Earlier this month, the UK Information Commissioner’s Office (“ICO”) announced a fine in a case that involved inferring health data and using this for marketing. The ICO found that catalogue retailer Easylife Limited (“Easylife”) had profiled 145,400 individuals for inferred health conditions without their consent, based on certain “trigger products” that they had purchased from Easylife’s Health Catalogue. For example, if a customer bought a jar opener or a dinner tray, Easylife would infer that the customer might have arthritis, and then call them to market glucosamine joint patches. The ICO has fined Easylife £1.48 million: £1.35 million for using customers’ personal information to sell health-related products without their consent, and a further £130,000 for making unsolicited direct marketing calls.
Continue Reading ICO Fines Easylife £1.48 Million For Data Protection and E-Marketing Violations
Alex Carn
Alex Carn is a London-based associate in Covington’s international disputes and public policy practice groups.
Alex has experience with international commercial and investor-state disputes across a range of industries including the technology, telecoms, life-sciences, construction, energy, financial services, transport, and luxury goods sectors. He has advised on disputes under a range of relevant laws including English, U.S. state and federal, French, Swiss, Belgian, Saudi, DIFC, UAE, Singaporean, and Malawian law. Alex is experienced with major arbitral rules, having conducted arbitrations under the ICC, LCIA, DIAC, and SIAC rules, as well as ad hoc proceedings under the UNCITRAL rules.
Alongside his international disputes work, Alex also advises on public policy issues, with a focus on the Middle East and Africa. Alex has advised sovereigns on regulatory reform of multiple sectors including sports and defence and assisted corporates with government engagement and regulatory issues in the automotive, defence, energy, food and beverage, financial services, consumer goods, healthcare, and technology sectors.
Alex is admitted to practice as an English solicitor and a New York attorney.