[LRUG] Outsourcing Bulk Emailing

[Michael Pavling]

On 21 October 2011 10:24, Paul Robinson <paul at 32moves.com> wrote:
> Data Protection law states that you must either:
> a) Keep all personal data in a jurisdiction with European Economic
> Area-equivalent data protection laws (i.e. within the EEA)
> OR
> b) Inform the subject that their data will be moved to a jurisdiction that
> has less adequate protection before moving it.

> It isn't correct to say you must stay within the UK, but you must stay
> within the EU unless you want to email your subscribers and give them the
> option of opting out before moving it to the US.

"Personal data" is something that can be used to identify a specific,
living individual, which an email address is generally taken to not be
capable of.

But depending on the content of the email in combination with the
address it's sent to, it *may* constitute "personal data"... it's a
minefield - does your client not have legal advisers to guide them?