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GDPR and Facebook Ads

Are you worried about breaking GDPR or PECR if you upload your email list to Facebook to build audiences?

Is it legitimate interest?

A lot of people have asked me about this. To provide some clarity, I spoke to the ICO for guidance.

The ICO said: ‘uploading compliant email data to target subscribers who can be found on Facebook with ads in their feed, does not fall under the scope of the Privacy and Electronic Communication regulations, and you would therefore not need the prior consent of individuals to market to them in this way.

However, as you will be sharing personal data with Facebook, to enable it to show these ads, you would need to consider an appropriate route to do so under the UK GDPR, ensuring that it was lawful, fair, and transparent.’

It is likely, as you already have permission to email the people on your list, and have been in contact with them before, that you could use legitimate interest to meet this requirement.

What you do need to ensure is that your privacy policy lets people know that you may use social media to market to them, and if this means making an update to your privacy policy, ensure you let current supporters know you have updated it.

A privacy policy is essential to run successful Facebook Ads. For some objectives, you need to submit a direct link to your privacy policy. For other objectives that send people to your website or landing page, as part of its approval process, Facebook’s bots will scan the page to see a privacy policy is in place.

If you are unsure I would suggest you contact the ICO directly, or your legal team, for clarity on your individual situation.

Being able to use your email data in this way will enable you to do so much more with Facebook Ads and fundraising, so it really is worth putting in place.

I would love to talk to you about how I can help you meet your goals.

Contact me on 07912 964993 or farrah@sparkplugmarketing.co.uk

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