Easylife Ltd

ICO (United Kingdom) case easylife-2022-10, decided 2022-10-04. EUR 1,500,000.

What the regulator decided

Easylife profiled customers based on items purchased from its non-health catalogue to make assumptions about their medical conditions and then used those profiles to market health products, processing special- category data within Article 9 UK GDPR without an Article 9(2) lawful basis; also made 1,345,732 unsolicited direct marketing calls to individuals registered with the Telephone Preference Service in breach of regulation 21 PECR.

Primary source

Regulator-owned URL. Quote this in legal briefs and academic citations.

https://ico.org.uk/action-weve-taken/enforcement/easylife-limited-mpn/

Archived snapshot

Wayback Machine snapshot of the primary source. Use this when the regulator URL might be refactored or expire.

https://web.archive.org/web/20240617084322/https://ico.org.uk/action-weve-taken/enforcement/easylife-limited-mpn/

ConsentMark interpretation

Operator-readable note on how this case shapes the ConsentMark scanner narrative. Not a legal opinion; cites the primary source.

Native fine GBP 1.35M (combined GBP 1.35M GDPR penalty and GBP 130k PECR penalty). Cite when the scanner narrative needs the precedent that inferring health-related profiles from on-site behaviour triggers Article 9 even if the inputs are not themselves health data - directly relevant to ad-tech audiences built on purchase signals.

Verification trail

Verified by: donal
Verified at: 2026-05-26
Review due: 2026-11-26

Cite this case

Pick the format that matches where you are pasting. The methodology version is preserved in every variant so the citation stays verifiable after future methodology changes.

BibTeX

@misc{consentmark-precedent-ico-easylife-2022-10,
  author       = {{ConsentMark}},
  year         = {2022},
  title        = {ICO (United Kingdom) easylife-2022-10 - Easylife Ltd},
  howpublished = {\url{https://www.consentmark.com/precedent/ico-easylife-2022-10}},
  note         = {ConsentMark methodology v1.3}
}

APA

ConsentMark. (2022, October 4). ICO (United Kingdom) easylife-2022-10 - Easylife Ltd. Methodology v1.3. https://www.consentmark.com/precedent/ico-easylife-2022-10

Markdown

[ICO (United Kingdom) easylife-2022-10 - Easylife Ltd - ConsentMark](https://www.consentmark.com/precedent/ico-easylife-2022-10)

Plain text

ICO (United Kingdom) easylife-2022-10 - Easylife Ltd - ConsentMark, 2022-10-04, methodology v1.3, https://www.consentmark.com/precedent/ico-easylife-2022-10