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GDPR Lawful Basis Legitimate Interest: B2B Cold Email Guide
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The four inputs that decide your balancing test# “Public professional sources and vendor databases with disclosed provenance are defensible.” Role relevance. Targeting by job function is the strongest signal that you had a reason to contact this person rather than 40,000 random people.
Lawful basis Realistic B2B use Effort to rely on Right to object? Verdict for cold outbound Consent — Art. 6(1)(a) Newsletter sign-ups, gated content, event lists High — granular capture, timestamped proof, easy withdrawal Withdrawal, any time Only works for inbound-generated contacts Contract — Art. 6(1)(b) Onboarding, billing, support for existing customers Low No Never covers prospecting Legal obligation — Art. 6(1)(c) Tax records, KYC, statutory retention Low No Irrelevant to marketing Vital interests — Art. 6(1)(d) Life-or-death emergencies N/A No Not applicable Public task — Art. 6(1)(e) Public authorities only N/A Limited Not applicable Legitimate interests — Art. 6(1)(f) Cold email, enrichment, lead scoring, account research Medium — documented LIA + Art. 14 notice + opt-out Absolute for direct marketing (Art. 21(2)) The only workable basis, if you do the work “your suppression list has to be a system of record, not a spreadsheet somebody forgets to import.” What is the three-part test, exactly?#