
Pre-described - To comply with the requirements of Chapter 3, Article 13 of the GDPR [Information to be provided where personal data are collected from the data subject], it is recommended to include information on how tracking and profiling will be applied to emails received by the subscriber, at the initial point of subscription.
Opt-out - Under GDPR a user can selectively opt-out of personal data-processing for specific purposes that are not necessary for "the provision of a service" (Article 7, Clause 4) and "without detriment" (Recital 42). This could mean that if the recipient requests ‘tracking opt-out’, senders must send emails with all tracking removed.
Tracking Notice - This could be an add-on to the ‘download images to proceed’ message. A clear notice that informs the recipient that loading the images and clicking any links will trigger the personal-identifiable tracking and the potential of profiling. Much like your Privacy Notice, this could be a link at the top of the email, which opens to a page that outlines how and why your Organisation is tracking the recipients data.
Vox Securitas can assist your Organisation in implementing the best technical procedures and policies, through a Government-backed Cyber Security certification, and organisational processes in order to become GDPR compliant.
We have over 30 years of combined experience working in the third sector and have a passion for ensuring they are secure! Call or email us today on: 023 8023 5342 or [email protected].
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