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People, rules and responsibility: organisation, regulation and sustainability

Is a loyalty data project worth the data risk?

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The prompt

A fictional German retailer with worldwide turnover of EUR 3 billion wants to use loyalty card data to send personal offers. It expects EUR 6 million a year of extra profit. Building proper consent, security and data deletion would cost EUR 2 million once and EUR 0.5 million a year (illustrative). Should it go ahead, and what does the GDPR cap mean for the decision?

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