Looking at this from a GDPR / ePrivacy perspective however:
I would say relying on legitimate interests if communicating by post would generally work. Phone is unclear, as it is undecided whether telemarketing will be encompassed under opt-in rules as part of ePrivacy (Article 16.5 leaves it up to individual member states to decide whether telemarketing requires opt-in consent.)
That is, as you say, making the presumption there would be a reasonable expectation that contact would be made to the individual - how you would make that presumption could be argued on however.
One example would be contacting an individual with their details listed on the website contact page / brochure / business card - I would struggle to see any issues with that. But deriving the information from a staff directory on the website / LinkedIn / a newspaper article and using to make a contact, some may argue this would not be considered 'fair'.
Regarding emails, this is also still all very unclear - GDPR won't affect this directly, but ePrivacy potentially will.
I am presuming your concerns are around the draft ePrivacy regulations requiring organisations to have a prior opt-in consent for business-to-business communications, and consent being the only legal ground for processing in the Regulation. This isn't set in stone yet, and final text is still to be determined, as such it is appearing unlikely ePrivacy will actually be agreed upon and kick in any time soon - until it comes into force, PECR will still apply to electronic marketing.
DMA have been strongly lobbying against some of these proposed changes, as it particularly affects the B2B industry, but there has not been much to report in the last couple of months - https://dma.org.uk/article/eprivacy-impasse
To go back to your original question - if ePrivacy is passed unaltered, and comes into force on the 25th May, you would always need to use generic email addresses (and potentially phone numbers) so you are not targeting a person at the company - unless they gave you consent. But that is a big unknown if.
Hopefuly some of this will become clearer in the coming months.
Thanks,
Michael Steven
Development Officer (Research)
Development and Alumni / Charles Stewart House / 9 - 16 Chambers Street / Edinburgh / EH1 1HT
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