I can't see how an invitation saying, basically, "please come to our
marketing event" can be anything other than direct marketing.
I too would be interested to know how the department identified nappy users
in the first place - and whether their use of the data to send out cashback
forms was actually legal. If it were a case of "here is a voucher for you
to use when you buy Brand X nappies" then that, in itself, might have been
direct marketing of Brand X products.
As usual, advice to our non-DP colleagues has to be "think and check before
acting".
Graham
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