Loyalty Programs and GDPR: Is Your Solution Safe Enough?

‍“Do you want to become a member? You get discounts and exclusive offers!”

We've heard it many times — whether it's in-store, online, or through an app. Loyalty programs have long been a natural part of the customer journey and a smart tool for building relationships and increasing resale. But amid the hunt for conversions and customer data, it's easy to forget one thing:

Is your benefits program actually in line with GDPR?

In this post, we go through the most common pitfalls — and what you should do to ensure both compliance and trust.

1. Do you leak personal data at checkout?

It may seem innocent, but even small routines in daily life can involve the risk of privacy violations. Examples we often see:

• Employees who ask aloud, “Is it still 98765432 which is your number?”
• In-store displays where the customer enters email while others watch
• Receipts showing date of birth or other personal data

The GDPR clearly states: Personal data should not be accessible to unauthorized persons. Also at the moment they are collected.

2. Is the consent valid -- or just practical?

A “Yes Thank You” at the checkout is not enough.

According to the GDPR, consent must be:

• Volunteer: Customers should be able to say no without feeling pressured
• Specifically: You must ask for your own consent for marketing, analytics and personalisation
• Informed: The customer should understand what they are saying yes to
• Easy to withdraw: A click, not a marathon

If employees record information without the customer actively understanding what it entails, it's time to clean up.

3. Are you gathering more information than you need?

GDPR requires data minimization — you should only collect what is necessary for the specified purpose.

Think through:

• Do you need the full date of birth, or does it keep with the month of birth?
• Why require a home address, if you only send email?
• Is ID number really necessary?

The more data you collect, the more responsibility comes with it.

4. Is the data used as promised?

Customers who sign up for a loyalty program give away information with an expectation: that it is used only as communicated. Not for:

• Advertising through third parties
• Targeted advertising without explicit consent
• Sharing across companies in the Group

GDPR's principle of purpose limitation says: If you're going to use data for something new -- you need to get new consent.

5. Do customers know what rights they have?

Members in a benefit program are entitled to:

• See what's stored
• Get errors corrected
• Request deletion
• Withdrawing Consent — Easily and Anytime

If this is difficult to figure out, or the process is complicated, it is not in line with GDPR. And it quickly creates distrust.

Time for a reality check?

Many benefit programs haven't changed in a decade -- but the regulations have.

GDPR isn't just about laws and forms — it's about trust. A secure and transparent loyalty program brings value to both the business and the customers.

Has you taken a review of their program lately? If not, you may want to do it now.

At Increo, we help businesses build digital solutions that both convert and protect their privacy. Get in touch and we'll have the talk.

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