This assessment applies to direct email marketing sent to UK Limited Companies regarding commercial vehicle sales and finance solutions.
Assessment details
Organisation: Automotivate Fleet Solutions Limited
Assessment date: 1 January 2026
Review date: 31 December 2026
Responsible person: Dominic Ilbury, Director
Processing activity: Direct email marketing to UK Limited Companies regarding commercial vehicle sales and finance solutions.
1. Purpose test
What is the legitimate interest?
Automotivate Fleet Solutions Limited supplies and finances commercial vehicles to UK businesses operating fleet vehicles. We contact Limited Companies to:
- Offer commercial vehicle supply solutions
- Provide business vehicle finance
- Support fleet replacement or expansion
- Inform companies about regulatory or cost-saving vehicle updates
Our legitimate interest is business growth through proportionate business-to-business marketing within our sector.
Why is this legitimate?
- We operate in the commercial vehicle sector.
- We market strictly to Limited Companies (corporate subscribers).
- The services offered are directly relevant to fleet-operating businesses.
- Business-to-business marketing is standard commercial practice.
2. Necessity test
Is email necessary?
Yes. Email is a standard business-to-business communication method. It is low-cost, proportionate and minimally intrusive, and allows recipients to easily ignore, delete or unsubscribe.
What data is processed?
- Business name
- Business email address (corporate domain only)
- Contact name, where available
- Job title, such as Fleet Manager or Director
We do not:
- Use private email addresses, such as Gmail or Hotmail
- Target sole traders or partnerships
- Process special category data
- Conduct intrusive profiling
3. Balancing test
Reasonable expectations
Limited Companies operating fleet vehicles can reasonably expect to receive relevant business-to-business marketing relating to:
- Fleet replacement
- Vehicle acquisition
- Business finance
- Industry updates
The communication is directly relevant to their commercial activity.
Impact assessment
Risk level: Low
- Corporate contact details only
- No sensitive data
- No behavioural profiling
- No automated decision-making
- Limited email frequency
- Clear opt-out in every email
Safeguards
- Limited Companies only, verified through Companies House where applicable
- Corporate email domains only
- Clear sender identity
- Full company details included
- Unsubscribe link in every email
- Immediate suppression-list processing
- Data reviewed and cleansed regularly
4. PECR position
Under the UK Privacy and Electronic Communications Regulations (PECR):
- Marketing emails to corporate subscribers (Limited Companies) are permitted.
- All emails include clear identification and an opt-out.
- Sole traders and partnerships are excluded.
5. Conclusion
Processing is conducted under Article 6(1)(f) UK GDPR — Legitimate Interests.
The interests of Automotivate Fleet Solutions Limited are not overridden by the rights and freedoms of the data subjects.
Approved by: Dominic Ilbury, Director
Date: 1 January 2026