Is the promotion to staff by post of a staff benefit that is available from a specific third party supplier marketing? There are no concerns about the purpose and lawful basis (LI). Points to note:
1)The postal letter will be sent to staff by us and not the 3rd party.
2)The letter would be addressed to staff, so makes it directed at individuals for marketing purposes.
3)The letter will promote a specific benefit and how to get further info from the third party.
My assessment is that it is marketing and therefore requires opt out information in relation to future communications has been questioned on the basis that this is general staff communication and that no opt out is needed.
I think you’re right. Are you in the UK? S. 122(5) of the Data Protection Act 2018 incidentally defines direct marketing:
“direct marketing” means the communication (by whatever means) of advertising or marketing material which is directed to particular individuals
This does not concern itself with whose marketing, or whose product is being marketed.
Art. 21(2) [UK] GDPR provides for the explicit right to object to processing for direct marketing purposes, and Art. 21(4) requires you to inform of the right at the latest when first using the contact details, but this might already have been done, and you wouldn’t necessarily have to keep drawing attention to opt-outs, which differs from email direct marketing where you need unsubscribe/opt-out text in every message.