GDPR, and how I spent a month chasing my data.

In May 2018, I received a letter from a local firm of solicitors, Roythornes, advertising a property investment event. I hadn’t heard of them and I was damn sure I hadn’t given them my permission write to me at home. They were wide of the mark to say the least- I’m an unlikely potential property tycoon, unless we’re playing Monopoly. Even then, I’m a long shot.

It was a quiet week at work so given the recent implementation of GDPR and the fact that I really don’t like junk mail, I thought I’d give the new Data Subject Access Request (DSAR) process a whirl.

I couldn’t find contact at Roythornes to send a DSAR to but, helpfully, GDPR places no restriction on the medium someone can use to make a request, so at around 9am that day I filled in their online contact form, despite my concerns that it would get picked up by a clueless admin assistant. I requested a copy of the data they hold on me, the source of that data and the evidence of my opt-in for direct mail. I also asked that they delete the data they hold on me and send no further marketing material.

At 1:42pm, I had a from “Norma” of Roythornes (not joking, sorry Norma), asking for a copy of the letter and stating that she couldn’t find me in their database. So far, so good…

At 1:55pm, I received an automated recall email from Norma.

A few hours later, another email arrived, this time from the firm’s “compliance partner”, stating that they had acquired my personal data in a mailing list they purchased from Lloyd James Media, on the 1st of May 2018, and that my letter was sent out on the 21st May 2018. She stressed that the purchase of the list, and the sending of the letter itself was prior to the GDPR implementation date of 25th May 2018, and therefore legal.

Solicitors abiding by the letter of the law, not the spirit of the law? Imagine that.

Dancing around technicalities notwithstanding, Roythornes did confirm that my data had been deleted and I wouldn’t be hearing from them again. Phase 1 complete, but who exactly were Lloyd James Media, and how did my data fall into their hands?

For Phase 2 of my quest, a quick google told me that Lloyd James Media “is a multi-channel data agency focusing on the intelligent use of data to optimise customer acquisition and retention.” I can only assume this translates as “we make and sell mailing lists”. So, off went my DSAR email to their sales email address, because yet again, there was no contact information available for non-sales enquiries, let alone DSARs.

Andrew of the compliance team at Lloyd James Media only took 24 hours to get back to me. He confirmed that they sold my personal data to Roythornes for a postal campaign. They had acquired my data from another firm, “My Offers”, and the consent for postal marketing was obtained by them, apparently. Helpfully,  Andrew suggested I get in touch with the “compliance team” at My Offers. Evidently, this is a team of one, someone called Saydan, whose email address Andrew provided. I reminded Andrew to remove my data from their system and headed off to continue the hunt for the true source of my data, feeling like a geek version of Bear Grylls tracking an elusive squirrel. Phase 3 had begun.

My Offers are “Europe’s leading online direct marketing company with a database of 22.2million registered users.” I fired my third DSAR email off to Saydan later that day. One week later, I’d heard nothing. According to GDPR, there is no need for an immediate response, as long as the DSAR is executed within a month, but the silence was unnerving. Was Saydan trying to ghost me? I found their Facebook page and sent a message to whichever poor soul supports their social channels. For good measure, I also dredged LinkedIn for their employees, emailed Ivan, one of their directors, and in true annoying millennial style, tweeted at them. The only response was from their Facebook team, who reiterated that I should email the enigmatic Saydan, then also went quiet on me.

Over the next few weeks, because nothing seemed to be happening, I pinged their facebook team a courtesy message once each week with a gentle reminder of the impending deadline for a response. Part of me was relishing the prospect of not getting a reply, and I began googling, “What to do if someone doesn’t respond to a DSAR.” I was way too invested in this.

Then, exactly one month to the day since the original request, an email from Ivan, the My Offers director arrived in my inbox. Ivan’s email was straight to the point and only had a few spelling mistakes. Attached was a password protected CSV file containing all the information I’d requested. The password was sent in a separate email. So far, so good (though, yet again, I had to remind him to remove my data from their systems).

The CSV file was interesting. And by interesting, I mean in the way that hearing the creak of a stair when you’re in bed, and there’s nobody else in the house is interesting. The data contained my full name, birth date, gender, home address, email address, phone number, data subject acquisition date and source (Facebook), as well as a list of businesses that my data had been shared with in the past year. The list totalled around 60, including Lloyd James Media, various PPI and no-win no-fee firms, and more. That explains all the marketing calls over the past year then.

This CSV file was the smoking gun. However, the trigger was evidently pulled by my own fair hand. At some point, possibly whilst drunk, bored at work, or both, I’d clicked on a campaign offering me a beard trimmer. I still don’t have a beard trimmer (I do have a beard), so I presumably I didn’t pursue this purchase but in getting only that far, I inadvertently provided My Offers with access to my personal data, and consent for direct marketing. Sounding eerily familiar, I wondered if my voting choices in the last election were my own making.

So, just over a month after I sent my first DSAR to a local firm, what have I learned from this?

Firstly, GDPR actually works. Not only was the DSAR process easy to do, it was free (for me), and two out of three firms responded within 24 hours. Presumably GDPR is also helping to reduce unwanted junk mail; after all, Roythornes as good as admitted that they wouldn’t have posted the initial letter to me after the GDPR implementation date.

Secondly, once your data is out there, it gets around. It only takes one “online direct marketing company” to get hold of it, and your personal information will spread faster than nationalism in Europe.

Finally, don’t be dumb on facebook (like me). We know about Cambridge Analytica of course, but they’re not the only guys trying to harvest information and profit from it. Resist the lure of data-harvesting surveys and competitions, even when drunk.

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