Asking customers to provide courtesy titles (such as ‘Mr’, ‘Miss’, ‘Mrs.’) is a common business practice, which is particularly popular in the e-commerce sector, where these details, usually collected at the time of purchasing goods or ordering a service, are used for personalisation of any follow-up communication with the customer. Collecting and retaining information concerning the way a particular person wants to be addressed is processing of their personal data. This results in the need to ensure the compliance of such data collection with the EU data privacy law. The recent opinion of the Advocate General of the CJEU in Case C-394/23 can provide crucial guidelines for controllers, who wish to address their customers using the provided titles.
