Having downtime due to lockdown, I did my annual clear-out of emails and documents I had saved over the past three years. In normal circumstances, I check each individually to see which is still relevant, but this time it was over quickly. Anything before December 2020 was deleted as it was of no practical use.
Suggesting that Brexit and Covid has changed everything is not hyperbole, especially for us in email marketing. I discovered an e-book headed Predictions of how marketing will progress in 2020. It was almost funny. Mind you, much of the hilarity was dampened as I have also indulged in the fantasy of prediction.
Some of the changes have been overt, while others have been more subtle, and it is all too easy to miss the implications of the latter. Is it time for you to do an annual clear out? It is possible, maybe even probable, that many of your processes are based on the introduction of the GDPR, way back in 2018. Much of the information is out of date due to Brexit and current guidance from the ICO.
For instance, what information do you send out in response to a subscriber access request? If it’s not been changed since Brexit then it is probably wrong. The norm is that your data controller will include the statement, ‘no personal data is transferred outside of the EEA’.
You’ve probably worked out what’s wrong with that, but just to be clear, it is no longer compliant with the UK GDPR. If you transfer personal data to anywhere outside the UK, the information must include what safeguards are used. It used to be so simple and straightforward.
If you haven’t already had your ‘spring clean’, it is overdue. Check relevant ICO guidance for where the requirements have changed, then ensure that your systems comply. Email marketing regulations and requirements are, as always, in a state of flux and it is up to you to ensure that your systems are up to date.
The ICO is there to advise as well as to punish. There’s no point in not using them.