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Alex J.
Alex J., Solicitor
Category: Law
Satisfied Customers: 3670
Experience:  Solicitors 2 years plus PQE
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If I was to offer my services as a sub-contractor to research

Customer Question

If I was to offer my services as a sub-contractor to research potential sales leads for a company and I don't do anything but provide the list of people (with their contact details i.e. name, company, job title and e-mail address) to the companies I work for, am I breaching any form of data privacy law? I am not selling a list of contacts, only my time to do "desk" research on their behalf.
Submitted: 2 years ago.
Category: Law
Expert:  Alex J. replied 2 years ago.
Hi,
Thank you for your question and welcome.
My name is ***** ***** I will assist you.
To be in breach of the Data Protection Act 1998 you need to store the data in a relevant filing system and process it.
Simply compiling publicly available contact information for the purpose of pursuing sales leads would not fall under data protection rules. You would have to be storing this information on mass and then selling the information as a data base before you come into realms of data protection.
Ultimately these people have made their contact details publicly available and therefore there is a reasonable expectation that you would use their contact details for a commercial purpose.
The Data Protection Act 1998 imposes legislation that states that people must use Personal Data within reason - reasonableness is key to what you do with personal data and if someone makes their business contact details publicly available it is reasonable some one may contact them for business purpose. What would not be reasonable for example is if their data was being compiled into marketing spread sheets for the purpose of being contact for "market research" or testing to which they did not consent.
https://ico.org.uk/for-organisations/guide-to-data-protection/exemptions/ - if you look at the information commissioner's website there is actually an exemption for research purposes.
The best way to protect yourself is to ensure you are not storing large quantities of the data on your personal computer.
Kind regards
AJ