In some cases, especially in active prospecting, it is common for the lead to ask where we got his data.
This type of information fits into one of the principles of the LGPD, transparency, which says that the processing of personal data needs to guarantee holders clear, precise and easily accessible information about the processing and the respective treatment agents, observing the secrets commercial and industrial
Of course, this process of passing information to the lead ideally needs to be defined by the company hiring Spotter, and this process is usually defined during the company's adaptation to the LGPD.
Each company needs to establish its legal bases for processing personal data, regardless of the source it uses to obtain the data (either Spotter or Google search, LinkedIn for example).
Likewise, the response to the data subject's request (or to the lead) must be defined for each company.
This is part of adapting to the LGPD. There is no ready-made model for this, as each company needs to analyze its business processes.
Exact cannot guide a response in this regard, as each process is particular and needs prior analysis. Of course, you can mention that you use a tool like Spotter, for example (if that makes sense for your fitness strategy). But this does not exempt the need to establish legal bases.
On legal bases, we suggest that you consult these materials:
To exemplify, let's talk about how we do it here at Exact. However, it is important to emphasize that the information below concerns our adaptation process, and should not be simply copied, combined?
In order to be able to collect and process data on Searching, for example, and offer it to customers, we use the legal basis of legitimate interest.
In order to be able to use these leads in our pre-sales, we also use the legitimate interest basis. In this case, we have 2 documents that support the use of legitimate interest for two different purposes: offering leads to customers and starting a business relationship with leads.
As for the leads generated by our marketing, the legal basis used is consent. That is, depending on the origin of the lead here at Exact, we use one legal basis or another.
This legal basis is what justifies and supports correct and secure data processing. And we have the data processing records and a defined process to respond to the data subject, or the lead, from where we collect the data if they ask.
Exact's guidance is: seek expert help to assess your business processes and define which legal bases will be used in the processing of operation data. That way you will ensure that your processes follow the guidelines and best practices of the LGPD ;)
We are always available to answer questions if this article is not enough, and new questions help to improve our content. So feel free to contact us!