SOLOCAL: a lead supplier’s promise did not substitute for proof of consent

CNIL found that supplier collection forms used misleading presentation and did not support free, unambiguous consent. It also found that SOLOCAL could not provide proof of consent for data obtained from a principal supplier. CNIL announcement.

The authority treated SOLOCAL as responsible for demonstrating the lawfulness of its own prospecting activity, despite using intermediaries. Authority notice on EDPB.

CNIL imposed EUR 900,000 and ordered electronic prospecting without valid consent to cease. A EUR 10,000 daily penalty was conditional on delay after nine months; it is not added to the recorded fine because this review did not establish that it accrued. CNIL announcement.

These are implementation checks suggested by Inth, not additional findings about the company.

• Retain supplier, form version, notice, purpose, recipients and evidence of the individual’s choice alongside imported leads.
• Stop using a supplier feed when required evidence cannot be produced.
• Check both collection design and proof availability; a contract addresses neither issue by itself.

Code audit can expose reviewed import and sharing changes. Where a choice is collected through Inth, consent records preserve that choice, country and applicable policy.

Those records do not retrospectively validate purchased leads or certify a supplier’s forms. That requires source evidence and legal review.

• CNIL announcement
• Authority notice on EDPB

Source review: 19 October 2026. This is a dated account of the cited authority decision. A recorded fine is not a confirmed payment. Later procedural developments are stated only where the linked record establishes them. Inth wrote the implementation checks; they do not establish legal compliance or replace legal advice.