If you’re using tools like Lusha to dig up leads, you’ve probably wondered if you’re skating close to the edge with privacy laws—especially GDPR. The truth: There’s no magic button that makes your B2B lead generation instantly compliant. But with a clear process, you can keep your outreach on the right side of the law (and avoid a nasty fine).
This guide is for anyone using Lusha to source leads in the EU, or who might accidentally scoop up EU data while prospecting. If you’re a sales, marketing, or ops person who wants to keep things simple and legal—read on.
1. Understand What GDPR Demands (and What It Doesn’t)
Let’s start by cutting through the noise. The GDPR is all about protecting the personal data of EU residents. “Personal data” means more than just emails—it’s anything that can identify someone, including work emails, phone numbers, LinkedIn profiles, and sometimes even job titles.
Key things you need to know:
- GDPR applies if you’re processing (collecting, storing, or using) data about people in the EU—even if your company isn’t based there.
- B2B data isn’t exempt. Just because it’s a work email doesn’t mean you’re off the hook.
- You need a legal basis to process data. For lead generation, “legitimate interest” is usually what companies lean on, but you need to justify it.
- Transparency is key. People need to know you have their data and what you plan to do with it.
What GDPR doesn’t require:
- Consent for every cold email (but you need a valid reason and have to be respectful).
- Keeping records “just in case.” If you don’t need the data, delete it.
2. Map Out Your Data Flow with Lusha
You can’t protect data you don’t understand. Before you get fancy, sketch out:
- What data you collect: Names, emails, phone numbers, company info, LinkedIn URLs, etc.
- Where it comes from: Lusha, LinkedIn, your CRM, public websites.
- Where it goes: CRM, spreadsheets, email tools, shared folders.
Pro tip: Draw a simple flowchart or list. You want to spot any points where data could leak, get misused, or just hang around longer than needed.
3. Check Lusha’s GDPR Story—But Don’t Just Take It at Face Value
Lusha markets itself as GDPR compliant. That’s a good start, but you’re still on the hook for what you do with the data.
What to look for:
- Data source transparency: Can you explain where the data came from if someone asks? Lusha says it only uses publicly available or user-contributed info, but double-check their Privacy Policy and ask for specifics if you’re unsure.
- Data processing agreement (DPA): You’ll need one with Lusha. This outlines how they handle and protect data for you. If you don’t have it, ask their support.
- EU data storage: Make sure Lusha stores and processes data in line with GDPR standards (ideally in the EU or with proper safeguards).
Don’t: Assume that just because Lusha says “GDPR compliant,” you don’t have to do anything else.
4. Set (and Document) Your Legal Basis for Outreach
Most companies rely on “legitimate interest” to justify collecting and contacting B2B leads. But you can’t just say “legitimate interest” and call it a day.
How to do it right:
- Write down your reasoning. Why is contacting these leads necessary for your business? Why does your interest outweigh the potential privacy impact on the person?
- Perform a Legitimate Interest Assessment (LIA). It’s not rocket science—just a short doc outlining your logic. There are plenty of templates online.
- Be prepared to show this if you’re ever challenged. Don’t bury it; keep it handy.
If you’re in doubt—especially if your outreach is high volume or very cold—talk to a privacy lawyer. Better safe than sorry.
5. Update Your Privacy Notice (And Actually Tell People About It)
GDPR means you need to be upfront about what you’re doing with people’s data—even if you found it through Lusha.
What your privacy notice should cover:
- What data you collect and where you get it (yes, say you use tools like Lusha).
- Why you’re processing it (e.g., business outreach, sales).
- How people can opt out or ask for their data to be deleted.
- Who to contact with questions (your DPO, if you have one, or a generic privacy email).
How to deliver it:
- Cold outreach: Include a short privacy blurb and a link in your first email. You don’t need a legal essay—just something like:
“We process your business contact info to offer relevant services. Details: [privacy link]. Let us know if you want to opt out.” - Don’t: Hide the notice in tiny print or only on your website.
6. Give People Control (Opt-Out and Data Requests)
Under GDPR, people have the right to know what data you have on them, ask you to fix it, or tell you to delete it.
You need to:
- Make it easy to opt out. Every outreach email should have a clear way to unsubscribe or say “stop.”
- Respond to data requests fast. You’ve got one month to answer requests for access or deletion. Don’t panic—just have a process.
- Keep it simple: A shared inbox or ticket system is fine. Don’t overcomplicate it with fancy software unless you have to.
What to ignore: You don’t need to build a self-service portal unless you’re dealing with tons of requests. Most smaller teams can handle this manually.
7. Keep Data Only As Long As You Need It
Don’t hoard old lead lists. GDPR says you can’t keep personal data “just because”—you need a reason.
Best practices:
- Set a retention policy. For example: “We delete unresponsive leads after 12 months.”
- Delete data promptly when someone asks.
- Regularly review your CRM and email tools. Purge what’s stale.
Pro tip: Document your policy (even a couple of sentences). If you’re audited, you’ll be glad you did.
8. Train Your Team—And Keep People Honest
Most GDPR screw-ups are just human error. Make sure everyone involved in lead gen knows the basics:
- What data you’re collecting (and why).
- How to respond if someone asks about their data.
- How to spot and report a data breach.
A quick onboarding doc and a yearly refresher are usually enough.
Don’t: Assume people will “just know.” You’ll be surprised what slips through the cracks.
9. Watch Out for Red Flags
Not all lead-gen is created equal. Here’s what should make you pause:
- Mass scraping: If you’re using Lusha or any tool to pull thousands of contacts with zero targeting, that’s risky.
- Sensitive data: Avoid collecting anything beyond business contact info—especially personal numbers, home addresses, or anything not work-related.
- Unusual sources: If you can’t explain how you got the data, don’t use it.
When in doubt, skip the sketchy stuff. Regulators have little patience for “but everyone else does it.”
10. Keep It Simple (and Don’t Buy the Hype)
There’s no silver bullet for GDPR compliance. Most of it is common sense: be respectful, don’t hoard data, and be honest about what you’re doing. If you’re ever in doubt, ask yourself: “Would I be annoyed if someone used my data this way?” If the answer is yes, rethink your approach.
Summary:
GDPR compliance with Lusha isn’t complicated, but it does take intention. Map your data, document your decisions, and be transparent with leads. Skip the snake oil and the scare tactics. Keep your process lean, adapt as you go, and remember—most of your competition is probably winging it. You can do better.