Attending or exhibiting at exhibitions? What happens to your personal data?

One of the most important principles to be followed under data protection legislation is transparency. In short, if you capture in any way personal data you must provide a statement to data subjects of what happens to that data, what you do with it and how you keep it secure.

With BETT 2025 in mind we decided to take a look at the privacy notice published by the event organisers Hyve. As a major, well resourced organisation, we expected this to be very clear in the way personal data is handled and that proves to be the case.

The privacy notice can be found here.

What we found in our review

We were impressed by the presentation of the notice. In particular, information about a data subjects rights is presented upfront – in the early part of the document. This information is frequently left until near the end of a notice.

BETT 2025 will be attended by numerous delegates from overseas countries. That point is not overlooked as the geolocation of the data subject – and the potential for local laws to have different emphasis - is not overlooked, with annexes to the UK notice providing information across multiple jurisdictions and with emphasis that the delegate might have additional rights through local laws.

Privacy notices can be updated from time to time and the reference point for any consent previously given is the notice in place at the time the consent was taken. Hyve make clear the date on which the notice was last updated.

How does Hyve use personal data in their own interests?

The Hyve website indicates that they expect more than 10,000 attendees. The Hyve database of contacts will be much greater than that number. For Hyve, personal data is an extremely valuable asset. It will be used to market intensively throughout the year but always with opt out functionality in the mailings sent.

Hyve sets out clearly where its data comes from and it’s not just by registering on the Hyve website. Data also comes from public sources such as Companies House and data brokers. The latter may strike you as questionable. In pre-data protection law enforcement days there were many businesses data scraping and selling data in unscrupulous ways. Data brokers still exist taking care to manage their business compliantly.

As long as the data subject has been made aware of the collection of the data in the first place, how it may then be used, and what rights the data subject has, this is fine. This could be by an email from the data broker or within the terms and conditions of any kind of sales agreement or contract entered into.

Data will also be shared with data aggregators –– the stated purpose being to “enhance the data we hold and provide our exhibitors with aggregated reports” (but these are stated not to include personal data).

If exhibiting, what do we need to be aware of?

To be clear you do not have an automatic right to have delegate data shared with you. If, however, you take advantage of badge scanning you are able to access delegate details but only with the consent of the individual – consent being given through the individual’s agreement to have the badge scanned.

From that point on you will be able to use that data to the advantage of your organisation – but at the same time have compliance duties which begin before the badge is scanned. Do you have a copy of your privacy notice prominently displayed on your exhibition stand? Arguably, a QR code linking to it suffices, but making things as easy as possible for the delegate is recommended. The data subject has the right to review information about what happens to the personal data before any consent is taken.

For exhibitors, and indeed any delegate, there are other routes to obtaining personal data. Using the BETT App and arranging meetings with delegates will involve the capture and use of personal data.  Note that the App will have its own customised privacy notice that can also be scrutinised before consent is given through registration on the app.

BETT 2025 will have sponsors – do they have greater rights?

They do, as is made clear in the Hyve privacy notice. In the case of sponsors data is shared as part of the sponsorship arrangement – the explanation provided in the privacy notice is:

“so that they can better plan their sponsorship to enhance attendee experience and where applicable to provide you with marketing communications or to invite you to private briefings” The notice emphasises that the data sharing is subject to confidentiality undertakings regarding the use of the data.”

Whether or not you are attending BETT these are some valuable hints and tips for your own marketing and preparation for any events that you become involved in, or organise within your own business.

The Freeths data team would be glad to help you with any questions that you have in this important compliance area.

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The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.

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