A relatively regular question we have with subscribers and users who have completed a marketing campaign and are at the end of a database subscription licence is “which records can I keep?”

Seems like a straight-forward question - and, in fairness, does have a pretty straight forward answer. Which goes something like this:

After a licence has elapsed, users can keep the details provided for postholder records that have “meaningfully interacted” - sounds a bit woolly right, so here’s some detail and specific cases around that.

You can keep records for those that have contacted users directly, for example:

- requested a meeting or call-back

- requested a quote or more information

- opted-in to "customer name" marketing

- and clearly anyone that has become a customer.

One neat little exception being the need to keep a list of ‘opt-outs’ - important of course!

In these cases, the rights to the records and associated future data processing and responsibilities pass to the user.

Examples of records that cannot be kept, would include:

- those Opening or clicking on emails received, but not contacted users directly.

- all passive and non-responsive records.

In these cases, at the end of a licence period the records must be deleted from users' system(s).

All well and good you may say, but why is that?

2 Reasons - no more or less:

1 - Compliance:

It’s important to note that until a record has ‘converted’ or in other words is yours, then we remain the data controller and therefore have to ensure data currency, compliance and that the latest permissions from the data subject are reflected. This is particularly important because a lot of information we hold is not in the public domain and provided directly to us on the basis of our data processing and privacy policies.

2 - Commercial Interest:

We spend a fair bit (a lot!) of time and energy in maintaining our data (a deep dive into our research processes for those feeling brave can be seen here). Therefore it’s commercially important to us that only those who have funded licences use our information and when the pennies stop, the usage stops.

Take-aways:

Well, again, pretty straight forward; It is a good plan - for many reasons, including tracking data effectiveness - to ensure that you have a source (and date) linked to any customer and prospect records you hold in your databases and platforms to ensure your own processing is compliant AND to ensure that any external licences held with third party data providers can be (easily) tracked and honoured. A bit preachy, but honestly very much worthwhile!

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