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Using AI lead-enrichment tools or bought contact lists? A GDPR Article 14 notice sheet for small businesses: what to tell people and by when

Updated 24 Oct 2026 · Disclosure: the EURO AI Register mentioned below is an Unadhi product with a free edition. This guide is for information only, not legal advice.

What you get: a finished Article 14 notice sheet: one row per contact source you did not collect from the person yourself (AI lead-enrichment tools, bought or rented lists, trade fair badge scans, lists from partners), a deadline formula for when the notice must reach people, one column per information check from Article 14(1) and 14(2), the objection line Article 21 asks for, a result formula, three made-up example rows and first-message wording you can adapt.

Short answer: when you get someone's personal data from somewhere other than that person, Article 14 GDPR says you must tell them who you are, why you use their data, where it came from and what their rights are. The deadline is the earliest of: one month after you got the data, your first message to them, or the first time you pass the data on. Data from public websites is not exempt: the notice must say whether the source was public.

Step 1: which of your contact data is an Article 14 case?

Step 2: the Article 14 notice sheet (one row per source)

ColumnWhat to writeSource
A. Source and AI tool[AI lead-enrichment tool / bought or rented list / trade fair badge scans / list from a partner / web pages collected by a crawler] · [tool or supplier name]Art. 14(2)(f)
B. Data categoriesName, work email, job title, company, phone, plus anything the AI tool adds or guesses (seniority, "buying intent" score, company size). Note guessed fields separatelyArt. 14(1)(d)
C. Date obtaineddd/mm/yyyy the data reached you (import date, export date)Art. 14(3)(a)
D. Planned first contactdd/mm/yyyy of the first email, call or message to the person; blank if none plannedArt. 14(3)(b)
E. Planned first disclosuredd/mm/yyyy you first pass the data to another recipient (a partner, a reseller, another company's CRM); blank if noneArt. 14(3)(c)
F. Notice deadline=MIN(EDATE(C2,1),IF(D2="",EDATE(C2,1),D2),IF(E2="",EDATE(C2,1),E2)) The one-month date is the outer limit; the rule is "within a reasonable period"Art. 14(3)
G. Lawful basis[legitimate interests (Art. 6(1)(f)) + link to your assessment / consent / other] and, for legitimate interests, the interest pursuedArt. 6(1); Art. 14(1)(c), 14(2)(b); Recital 47
H. Article 14(1) items in the noticeY / Partial / N: your identity and contact details (and EU representative if any), DPO contact if you have one, purposes and legal basis, data categories, recipients, transfers outside the EU and the safeguardArt. 14(1)(a) to (f)
I. Article 14(2) items in the noticeY / Partial / N: retention period or criteria, rights (access, rectification, erasure, restriction, objection, portability), withdrawal of consent if consent is the basis, complaint to a supervisory authority, the source and whether it was public, automated decision-making or profiling if it appliesArt. 14(2)(a) to (g)
J. Objection line at first messageY / N: the right to object (and to object to direct marketing at any time) is stated clearly and separately from other text in the first messageArt. 21(2) to 21(4)
K. Exception claimedNone / already has the information / disproportionate effort (write down why: number of people, age of data, safeguards, and publish the information) / laid down by law / professional secrecyArt. 14(5); Recital 62
L. Notice given on, howdd/mm/yyyy · [in first email / separate email / letter / published page if exception K applies]Art. 5(2) accountability
M. Result=IF(COUNTIF(H2:J2,"N")>0,"Fix notice",IF(L2="",IF(TODAY()>F2,"Overdue","Due "&TEXT(F2,"dd/mm/yyyy")),IF(L2<=F2,"Given on time","Given late")))Art. 14(3)
N. Action, owner, date[add source line to first email / add objection line / delete list / stop using guessed fields] · [role] · [dd/mm/yyyy]Art. 5(2)

Put Y, Partial or N in columns H to J. Sort by column M so "Fix notice" and "Overdue" rows come first. Partial counts as a pass in the formula, so read those rows by hand.

First-message wording (adapt to your business)

Email and phone marketing also fall under your country's rules implementing the ePrivacy Directive 2002/58/EC. Those rules decide whether you may send the first message at all; Article 14 only decides what it must say.

Three example rows (made-up businesses, for illustration only)

If you want to claim an exception

Do this week

This sheet is a working aid, not a legal opinion or proof of compliance. References are to Regulation (EU) 2016/679 (Articles 5(2), 6(1), 13, 14 and 21 and Recitals 47 and 62, as published on gdpr-info.eu) and the Article 29 Working Party Guidelines on transparency under Regulation 2016/679 (wp260rev.01). Example rows are made up for illustration and do not describe any real business or supplier. Checked on 24 October 2026. Spot an error in this guide? Write to mininglife7@gmail.com.

For accountants and tax advisers

Small clients who start using AI lead-enrichment tools or buy lists rarely know that a notice is due within a month or at the first message. Hand them this sheet with the client AI inventory so the source, deadline and wording are written down. Stay inside your professional rules and refer legal questions on.

Keep the answer next to your AI register

The EURO AI Register free edition runs in your browser with no account and no upload. It covers your first 10 AI systems and 10 evidence records, the screening questions, duties by role with dates, and a printable Article 4 AI-literacy record. List each AI tool once and attach its notice row and first-message wording as an evidence record.

When you need more than 10 systems, the EURO AI Register membership starts at $19 a month and adds unlimited systems, rule updates and email help. Neither tool is legal advice or proof of compliance.

Partner programme opening soon

Partner programme opening soon: join the free waitlist. Planned terms are 50% of each referred sale (75% once you have 5+ paying customers), single level, paid through Gumroad only from revenue received.

Free start: list your AI tools in the EURO AI Register free edition, then add this sheet. Related: Article 13 privacy notice AI section · legitimate interest assessment · data retention schedule · Article 7 consent record sheet

Sources

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Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.