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Part of How to vet the tools behind lead generation networks
Lead generation networks: the record fields and PECR screening a B2B lead list needs
The record fields a B2B lead list from a lead generation network needs: PECR subscriber type, CTPS and TPS screening, soft opt-in basis, six worked contacts.
What to take away
- Whatever system holds your leads, the first field to add is subscriber type: corporate or individual.
- The PECR rule on marketing by electronic mail does not apply to corporate subscribers, but it applies to sole traders and some partnerships.
- Live B2B calls need screening against both the Corporate Telephone Preference Service (CTPS) and Telephone Preference Service (TPS) registers.
- Contacts of unknown type are a risk, so treat them as individual subscribers until checked.
- No feature in a lead tool replaces these checks. The fields only record that you made them.
Why is subscriber type the first field?
Businesses are classed as corporate subscribers under PECR if they are a corporate body with separate legal status, such as companies, limited liability partnerships, Scottish partnerships and some government bodies. Sole traders and other types of partnerships are classed as individual subscribers and treated the same as individuals.
The difference decides what you may send. The PECR rule on direct marketing by electronic mail does not apply to corporate subscribers. You do not need their consent under PECR to send such messages, but you must not disguise your identity and must give a valid address for opting out. The ICO guidance on business-to-business marketing sets out both groups.
For individual subscribers the rule bites. Regulation 22 requires that the recipient has previously notified the sender that they consent, unless an exception applies. The wording covers sending and instigating, as the text of regulation 22 of PECR shows. A network that supplies leads is not a shield if you instigate the message.
Which six fields should each lead record carry?
Whatever system holds the leads, add these fields to the lead record. Each one records a decision you can show later.
| Field | Example values | Why it exists |
|---|---|---|
| Subscriber type | Corporate, individual, unknown | Decides the email and text rule |
| Legal form | Limited company, LLP, Scottish partnership, sole trader, other partnership | Evidence for the type |
| Email basis | None needed, consent, soft opt-in | Records why you may send |
| Call screening date | Date checked against CTPS and TPS | Live calls need both registers |
| Source and date | Network name, form, import date | Shows where the details came from |
| Opt-out status | Active, unsubscribed, objected | Every message needs a working opt-out |
Keep the type field mandatory on import. A lead without it stays out of campaigns. The CRM integration guide covers how leads from a marketplace reach those fields. The tool implementation article covers rollout order.
How do six sample contacts sort?
The contacts below are invented to show the classification under the PECR subscriber definitions.
| Contact | Legal form | Subscriber type | Email marketing |
|---|---|---|---|
| Acme Components Ltd | Limited company | Corporate | PECR consent rule does not apply, identity and opt-out required |
| Harbour Advisers LLP | Limited liability partnership | Corporate | Same as above |
| Highland Crafts | Scottish partnership | Corporate | Same as above |
| A. Patel, plumber | Sole trader | Individual | Consent or soft opt-in |
| Smith and Jones | English non-limited partnership | Individual | Consent or soft opt-in |
| Northside Services | Not recorded | Unknown | Treat as individual until checked |
Unsure rows matter most. If you are unsure whether the contact details belong to an individual subscriber or a corporate subscriber, you are at risk of breaching PECR. Look up the company number in the GOV.UK service to get information about a company, which gives free company information such as registered address and date of incorporation. Or ask the network for the legal form. Note the answer in the record.
What does the soft opt-in need?
For sole traders and partnerships, electronic mail marketing needs specific consent, or the soft opt-in must apply. The soft opt-in needs all four of these:
- You obtained the contact details in the course of a sale or negotiation of a sale of your product or service.
- It is your similar products and services being marketed.
- You gave a clear opportunity to refuse or opt out when you collected the details.
- You give them an opportunity to refuse or opt out in every communication.
Contacts bought from a network may not meet the first condition, because the sale was to someone else. Record the email basis as consent only if the network can show who consented to what. The legitimate interest versus consent article covers bought leads in more detail.
What about calls and the UK GDPR?
Before you make live B2B calls, screen against both the CTPS and TPS registers, as well as your own do-not-call list. Store the screening date in the lead record.
Personal data in a business context is still covered by the UK GDPR, and Article 6 sets the lawful bases. Consent under Article 6(1)(a) means the person has given consent for one or more specific purposes. Legitimate interests under Article 6(1)(f) are a separate basis, which yields where the person's rights override them.
If you collect an individual's contact details in their business capacity and intend to send direct marketing, you must tell them and have a lawful basis for the processing.
Use the data protection article to map that basis, and the quality checklist to score a batch before it enters the system.
Common questions
Does a corporate subscriber need to consent to B2B email?
No. The PECR rule on electronic mail does not apply to corporate subscribers. Identity and a valid opt-out address are still required.
Can a CRM decide the subscriber type for me?
It can store the value. The decision rests on the legal form of the business, which you check from the record and the network's information.
Which lawful basis applies to a bought lead?
Under UK GDPR Article 6, consent for specific purposes and legitimate interests are separate bases. Record which one you rely on. Then use the supplier comparison to ask each network what evidence it holds.
