Using directors' names: UK GDPR in plain English

A director's name is personal data, even though it is on a public register. If you use it to contact someone, UK GDPR applies. The usual lawful basis for business marketing is legitimate interests, with a duty to tell people about it and to stop if they object.

Public does not mean free to use

Information being on the Companies House register does not remove your obligations. UK GDPR applies whenever you identify an individual by name, even in a business setting.

Legitimate interests

For marketing that PECR does not require consent for, such as a letter to a director at their company's registered office, many organisations rely on legitimate interests. In general you should:

1. Identify a purpose: for example, offering a relevant business service.
2. Check it is necessary: could you reach the business without using personal data?
3. Balance it: consider whether the person would reasonably expect this and whether it could harm them. A business-relevant letter to a director is easier to justify than something unrelated or intrusive.

Write the assessment down. Where PECR requires consent, such as email to a sole trader, legitimate interests cannot replace it.

Transparency

When you collect someone's details from a source other than the person, you must give them clear privacy information. In practice that means your first message should say who you are, why you have their details, where you got them (public records such as Companies House), how to object and how to find your privacy notice. Keep a privacy notice on your website.

The right to object

People have an absolute right to object to direct marketing at any time. When someone objects, stop. Keep their details on a suppression list so you do not contact them again.

Good habits

• Use only what you need, such as a name and a business address.
• Do not keep data longer than you need it.
• Keep a record of your reasons and of objections.

Official guidance

• ICO: direct marketing guidance
• ICO: business-to-business marketing

General guidance, not legal advice. Last reviewed October 2026.