X joins a library in 2012 and signs "I consent to the use of my personal data for the purposes of providing and promoting library services and to enable the collection of any charges that I incur as a member of the library". The first and third purposes are probably coextensive - collecting charge is part of the service.
From 25 May it is proposed to make the choice more granular - separate opt-in for 'promoting'.
Does the earlier consent need re-validating despite being a clear opt-in?
My reading is yes based on A29WP "Ff existing procedures for obtaining and
managing consent do not meet the GDPR’s standards, controllers will need to obtain fresh GDPR compliant consent". Does "GDPR standards here include standards on granularity? I think so as in the same paragraph of A29WP they talk about revision of systems to "allow for more granular
indications of the data subject’s wishes".
On a slightly different tack the library manager suggests simply dropping "and promoting" as "it’s of benefit to all users to know if resources have been added or cancelled" so that is simply part of 'providing' library services. I would probably (just about if enough pressure was applied!) be happy with that if he could guarantee that was the extent of "promotion" but I am an old sceptic ....
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