In this decisive phase of the legislative procedure on the revision of the European Data Protection legislation, INTERGRAF would like to reinstate its concerns.

The printing industry provides jobs to more than 637 000 Europeans active in 117 000 companies and generates a turnover of approximately € 85 billion.

The European Commission's proposal for a General Data Protection Regulation considerably restricts marketing opportunities of industry and thereby has a serious impact on the entire marketing industry, including on the printing industry. Direct marketing is indeed crucial for our sector. We estimate that approximately 30% of the printing industry’s production is dedicated to direct mail. While experiencing severe economic difficulties for several years now, a change of approach in direct marketing’s practices would jeopardise the existence of many European printing companies.

We therefore count on the Council’s position to secure a workable legislative framework for our companies:

 

Ensure that the ‘right to object’ is not being replaced by a prior consent approach

For the marketing industry in Europe, addressed direct mail is of great importance. It is therefore essential that processing of data for direct marketing purposes continues to be permitted with the recognition of the legitimate interest as legal basis (Article 6.1(f)) without prior consent, but providing for a ‘right to object’ (Article 19).

 

Acknowledge the legitimate interest of third parties to process data

Many printing companies process personal data for direct mail purposes on behalf of their customers. It is essential that they can continue to do so. The legitimate use of data by third parties should explicitly be acknowledged in Article 6.1(f).

 

Recognise the legitimate interest as legal basis for the further processing of data

It is key for our industry that the legitimate interest (Article 6.1(f)) is also recognised as a legal basis for the further processing of data under Article 6.4.

 

Avoid excessive requirements on profiling

Profiling is a legitimate instrument for customer acquisition and retention. It should not be stopped by excessive requirements (Article 20).

 

Avoid disproportionate administrative burden for SMEs

The printing industry consists mainly of small and medium-sized enterprises. The future European Data Protection Regulation should not lead to more bureaucracy and additional information requirements, which would impact in particular small and medium-sized companies.

 

Contact: Laetitia Reynaud

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