On August 20, 2018, the Information Commissioner Officer, ICO – the British data protection authority – fined Lifecycle Marketing (Mother and Baby) Ltd, aka Emma’s Diary, £140,000 for failing to comply with the data protection ‘fairness’ principle. The principle imposes a transparency duty requiring data controllers to provide data subjects with information about the purposes for which their personal data will be used. “The ‘fairness’ requirement […] also included a substantive duty to treat individuals fairly when using their personal data. In particular, fairness involves adhering to individuals’ reasonable expectations of how their data will be used and not using their data in ways that cause them damage or distress, unless there is some sufficiently weighty justification for doing so”. As for Emma’s diary – a business providing advice on pregnancy and childcare – the data subjects could not reasonably have expected their personal data to be disclosed to a political party for the purposes of political marketing.
The ICO’s decision is available at https://ico.org.uk…/
More information is available at http://www.corderycompliance.com…
For more information about how privacy is implemented in Europe, contact Francesca Giannoni-Crystal & Federica Romanelli.
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