A marketing team proposes using "vital interests" under Article 6(1)(d) to email discount offers because customers "might need deals." Why does that fail GDPR analysis?
Select an answer to reveal the explanation.
Short Explanation
Vital interests is the ambulance basis—not the coupon basis. It covers threats to someone's life or comparable essential interests, not "they might like a sale." Marketing needs a proper ground like consent or carefully assessed legitimate interests.
Full Explanation
Article 6(1)(d) permits processing necessary to protect the vital interests of the data subject or another natural person, typically in life-or-death or comparable emergency contexts. Routine marketing and promotional emails fall far outside that concept. Private controllers may use vital interests in rare true emergencies, but the ground does not require household-wide consent nor does it replace Article 9 for special categories.