Two very similar companies have joined forces via acquisition. Products and services the same, slightly different ‘consumer’ demographic.
All customers have been informed of the merger and provided with core privacy information regarding who is the new data controller etc. Everyone made aware of rights, and GDPR § 13 requirements addressed.
‘A’ would now like to send email direct marketing to existing customers of ‘B’. Due to PEC Regs, this must be completed with the CONSENT of the individuals. Can ‘A’ rely upon the consent given to ‘B’ pre-acquisition?
Information Commissioner GDPR guidance would appear to suggest not, failing the ‘specific and informed’ requirement.
If no consent, would it pass as a balanced legitimate interest for other marketing channels?
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