Data Protection Guidance: Marketing
Direct marketing is communication (by whatever means) of any advertising/marketing material
which is directed to particular individuals, including the offer for sale of goods and the promotion of
an organisation's aims and ideals.
An individual is entitled, by written notice to require the University not to begin or to cease
processing his or her personal data for the purposes of direct marketing. This covers all marketing
material that is not directly related to current academic study or to student administration. If the
University receives such a notice, it must comply as soon as possible; there are no exceptions to
this. Students are given the opportunity to opt out of receiving direct marketing in the Data
Protection Notice they receive at registration and the list of students opting out is collated by the
Development and Alumni Relations Office.
Dealing with Enquiries
When personal data is obtained from enquirers/potential students, staff must ensure that they are
informed of the purposes for which the data will be held. If it is possible that the enquirer will be
sent information relating to the marketing of courses or services beyond those specified in the
original enquiry, they should be offered the chance to opt out.
Staff must ensure that the data collected is only disclosed to external parties with the consent of
the subject. Particular care must be taken to obtain consent when disclosing data to parties outside
the European Economic Area (EEA).
If the data is collected via a web portal, the submission of details must be safeguarded so that
unauthorised parties such as hackers, cannot access the details. The extent to which these
safeguards are implemented depends on the harm that might result from a breach of security and
the nature of the data to be protected.
It is recommended that enquirer records be deleted at the end of each relevant admissions cycle. If
records are kept for longer, particular care must be taken to inform the enquirer that their details
have been retained and that they are entitled to object both to this and to any marketing which may
take place.
Photographs
If publicity materials carry clear pictures of students, then the permission must be sought. It may
not be necessary to obtain the specific permission of all students who appear incidentally in the
background of publicity shots. You can ensure that a photograph may be re-used in future publicity
by using a clause such as the following:
"I give permission to the University of Exeter for my photograph and written profile to be used in
the [Undergraduate Prospectus 2008] and other promotional material for which it may be suitable.
Signed…………………………………
Print name……………………………..
Date……………………………………"
Telephone Communication
Where direct marketing material is communicated by telephone, staff must identify themselves and
if requested, provide an address or telephone number on which they can be reached. Where coldLast Updated: August 2008
calling for fundraising takes place, details should first be checked against the Telephone
Preferential Service (TPS). Those receiving calls should be made aware of their right to object to
the calls.
Last Updated: August 2008