Hi Jackie
Some of the German data protection authorities have been casting a critical eye over this sort of thing - see https://www.spiritlegal.com/en/news/details/facebook-custom-audiences-and-data-protection-law.html
Nb the point that the data in question appears to be pseudonymised (not anonymised) as the controller retains the ability to reidentify the individuals. That being the case, data protection law continues to apply, and an appropriate legal basis (most likely consent) needs to be in place to justify the processing.
Best wishes,
Jon Baines,
Chair,
nadpo.co.uk
> On 15 Jan 2018, at 17:10, Jacqueline Barlow <[log in to unmask]> wrote:
>
> Hi all,
>
> I have a question for any colleagues whose organisations undertake profiling.
>
> I have had a question from our marketing team as to whether it is ok for them to use current donors’ email addresses (we have the consent to use these email addresses for marketing purposes) via Facebook to see out lookalikes.
> The actual process is anonymous and the current donors email addresses are not disclosed to anyone and the ‘new lookalikes’ just receive the marketing information.
>
> I know that profiling is going to be covered in our revised privacy policy but do colleagues think that we also need to get explicit consent from our current donors for the use of their email addresses in this way?
>
> Many thanks
> Jackie
>
> Jacqueline Barlow
> Data Protection Manager
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