CompTIA Cloud Essentials+ (CLO-002)Governance, Risk, Compliance and SecurityMedium

A European e-commerce company wants to send marketing emails to customers about new products. Under GDPR, which of the following lawful bases must the company obtain from customers before sending non-essential marketing communications?

  1. ALegitimate interest
  2. BContractual necessity
  3. CLegal obligation
  4. DExplicit consent
Show answer & explanation

Correct answer: D. Explicit consent

Under GDPR, marketing communications generally require explicit, freely given, opt-in consent from the individual, as this processing is not necessary to fulfill a contract or comply with a legal obligation, and legitimate interest is not typically sufficient for direct marketing outreach without consent.

Why the other options are wrong

  • A. Legitimate interest can apply in limited marketing contexts but generally requires an opt-out and is not the primary basis GDPR mandates for direct marketing consent.
  • B. Contractual necessity applies to data needed to fulfill a service agreement, not optional marketing outreach.
  • C. Legal obligation applies when a law requires processing, such as tax reporting, not marketing emails.

GDPR Lawful Basis - Consent

Under GDPR, consent is one of six lawful bases for processing personal data, requiring a freely given, specific, informed, and unambiguous opt-in, commonly required for marketing communications.

  • Must be an affirmative opt-in, not a pre-checked box
  • Individual can withdraw consent at any time
  • Required for most direct marketing communications

Memory trick: CCLVPL: Consent, Contract, Legal obligation, Vital interests, Public task, Legitimate interests

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