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Anonymous
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Asked: October 15, 20212021-10-15T16:03:48+01:00 2021-10-15T16:03:48+01:00In: GDPR

Renewal emails

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Can anyone confirm whether a membership renewal notice is classed as a service message or a marketing message please?

An example would be:

Your annual membership falls due for renewal on 1 November 2021. To renew your membership please….

Thank you

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    1. Stephen Lark

      Stephen Lark

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      Stephen Lark Bronze contributor
      2021-10-17T22:41:08+01:00Added an answer on October 17, 2021 at 10:41 pm

      Lawful basis would be contract and service message. However once the subscription expires then the lawful basis would be Legitimate Interest and marketing.

      Personally I continue to use contract for a period of 1 month after expiration. if I hear nothing from the ‘member’ after this period it’s usually safe to say they are not looking to renew.

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      • Liz

        Liz

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        Liz Bronze contributor
        2021-10-19T08:48:54+01:00Replied to answer on October 19, 2021 at 8:48 am

        Routine customer service messages do not count as direct marketing – in other words, correspondence with customers to provide information they need about a current contract or past purchase (eg information about service interruptions, delivery arrangements, product safety, changes to terms and conditions, or tariffs). General branding, logos or straplines in these messages do not count as marketing. However, if the message includes any significant promotional material aimed at getting customers to buy extra products or services or to renew contracts that are coming to an end, that message includes marketing material and the rules apply.

        https://ico.org.uk/for-organisations/guide-to-pecr/electronic-and-telephone-marketing/#directmarketing

        I think this suggests otherwise? I’m even more confused now!

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    2. Liz

      Liz

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      Liz Bronze contributor
      2021-10-18T08:58:49+01:00Added an answer on October 18, 2021 at 8:58 am

      Really useful Stephen, clarifies my thinking! 🙂

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