An AG opined that consent to marketing by unidentified “partners” is not sufficiently informed

An AG opined that consent to marketing by unidentified “partners” is not sufficiently informed. A later controller must obtain fresh consent before sending electronic direct marketing. English Summary. Facts. In 2021, Groupe Canal + SAS, the controller, carried out electronic direct marketing campaigns targeting approximately 3.9 million people. Their personal data had initially been collected by two internet service providers (ISPs). When collecting the data, the ISPs asked their subscribers to tick a box consenting to the use of their personal data for direct marketing by the ISPs’ “partners”. However, the partners were not identified on the collection form, through a hyperlink or by any other means. Consequently, the data subjects did not know that the controller could subsequently receive and use their data for electronic direct marketing. Following several complaints concerning the controller’s marketing activities the DPA carried out inspections. On 12 October 2023, the DPA found