A company is subject to GDPR. They wish to use customer data for a new purpose (marketing) that was not disclosed when the data was originally collected. What must they typically do?

Answer options:

Obtain fresh consent from the data subjects.

Proceed if the marketing is in the company's legitimate interest.

Anonymize the data and then de-anonymize it later.

Pay a fee to the Data Protection Authority.

How to approach this question

GDPR Principle: Purpose Limitation. If you change the purpose, you need new permission.

Full Answer

A.Obtain fresh consent from the data subjects.✓ Correct

Under GDPR's Purpose Limitation principle, data collected for specified, explicit, and legitimate purposes shall not be further processed in a manner that is incompatible with those purposes. Marketing is often incompatible with original service provision, requiring new consent.

Common mistakes

Assuming 'Legitimate Interest' covers everything.

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