Cold emails and GDPR

  • 6 December 2022
  • 4 replies

Badge +6

Hi there,


I have been offered work with a client who wants to send emails using a list which he built himself through years of going to networking and exchanging business cards. He wants me to cold email his list (he has about 5,000 contacts).


Cold email is still valid but I’m confused by GDPR as I thought that ANY email needs an opt-in. Apparently not.


Here’s my plan and I’d love some feedback. Assume that the emails have an option to opt out, are from a warmed trusted ESP, don’t contain spam, data is stored safely etc.


  1. Go through the list and clean it – each and every cold lead needs to have a genuine reason why they could benefit from the sender (aka “genuine interest”). No point including car wash businesses if we are selling beds for example.
  2. With what’s left, start with phone numbers (which he has collected via asking people at events or checking out their website) and cold call them. They vaguely remember him from events which warms them a little, then start a conversation. It doesn’t have to be salesy, and even if they aren’t interested right now we can ask if they know anyone who might be interested in the specific service. Mark down by each number who is a lead and who didn’t pick up – call later.
  3. Move on to business emails if we don’t have a number. If it’s a business email address then we can send whatever we need and not legally worry about consent (but we will still be otherwise compliant and respectful). Ask the business for the person who we want to get a hold of (we already know the lead’s name but we need proof that the business gave it to us) and just say that we met the person at networking or work or whatever. We will send a follow up email if the business doesn’t reply.
  4. If we are left with personal emails, don’t cold email them to be safe. Go to their website, get the contact from there so we can prove it’s publicly available and then cold call them. No pick up? Cold email them with the business email.
  5. If any contacts are left that are personal emails, and have no phone numbers, and don’t have a business email address publicly available, don’t risk sending promotional email.



4 replies

Userlevel 7
Badge +61

Hi @Owens_CW,

Thanks for sharing this question with us.

List cleaning as a preliminary step is always a great idea, especially when you’re talking about getting into contact with a list that has been built over the course of several years. And scanning for relevance, as you point out, is an important part of that. Generally I think your workflow makes a lot of sense and assuming you’re following all of the GDPR guidelines, I see no issues with the strategy. 

Interested to hear others chime in on this as well :) 

Userlevel 4
Badge +7

Are you intending to cold call them to qualify them as email leads?


Badge +6

Are you intending to cold call them to qualify them as email leads?


No I wasn’t. How would I do this? I don’t think that cold emailing needs an initial outbound email to check if they want to receive another email, so long as they have the option to opt out at any time and are a B2B email address.

How would I phrase it? “Hi, can I have permission to send you a cold email?” That would be ignored or be put in spam. Im not sure I understand your question

Userlevel 4
Badge +7

I think I may have misunderstood the sequence you propose . When you say cold call do you mean a telephone call or email?