Grove Pension Solutions Ltd is a UK-based company that helps
people get "pension releases," i.e. getting money out of
their pensions. The company uses a vendor to conduct lead
generation. That vendor would identify individuals who had given
consent to get messages on a variety of third party websites
(including for example, soapboxsurvey.co.uk). None of the
individuals had a relationship with Grove, and the consents did not
specifically name Grove. Grove sent almost 2 million messages to
individuals following this process, after obtaining advice that
doing so was compliant with applicable laws.
The ICO disagreed, and in its Monetary Penalty Notice,
indicated Grove had violated UK law, which holds that companies
cannot send unsolicited direct marketing emails unless certain
exceptions apply. None of those exceptions were applicable in this
instance, however, according to the ICO. In reaching its conclusion
the ICO stressed that "indirect consent" is not
sufficient for
