Contacting institutions using email addresses made public

Feb 27, 2020

We recently were asked the following question on a Data protection forum:

“There is a website called which publishes 100s of email addresses for special need schools. As I understand it GDPR prohibits us from sending them an email with a discount code for goods relevant to their institution.

Would it be allowed to contact them asking whether they would be interest in receiving information about our company without offering the actual offer?”

Xynics Response:

Any promotion of your business by email, telephone or SMS, whether it is directly, or asking if they'd like information is marketing under the Privacy & Electronic Communications Regulations.

Looking at that website, the email addresses are not published for the purpose of receiving marketing information. The Privacy Policy clearly says the owners of that site will not share/sell information with third parties which implies that they do not expect people to bulk obtain the information they hold and use it for their own purpose.

It cannot be assumed that the email addresses are generic mailboxes, they may be manned by only one person, in which case they are that person's personal data, so in our professional opinion, it would be dangerous to use it in the way you suggest.

We have previously wrote an article about ‘When is it OK to use “publicly available” data? which you can read

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