2. Can an AI receptionist make sales calls or chase quotations automatically?

Why should outbound AI voice receive extra scrutiny?

The ICO has considered a system using a short AI-generated greeting before a human took over. It concluded that the described system fell within PECR’s automated-calling definition and required specific consent for the marketing call. The definition includes systems that automatically initiate sequences of calls and transmit sounds that are not live speech. ICO innovation-advice example. (cy.ico.org.uk)

Recommended purchasing position: do not approve outbound AI sales calling merely because the supplier describes it as conversational rather than prerecorded. Require a written Regulation 19 assessment of the actual system and the permission evidence it will use.

The cited example is not a comprehensive ruling on every real-time generative-voice architecture. That remaining classification question is a reason to seek specific advice—not an exemption to assume.

When are service reminders actually marketing?

The ICO distinguishes a factual appointment notification from a message promoting a service plan. Adding a promotional offer can make a message direct marketing even when it also contains service information. ICO small-business guidance.

These classifications are workflow recommendations based on the ICO distinction; the exact wording, purpose and circumstances matter.

Does an existing customer list permit automated email and SMS marketing?

Not automatically. The products-and-services soft opt-in requires direct collection during a sale or negotiation, marketing of the sender’s similar services, an opt-out at collection, and an opt-out in subsequent messages. A quote request can constitute negotiation, but it does not remove the other conditions. ICO direct-marketing guidance.

PECR also distinguishes corporate subscribers from individuals, including sole traders and some partnerships. Do not label every commercial HVAC contact as exempt B2B data. ICO electronic-mail guidance.

Ask the agency to demonstrate: permission source, collection date, channel, approved message purpose, and an opt-out propagating into every connected campaign. A contact record without permission evidence should enter an exception queue—not automatically enter a reactivation campaign.

Have the cookie changes made marketing tracking consent-free?

No. The statistical-purposes exception is limited to qualifying analytics for improving a service or website, with clear information and a simple, free objection mechanism. The ICO expressly distinguishes this from advertising, individual tracking and profiling; combining an exempt purpose with a non-exempt one can still require consent. ICO exceptions guidance · ICO multipurpose-technology guidance.

For a trades-focused marketing agency, request a technology-by-technology inventory. Do not accept a blanket statement that DUAA permits all analytics, advertising pixels or lead tracking without consent.