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Did she actually take a copy of the contact details, or has she just remember who the clients were and found a way to contact them?
That is indeed a potential breach because if she took the contact details just to contact them in relation to their sessions/bookings and has now used them to solicit business, it means that the customers’ personal data is being processed for reasons incompatible with these for which the data was initially gathered. That would be a breach of Art 5 of the GDPR. It means that if their personal data was collected for a specific purposes, it should only be used for that purpose, unless the customers had given their explicit consent for it to be used for other purposes as well.
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