When a customer withdraws marketing consent after paying a deposit, stop the affected marketing activity through the relevant systems and clarify any separate request about the service or booking. A marketing opt-out should not be lost in a finance inbox, and it should not be interpreted as an instruction to cancel an order unless that is what the customer has actually requested.
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The PDPC’s consent guidance recognises withdrawal of consent. Your response should identify its scope and consider any applicable exceptions, rather than treating all uses of the customer’s information as identical.
Read the request before changing the account
Does the customer object to promotional emails, telephone marketing, disclosure to a particular partner, or all further use of certain data? Does the message also ask for a refund or cancellation? Break the message into its separate instructions so each can reach the correct person.
If the wording is genuinely unclear, ask a focused question. Do not require the customer to explain why they no longer want promotions. Also avoid using a clarification request as a reason to keep sending the very campaign they have clearly rejected.
Suppress the campaign at its actual source
Update the relevant marketing system, not merely a note in the invoice ledger. Identify scheduled messages, advertising audiences and approved campaign providers that rely on the affected consent. Confirm what needs to stop and who can make the change.
- Record the request’s date, channel and scope.
- Apply the relevant suppression or preference setting.
- Check queued promotions and downstream campaign lists.
- Tell the responsible team what was changed.
- Retain an appropriate record so the person is not accidentally added back to the same campaign.
Do not export a complete customer database to solve a single opt-out. Limit the update information to what the receiving team or authorised provider needs.
Review service correspondence separately
A booking confirmation, a genuine clarification about an order and a promotional message have different purposes. Review the content and the applicable basis for each communication. Adding an advertisement to a service message can change the nature of what you are sending.
Where withdrawal affects the company’s ability to provide a service, explain the actual consequences clearly and obtain advice on the applicable obligations. Do not describe every optional use of data as essential simply because it is convenient for your sales team.
Example: a course booking and a mailing list
A customer pays a course deposit, then asks to leave the company’s promotional mailing list. The company should handle the mailing preference through its campaign system. It should separately determine what communications are appropriate to administer the existing booking. If the customer also wants to cancel the course, the cancellation request needs its own assessment under the booking terms and applicable law.
Do not promise that every financial record has disappeared
A withdrawal request and a request to delete records are different issues. Identify what the customer has asked for and review retention against the relevant business and legal purposes. Preserve records required for an actual obligation or dispute while protecting them and restricting unrelated use. Do not tell a customer their deposit record has been deleted if finance still needs it for reconciliation or another lawful purpose.
The sensible question is what each record is retained for, who can access it and when that purpose will be reviewed. A blanket label such as “keep forever because paid” is not a retention policy.
Send an accurate confirmation
Explain what preference was updated and where the customer can raise a separate service or record-handling question. Avoid making promises beyond the changes you have verified. If another provider must complete an update, keep ownership of the follow-through and record the outcome.
Does an opt-out automatically entitle the customer to a refund?
Do not infer a refund decision from the marketing instruction. Identify the actual cancellation or refund request and assess the contract and applicable law.
Can sales manually add the customer to a later campaign?
Check the recorded preference and the lawful basis before any later use. A new spreadsheet should not erase the company’s knowledge of the earlier withdrawal.
Related guidance
- Mapping the personal data your company holds
- Organising a data protection management programme
- Background on company data protection obligations
Help with company compliance and privacy matters
If you would like assistance organising your company’s compliance procedures or obtaining advice on a privacy issue, email [email protected] or WhatsApp +65 8501 7133. Our team can assist with corporate secretarial, accounting and tax matters. Where legal advice is needed, advisers from our associated law firms can assist. This is general information; legal advice should address the facts of the particular request or dispute.