Sphere Of Interest - Latitude & Confines
Click4Filters Ltd send reminder e-Mails to our customers to let them know their water filter is due for renewal.
Usually 1 eMail every 6 to 12 months.
We have not asked customers for explicit consent to contact them. We have relied on existing legislation & the accepted concept of soft opt-ins, whereby existing customers who have successfully purchased & provided their e-Mail during the course of a purchase, As initial contact was made by the customer we consider this to be the basis of implied consent for relevant activities.
On all mailings we provide the ability for the customer to withdraw from further marketing.
General Data Protection Regulations (GDPR)
New GDPR regulations, effective May 25th 2018, permit companies to continue on the basis of previous legislation without consent subject to completing a Legitimate Interest Assessment (Recitals 47, 48, 49).
This document complies with our auditing & accounting obligations under Articles 5(2) and 24.
We do not sell products to minors.
The products we market, should not spark the interest
of minors who may seek to purchase the product, in accordance with our terms & conditions of trade.
Hence the breath of this assessment & the core assumption will be all Data Subjects are over 18 years.
Legitimate Interest Test
Why do we want to process this data ?
What are we trying to achieve?
As outlined, the sending a reminder e-Mails
to a previous customer, with a view to informing them,
their existing filter is due replacement.
Who benefits from the processing? In what way?
It is fair to assume, we benefit
if the customer chooses to make a purchase.
The nature of the products is such that over time & used beyond their quoted lifespan there is a risk
(increasing with time) of the product becoming unsafe, unsanitary or structurally impaired.
These opinions are shared industry wide,
including professional bodies, scientific study
& medical best practices.
Given a risk exists the customer is also likely to benefit as a result of Us extending a duty of care.
In the event a product did develop a problem,
evidence of a read electronic communication
which proves receipt could potentially be deemed sufficient to cover our obligations to the customer.
Customers should always read the appliance manual & fully understand the risks of not maintaining a product.
Furthermore we are unable to ascertain if the products are being installed by professionals, friends or third parties.
The customer may or ma not have understood the risks to themselves, their family or property through neglect or poor maintenance of their product.
Any wider public benefits to the processing ?
Poorly maintained products used in apartments,
blocks of flats, HMOs & similar carry a risk of potential damage, in the event of long term structural failure
How important are those benefits ?
Experience of the industry & working with customers
has demonstrated many people are unaware their filters require changing - partly due to the period of time
(typically 6 to 12 months)
& people simply forgetting the product is due for renewal.
Impact be if we couldn’t go ahead ?
Expected levels of customers not replacing their cartridge would potentially increase.
Consequently this would open up
the aforementioned risks to the customers / family visitors & their immediate neighbours
Would our use of the data be unethical or unlawful in any way?
We have not identified any issues which may be deemed unlawful or unethical.
Does this processing actually help to further that interest?
The use of the data in sending an email to the Data Subject allows us to inform the customer that the cartridge is due for replacement and to provide them an expedient option to order a replacement.
Is it a reasonable way to go about it?
The method informs the customer without putting them under the pressure to make a purchase on the spot. The tone and content of such emails is intended to be ‘informative’ first and foremost.
Is there another less intrusive way to achieve the same result?
Of the three viable options - Telephone, Email or Written Letter, we consider Email to be the least intrusive option. Calling customers on the phone puts them under unnecessary pressure that may be considered exploitative to certain demographic groups. Written letters carry a significant carbon footprint both in their production and their delivery. Emails are quick, efficient, arms-length (if the customers wishes to ignore them, they can) and essentially represent the ‘most environmentally friendly’ method of communicating with a Customer.
Q1/ What is our relationship with the individual?
All Data Subjects receiving a reminder eMail will be existing customers who have previously made a purchase To make a purchase customer provide an eMail address for order confirmations, receipts & order updates.
Q2/ Is any of the data particularly sensitive or private?
We do use the customers name, eMail address, postal address & the filter(s) previously purchased.
No private/personal notes associated with, sent by or sent to the customers form part of the system nor is any financial information (credit card details etc) required.
Q3/ Would customers expect us to use their data in this way?
We have been sending reminders to customers by eMail since our systems supported online ordering.
Given the technical nature of the product & the fact it is limited in life, it is our view that customers would expect a communication to let them know the product life has effectively ‘expired’.
Q4/ Are we happy to explain it to them?
Any customers with concerns on our use of their data,
or who would like to ask questions as to this Legitimate Interest Assessment, may eMail myself at
Please add the headed GDPR to your eMail
Our aim would be to respond to customers questions & concerns within 48 hours.
Q5/ Objections or find or messaging intrusive?
Customers may have made provisions to replace
their filter themselves & may consider it unnecessary to receive a reminder eMail
However we don’t feel it could be considered intrusive.
Q6/ What is the possible impact on the individual?
Worst case - the customer will receive an additional eMail which they need to delete & / or click the link to request
no further emails are sent.
Q7/ How big an impact might it have on them?
The actions required in the unlikely event of a negative impact on a customer (ie. unsubscribing) are outweighed by the benefits brought to the majority of customers in terms of health & updated on their product.
Q8/ Are any individuals vulnerable in any other way?
We are unable to ascertain if anyone may be vulnerable due to the nature of the business (mail order).
However, as we only market to customers who have made a previous purchase the assumption is that being able to make an informed decision on the initial order would,
in the vast majority of cases, allow them to make the same level of judgement on subsequent orders.
Q9/ Safeguards adopted to minimise the impact?
eMails are kept factual.
Our information / data logging are checked
& systems are in place to ensure this is accurate.
We appreciate it is possible that errors can be made
However, we will tryto ensure this does not happen.
Our e-Mail systems log all outbound e-Mails
& in the event of any query we maintain adequate information in order to diagnose any technical errors.
Q10/ Opt-out of messaging supplied.
All reminder eMails have a clear opt-out,
which we log & respect explicitly.
Any customer who wishes to receive no further reminders will be removed from future mailings.
Customers will be assessed as ‘ no more ’ & be removed from the reminder system,
if they ignore 5 successive reminders within 3 years
We have chosen 3 years,
as this is the timeframe for which some of our range
has to be supported under UK Consumer Goods
This statement has been prepared by Peter England
in the capacity of Director for Click4Filters Ltd.
Contact: [email protected]
Questions may be raised in writing to:
54 - Valletort Road, Stoke,
Plymouth. PL1 5PN