Can I ask for advice on two separate issues?
1. The University issues a Newsletter to all its staff which is personally
addressed with a label from the payroll system to their work address. The
last issue included an inset advertising a certain make of car which was paid
for by the company concerned. The Newsletter also includes block advertising
by non-University companies. This helps to defray the costs of production. A
member of staff objected to the insert and asked to be removed from the
mailing list in future. I have taken steps to ensure that he does not receive
future issues but it has raised a number of issues:
a) Is the insert direct marketing?
b) Is there any difference between inserts and block advertising?
2. The University has relationships with certain companies to offer staff
benefits i.e. health cover, telephone discounts, etc. In the past I have
allowed details to be circulated with payslips where I considered it to be in
the interests of employees.
a) What is the position now. Is this direct marketing?
b) Is a flyer (either sent direct, or included with the Newsletter) giving
the details of a scheme giving discounts on BUPA membership which gives
details of the company concerned direct marketing? Would there be any
difference between a flyer or an article actually in the Newsletter?
c) Should I prohibit circulation of this type of material using payroll data?
If I provide an opt-out option then the employee will not be notified of other
possibly important information contained in the Newsletter.
Any advice would be most welcome.
Dennis Barrington-Light
Head of Student Records and Statistics and University Data Protection Officer
University of Cambridge, 10 Peas Hill, Cambridge CB2 3PN
Tel: 01223-332303 (Direct line) Fax: 01223-331200
Email: [log in to unmask] or [log in to unmask]
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