Data for acquisition marketing

Our approach to Data-driven Direct Mail, and how it relates to GDPR.

Giving consumers greater control over the processing of their personal data is one of the primary intentions behind recent legislation such as the GDPR.

How do we fulfill data-driven direct mail?

We believe data holds the potential to improve every aspect of our modern lives. It already has in many ways. Equiniti believe that when you connect strong markets with great businesses, then amazing things can happen. We’ve seen how data has become the medium for this, and we’re passionate about spreading the message. This is what drives us to add value to business and consumers every day.

Because of this drive, we receive data from a diverse range of sources, with a mind to ensuring that we can build any audience for any conversation. We have partnered with many businesses who share our values. Our stringent value-centred vetting process applied to our partners is robust to protect consumers.

Some of our data partners fit into the following categories:

  • Online (Competitions sites/subscriptions/surveys/price comparison sites/memberships)
  • Telephonic (Call centres/transactional)
  • Postal (Mail order/competition surveys)
  • Face to face surveys
  • Public Data (including Open Register (also known as Edited Electoral Roll), Office for National Statistics (ONS) census data and Open Government sources)

The application of consumer data in marketing is in full compliance with the GDPR, having consulted with them closely.

Our position

We’re often asked about our legal position, as it is understandably a common question for clients.

So here’s a quick run down:

  • We operate under legitimate interest (LI), as referenced under the GDPR.
  • We are a ‘data controller’ of our own UK consumer database and processes on the lawful basis of LI.
  • We define our LI for ‘insight and analytical purposes to deliver demographic, attribution, segmentation, modelled and profiled data to enable additional insight about our client’s customers and target audiences’.
  • We only conduct marketing using 3rd party consumer data in the channel of Direct Mail*.


We consider our use of consumer data with the lens of guardianship. Our use of consumer data is always balancing the position of the consumer with the benefits created by our introduction of the client’s business.

With this in mind, we always ensure the customer will:

  • expect the processing activity to take place
  • have the absolute minimum amount of personal data processed
  • have their privacy and interests
  • We always seek to delight, bringing services of businesses to those whom we believe need them.

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*This is in compliance with GDPR recital 47 and article 6(1)(f) which identifies direct marketing as a “legitimate activity by the controller on or on behalf of a third party”.

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Stephen Green

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