Colour Car Sales Limited's Investigation by UK DPA

€198,000 in fines


UK DPA fined a car finance company for not providing a simple, clear and specific opt-out process for marketing, lack of information about data processing practices, and absence of opt-out option for individuals.

Our analysis

CCSL, a car finance company in the UK, was fined by the Information Commissioner's Office (ICO) for violating Regulation 22 of PECR by sending unsolicited direct marketing messages. Between 2018 and 2019, the ICO received nearly 200 complaints regarding the unsolicited electronic direct marketing text messages sent by CCSL. The ICO found that individuals did not have the option other than agreeing to receive direct marketing, making consent not freely given. Similarly, it was not specific as individuals could not select which party they agreed to receive marketing from, and it was not informed as the information provided was too vague. The company used a hard opt-out process, making it difficult for individuals to opt-out of receiving marketing messages. CCSL claimed to have gathered consent through an application form with no specific reference to direct marketing or purposes of contact from third parties, and there was no method for the individual to apply without consenting to being contacted. The company also failed to provide individuals with the opportunity to refuse or opt-out in the first place.


CCSL was fined approximately €198,000 by the ICO, which considered several factors in determining the amount of the fine. These factors included the gravity of the violation, as well as whether the violation was committed intentionally or negligently, and the extent to which CCSL cooperated with the investigation.


Colour Car Sales Limited (CCSL) and ICO - UK DPA

Case number

Monetary Penalty Notice - 2619914

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