ylop
Well-Known Member
The ICO doesn’t agree with you: Principle (b): Purpose limitationNo, data can be used for other purposes if they are legal, and there is no legal barrier to keeping users informed about the system being closed in any law I’m aware of. GDPR explicitly allows it, for instance.
Whether it’s feasible is another matter as you rightly point out.
Now it may be that the original purpose already covered informing users about the planned future/end of the service or something close enough to it to be “compatible with the original purpose”, and indeed it would be unusual if they collected email addresses and didn’t use them to tell you about stuff like this, but as a general rule an organisation can’t gather data for one purpose and then use it for another purpose.
By the way I just had a skim through the privacy notice - I don’t think it explicitly says they will collect your email address anywhere! Weirdly it says they will send you stuff but not how! I suspect like most Privacy Notices it was created because they have to, rather than because they wanted to. And this will be an awkward one - it’s the RYA’s notice but they are just white labelling someone else’s product so the RYA actually don’t have much say in how it works.