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The ICC/ESOMAR Code requires that research companies (or research divisions/functions) are transparent in their dealings with individuals and do not misrepresent as research any activity that is outside the definition of research in the Code.

Therefore, whilst the collection and processing of an individual’s data is permitted for a research purpose, the sharing of individually identifiable information with a client (internal or external) for targeting or direct marketing purposes is not research, must not be described as such, and must follow the legal frameworks established for commercial activities such as direct marketing.

There must be a clear distinction within your company or division between the research and data analytics services on the one hand, and individual targeting/ direct marketing, and CRM services on the other - both in external communications, as well in all applicable terms and conditions.
The Notes on How to Apply the ICC/ESOMAR International Code and the Guideline on Distinguishing Market Research from Other Data Collection Activities provide more guidance on this topic.

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