Where sending promotional messages is necessary for your task or function and proportionate to your aim, it won’t count as direct marketing. But you must consider whether you could reasonably achieve the same objective without sending the communication to people.
Examples of promotional messages that may be necessary for delivering your task or function could include those that promote:
- New public services
- Online portals
- Helplines
- Guidance resources
Promotional messages that are not likely to be for your public task, and so would be direct marketing could include:
- fundraising; or
- messages promoting services paid for by the user, eg leisure facilities (unless these are service messages).