The beauty and power of social media marketing as a business tool is in the name, it’s social. It is based on the connections and relationships that exist between people and communities, and these connections are based on individuals. The ability to identify and target advertising on social media with such precision based on, say, their characteristics, their connections, or their activity, is what makes this method of advertising extremely powerful. In fact, major platforms such as Google, Facebook, Twitter and LinkedIn are continually investing in their ability to target consumers and businesses with increasing efficiency.
It also means that inherent within it is the fact that data collected for the purposes of social media marketing is very often personal data in that it relates to identifiable living individuals. As such you have to ensure that you comply with GDPR in relation to any personal data collected and used by you for the purposes of such marketing.
Often social media marketing is used for what is referred to as lead generation, i.e. it is used to capture the identity and contact details of potential leads for a business. This is an established and effective form of direct response marketing but, again, inherent within it is the fact that in doing so the personal data of identifiable individuals is being collected; and this brings the activity within the scope of the GDPR.
Another feature of social media marketing is the use of what is known as lookalike audiences, whereby details of existing contacts of a business can be uploaded to social media in order to allow that platform to identify other audiences that look like that existing list. In this case, it is important to be clear that the data being uploaded for that purposes is very likely the personal data of the individuals concerned. If those individuals are located in the EU it would be essential to ensure that any use made of that data is compliant with GDPR.
Your obligations if you are marketing to EU citizens
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