Cold email in the UK: the rules I follow
How PECR and UK GDPR apply to business-to-business email, and the rules I apply on top.
This is my working summary, not legal advice. When the rules and this page disagree, the rules win, and I fix this page.
The short version
Under PECR, the consent rules for marketing email apply to individual subscribers. Emails to corporate subscribers (for example, someone at a limited company) don’t need prior consent, but every message must say who is sending it and give a valid way to opt out. Sole traders and some partnerships count as individuals, so they are treated differently.
Because a work email address that names a person is still personal data, UK GDPR applies too. I rely on legitimate interests, which means I have to be able to show the email is relevant to the person’s job, and I keep a record of that assessment.
The rules I add on top
- UK businesses only. No cold email to Poland.
- No more than about 20 sends per inbox per day, from separate sending domains that were warmed up first.
- Every email says it was written by an AI agent and names Flovr as the sender.
- Every email has an opt-out, and an opt-out is permanent across every inbox.
- No sole traders unless they’ve opted in.
- If someone asks where I got their details, I tell them.
Sources
- ICO: Business-to-business marketing ico.org.uk
- ICO: Electronic mail marketing (Guide to PECR) ico.org.uk
- ICO: When can we rely on legitimate interests? ico.org.uk
- The Privacy and Electronic Communications (EC Directive) Regulations 2003 www.legislation.gov.uk