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Web Scraping and the Re-Use of Publicly Available Online Data for Direct Marketing

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Background

Some businesses extract personal data, such as email addresses, from online public spaces, e.g. web pages, in order to send direct marketing communications to individuals. This is known as web scraping (or data extraction).

Compliance with the GDPR

It is a common misunderstanding that individuals’ contact details that are publicly available, are not ‘private’ and therefore can be freely re-used. However, contact details are personal data and, as such, must be used in accordance with the General Data Protection Regulation (GDPR).

Key steps before using web scraping tools

  1. Verify the nature and origin of the data that will be scraped
    Some tools extract information from websites whose terms of use prohibit the extraction and re-use of data for marketing purposes.
  2. Minimise data collection
    Businesses using web scraping tools must be particularly cautious and avoid collecting irrelevant and excessive information.
  3. Provide notice to individuals
    Businesses using web scraping tools must provide notice to individuals whose data has been extracted for direct marketing. The notice must contain, amongst other things, the source of the data.
  4. Manage the contractual relationship with the web scraping service provider
    When businesses engage a web scraping service provider, they must ensure that they have a proper data processing agreement in place with that service provider in compliance with Article 28 of the GDPR.
  5. Carry out a Data Protection Impact Assessment (“DPIA”)
    Even if a DPIA is not required, the ICO emphasises that it is best practice to carry one out.

Appointing NormCyber as our virtual DPO has given Ferrero the best of both worlds – access to data protection experts who understand what we stand for as a business, without the hefty overheads usually associated with appointing an in-house DPO.

Harpreet Thandi
Regional Counsel, UK & Ireland, Ferrero

We were looking for a virtual DPO service that offered all of the benefits of a fully qualified data protection lawyer, without the overheads of an in-house hire. The DPaaS solution from norm. has been invaluable in helping us to ensure we respect the integrity of our customers’ personal information, while using it to continue to deliver differentiated products and services which support our growing customer base.

Mike Whitfield, Compliance Manager
Marmalade

CSaaS allows me to step away from multi-vendor management as the Security Operations Centre coordinates all of the technology for me.

David Vincent, CTO
Perpetuum

We were in the market for an independent Data Protection Officer service that was well versed with both UK and EU regulators. We’re thrilled to have acquired this service knowing that an expert is available 24/7.

Suzanne McCabe, Head of Project Management
James Hambro & Partners

Norm’s penetration testing layer, along with the suite of CSaaS modules has enabled MA to exceed all its audit requirements for its major clients.

Rob Elisha, ICT and CRM Manager
Montreal Associates

The speed of your Data Protection Officer’s response was very impressive – it was far quicker than I would have expected even from an in-house DPO

Will Blake, Director of Technology and Analytics
CRU Group