Costs and pricing
Lead generation marketplace due diligence for UK buyers: records to request
A checklist of the records, gates and exit proofs UK buyers should request from a lead marketplace before committing budget or signing a contract.
What to take away
- Five record groups matterentity status, lawful basis evidence, supply chain proof, contract terms and exit proofs.
- A per-lead consent log with timestamps is the most useful single document in the pack.
- Verify company filings and data protection registration before the sales call, not after.
- Pay-per-lead, subscription and retainer models need different refund and exit tests.
- Regulated sectors add FCA Consumer Duty duties on top of data protection rules.
Why a shared record pack beats a price list
Sales calls usually finish with a rate card. Due diligence starts with documents instead.
Ask every shortlisted supplier for the same pack. Then grade the answers side by side rather than from memory.
Score each item as supplied, partial or missing. A missing consent log is a harder stop than a higher price.
The pack below lists what a UK buyer can reasonably request before releasing budget. Every item is checkable rather than a verbal promise.
The supplier record matrix
| Record requested | What it evidences | Warning sign |
|---|---|---|
| Companies House filing history | Trading status, accounts, named directors | Recent name changes or dormant filings |
| ICO registration entry | Data protection fee tier and contact | No entry under the trading name |
| Consent and lawful basis log | Lawful basis per campaign and lead | No timestamp or capture source |
| Sub-processor list | Every party that handles the data | Undisclosed call centres or list brokers |
| Upstream source contracts | Control over where leads begin | Supplier refuses to name sources |
| Complaint and refund register | Lead quality tracked over time | No register kept at all |
| Contract and exit terms | Notice, refunds, data return, deletion | No deletion confirmation offered |
Filing history is free to check through Companies House before the first call.
Five checks in order
- Verify the legal entity, its status and its filing history.
- Confirm the data protection registration and the stated lawful basis for contact.
- Request the consent log format for one live campaign, not a mock-up.
- Read the contract for notice period, refund rule and data return wording.
- Run a paid pilot with a written exit test agreed in advance.
Example: a pilot request for one accountancy segment
Send 50 leads for a single service line. Each record must show a timestamp, capture page, consent wording and campaign reference. State how duplicates and wrong numbers are refunded. Return or delete all data within 14 days of written notice.
Contract clauses and exit proofs
Notice periods decide how quickly you can stop paying. Look for 30 day terms rather than rolling 90 day commitments.
Ask what happens to data already delivered. A written deletion confirmation is stronger than a policy statement.
Refund rules should map to named faults. Examples include duplicates, out-of-area leads, disconnected numbers and leads already sold to another buyer.
Check whether the marketplace guarantees exclusivity in a postcode or sector. Exclusivity claims need a clause, not a slide.
Consent, complaints and PECR evidence
Electronic marketing in the UK sits under PECR and the UK GDPR. Consent must be specific, recorded and traceable to a named source.
The ICO publishes direct marketing guidance covering the records a buyer should hold. Keep it open during negotiations.
A supplier that cannot produce a sample consent log leaves you holding the compliance risk.
Complaint volumes also matter. Ask for the count of complaints per 1,000 leads over the last two quarters.
Regulated sectors and Consumer Duty
Mortgage, insurance and investment leads sit inside FCA rules. Consumer Duty requires firms to evidence good customer outcomes, including how often a lead is contacted.
Buyers in those sectors should request contact frequency caps and a complaints summary. A marketplace that cannot supply either adds risk to your regulatory evidence.
Where the next decision sits
Once the records pass, the choice becomes commercial. If your clients are accountancy practices, this comparison for accountancy practices covers filters, tax return leads and firm fit.
Team capability comes next. This skills outlook for lead networks sets out task scenarios and public benchmarks without invented vacancies or pay claims.
Finally, decide how you will test demand yourself. These survey tools versus panel data options differ on cost, speed and sampling bias.
Common questions
What should the first request email contain?
Ask for the legal entity name, data protection registration number, a sample consent log, the sub-processor list and the current contract template. A partial reply is itself information.
How long should a paid pilot run?
Thirty days or 50 leads, whichever comes first. Fix the exit test in writing, covering duplicates, refunds and deletion.
Is a data processing agreement enough?
No. A DPA sets roles and duties, but it does not replace evidence of consent or a refund policy that works in practice.
What if the supplier is an introducer rather than a marketplace?
Ask who determines the purpose of contact and who owns the complaint. That answer decides whether they act as a controller or a processor.
