The principle derives from professional and personal experience. We believe we know the privacy rules around Europe, and how those are interpreted and managed in most countries, so first of all we think we understand what we should be doing professionally. Second, our personal experience is no different to any other user's: we don't like being chased around the web, and we're somewhat alarmed by how much of our data appears to be out there. So that provides our principle: we manage your data in the same way as we would want our own to be managed. That means (the following are the four elements referenced above):
Reproduced below is the three-part test for ‘legitimate interest’ as the lawful basis for processing personal data, as referenced above and as required by the ICO. The information below is the same as we have provided to the ICO.
We are a start-up business. WikiRegs is a regulatory database which provides free access online to rules that affect marketing communications in nine countries in Europe in the first instance, and worldwide in due course. The service is aimed at international advertising agencies and advertisers. The information it provides is not available elsewhere, and certainly not for free. Its benefit is that it helps agencies and advertisers understand multinational content and channel rules, thus avoiding what can be expensive mistakes. In order for us to secure any kind of return on investment (which has been considerable), it's important that we obtain the user’s email address when the user registers. We don't need to know the person’s name, and do not request that on registration, but we recognise that some email addresses, albeit very likely to be business addresses, may identify the individual.
The reason that we require email addresses is fourfold:
That question is probably best answered by the individual and, of course, the individual will answer it when an email address is requested and the full privacy issues are clearly spelt out to that person. However, we can confirm, based on qualitative information, that there is considerable industry interest in this service: as we have said, it is not available elsewhere, and it can lead to the avoidance of costly and embarrassing mistakes when developing international advertising.