Direct Marketing Customer Charter

We will not send unsolicited one-to-one (direct) marketing email and/or SMS communications unless they comply with the rules of GDPR and PECR and related guidance. Direct marketing covers the promotion of aims and ideals as well as the sale of products and services. We will not send or instigate the sending of one-to-one commercial communications to any customer using data obtained in breach of data protection and/or privacy legislation.

Specifically:

  1. We use opt-in boxes (unless we are contacting previous customers about our own similar products during the course of a sale, and we offered them an opportunity opt-out when they gave their details)
  2. Our store and contact centre colleagues will always inform customers about the further use of their contact details for direct marketing when they make a purchase
  3. We will offer genuine and granular choice by specifying the methods of communication (e.g. by email, text)
  4. We will ensure that the product or service we are marketing are the same or similar to those that the individuals originally consented to receive marketing for
  5. We ask for consent to pass details to third parties for marketing and name those individual companies when requesting consent for third-party marketing
  6. We record when and how we obtained marketing consent, and exactly what it covers
  7. We will ensure the consent language used is ‘clear, specific, concise, prominent, clearly distinguishable from other matters, separate from other T&Cs and easy to understand.
  8. We will not use in our marketing statements language likely to confuse – for example, the use of double negatives, technical or legal jargon and confusing terminology or inconsistent language – will invalidate consent.
  9. We will not share marketing lists (names & contact details) between Carphone Warehouse and Dixons Retails Group Ltd (without your prior consent)
  10. Where necessary we will screen names and contact details against the Telephone & Mail Preference Service
  11. We will always offer our customers the option to opt out of direct marketing at the point when we capture your contact details and in every subsequent communication (by reply or unsubscribe link)
  12. We will promptly opt someone out of all marketing activities on request. We will ensure there is a simple easy-to-access and free of charge way for customers to withdraw consent.
  13. We will not misrepresent ourselves by send any marketing message disguised as a service message or survey when the real purpose of the contact is to sell goods or services
  14. We will operate and maintain an in-house suppression file – listing the names and contact details of customers who have indicated they do not wish to receive commercial communications via all or particular means of communication
  15. We will rely on the legitimate interests of the business (as an alternative to explicit consent) when undertaking postal marketing, when conducting live outbound phone sales or when contacting our business customers. We will include information within our telephone scripts and in all postal marketing on how to opt out of receiving such marketing.
  16. We will screen data to remove files of deceased people so that they are not used for marketing
  17. We will remove inactive customers from our marketing campaign lists
  18. We have procedures for dealing with inaccuracies and complaints.
  19. We will cooperate fully with any investigation by the Information Commissioners Office (ICO) in relation to our direct marketing activities.

Bought in lists

We will only use bought-in lists for texts, emails or recorded calls where we have proof of opt-in consent which specifically named us.

  1. We only use the information on the lists for marketing purposes
  2. We delete any irrelevant or excessive personal information
  3. We screen the names on bought-in lists against our own list of customers who say they don’t want our calls (suppression list)
  4. We carry out small sampling exercises to assess the reliability of the data on the lists
  5. When marketing by post, email or fax we include our company name, address and telephone number in the content
  6. We tell customers where we obtained their details
  7. We provide people with a privacy notice (where it is practicable to do so)
  8. We undertake adequate due diligence when first selecting data suppliers and on-going basis in order to ensure it has received and used personal data fairly
  9. We ensure that adequate contractual terms requiring data suppliers to ensure personal data was obtained and provided fairly and in accordance with the requirements of GDPR
  10. We take practical steps to satisfy ourselves that individuals to whom the data relates to are provided with sufficiently specific information to help them understand what would be done with their personal data.