We operate a loyalty scheme for our own products and services. How do the Regulations apply here?
If someone participates in a loyalty scheme, the least they can expect from you is an update on how many points or vouchers they have earned. In our view, under the soft opt-in rule, you may send them further information about other incentives that are available under the scheme, until they opt out of receiving it. Once they have opted out, you should not send such further information until they opt back into receiving it again.
We operate a loyalty scheme in partnership with other companies. A lot of information is transferred across the scheme and the partners do not necessarily offer similar products and services. How do the Regulations apply here?
We assume you have collected any contact information you already have in line with your obligations under the Data Protection Act.
If you are collecting information to conduct marketing exercises electronically, you may need to re-read the data protection and privacy wording of your application form. You must make sure individuals are fully aware of the nature of the promotions you propose to send. The least an individual can expect is an update on how many points or vouchers they have earned.
In our view, under the soft opt-in rule, you may send them further information about other incentives offered by all the participating companies in the scheme, until they opt out of receiving it. If there are several partners in a loyalty scheme, you may find it easier to provide an opportunity for the individual to invite (solicit) further marketing contact from each partner if those partners propose to contact the individual independently of this scheme.