The Bill passed its Report Stage and Third Reading in the Commons last week, and we can be sure that no amendments will change the way that charity soft opt-in should be allowed once it becomes law.
The Bill now returns to the Lords, this week, for consideration of the other amendments and we might see the Bill become law before the Summer recess, or certainly in early Autumn.
We are already seeing rumours about how some aspects of charity soft opt-in may work, but the only guidance that matters is from the ICO, our regulator. They quickly need to issue guidance on two issues that will both be huge for charities:
- Will the soft opt-in be retrospective or will it just apply to data collected after the bill becomes law?
- Will soft opt-in apply to data obtained from third parties, e.g. fundraising and event booking platforms (the current ‘commercial’ soft opt-in excludes this)?
As soon as we hear anything from the ICO, we will let you know.