The little 'black books’ of luxury retail – are you on the data protection compliance 'A list'?

The little 'black books’ of luxury retail – are you on the data protection compliance 'A list'?

You are a luxury goods retailer with a customer list that is the envy ofevery bored housewife and tabloid editor.  Your customers are discerning and demanding, so you dutifully keep a note ofimportant details such as clothing sizes and colour preferences -  and Duchess Zodiac Tahini, the Bichon Frisé’s, birthday and her requirement for only Icelandic water and venison carpaccio - in a leather-bound ‘little black book’, which is kept under lock and key in the shop safe at the end ofevery day.

Do you have to comply with the requirements ofthe Data Protection Act 1998 in relation to the contents ofthe black book and can the business send emails to those contacts without the 'opt out' ofreceiving more emails that usually accompanies marketing communications?


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Luxury goods retail and 'black books'

It is a common practice for luxury goods retailers to hold records ofspecific information about particular customers—the so-called little 'black book'.

'Black books' can be valuable resources for retailers servicing their big spending clientele to be able to look up individual customers' purchasing histories and preferences and other useful information about them. Such customers also demand a high level ofdiscretion and retailers are expected, both by those customers and the law, to put in place appropriate safeguards to ensure that such information, often deeply personal, remains private and is handled properly.

Traditionally, these black books have been in hardcopy, although these days more are moving online. When multiple customers' data is aggregated in electronic form, this unleashes the potential for retailers to profile customers, mine the aggregated data for potential sales leads and to push targeted marketing to their 'most-valued customers', as well as a range ofother activities.

This post focuses on black books in hardcopy format and the associated data protection issues.

When will the Data Protection Act 1998 apply?

The Data Protection Act 1998 (DPA 1998) will only apply to that information which is ‘personal data’. Section

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