14/05/2018 GDPR PRINCIPLES IN THE GROUP – In Terms of Marketing The principles set out below are what we believe to be a realistic “real world” approach to our customer marketing/databasing in terms of GDPR in the group, with which we will enter the new “GDPR Era” on the 25th May. It may be that subsequent information, test cases or further clarification will cause us to review our position. We will therefore continue to review GDPR and modify our model should it be necessary to do so. GDPR CUSTOMER DATABASE PRINCIPLES GENERAL – SALES/AFTERSALES/WHOLE GROUP In the terms of our active customer base, we believe that we have a strong/compelling “legitimate interest” to continue contacting them in both a sales and aftersales context (see * for definition of active). However, over time and as we have contact with our customers and by specific actions conducted by the Marketing Department (if required), it is our intention to work methodically towards a fully consented and preference-based customer database using our DMS and Showroom management systems as the basis. Consent and Preferences will be collated separately for Sales and Aftersales, and will subdivide into methods of contact for those customers who consent. Functionality and fields within our DMS/Related systems will subsequently allow for the collation, storage and correct deployment of these preferences by the company. On an ongoing basis, we will make it easily possible and straightforward for customers to review, manage and amend those preferences, as they see fit and when their circumstances change. *Active customer definition = Contact with the company in the previous 5 years SALES In the Sales context, we believe that we have a “legitimate interest” in continuing customer contact in terms of marketing activity assuming they are an active customer.* As it is currently a “grey area”, we believe that any Sales marketing campaign that includes customer data of more than 3 years old (in terms of customer activity) should automatically generate a discussion resulting in Director Approval. As clarity emerges on this “grey area”, we will review and set different parameters if required. AFTERSALES In the Aftersales context, we believe that we have a “legitimate interest” in continuing customer contact in terms of marketing activity assuming they are an active customer.* In terms of Service Reminders, MOT Reminders, Service Plan Information/Updates, Extended Warranty Customers and Product Recalls, we believe that an ongoing “legitimate interest” exists with active customers. As it is currently a “grey area”, we believe that any Aftersales marketing campaign that includes customer data of more than 3 years old (in terms of customer activity) should automatically generate a discussion resulting in Director Approval. As clarity emerges on this “grey area”, we will review and set different parameters if required. DELETION OF CUSTOMER RECORDS In terms of the deletion of customer records, it must be carried out at 7 years (assuming the customer is not active*) and in harmony with financial/accounting records. <7 Years Subject to ongoing review>. The “harmony” between these two makes sense as a customer record is linked to a financial transaction. IMPORTANT – The deletion of customer records can only be performed by the Marketing Department with specific permission from the Directors.
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