birthday-offer

---
name: birthday-offer
description: Builds the one email automation that pays for itself - a birthday message to your own customers, with the offer, the timing, the wording and the lawful basis all written down. Use when you hold birth dates in a booking system, a loyalty card or a sign-up form and have never used them.
---

# Turn the birthdays sitting in your booking system into tables you did not have

You give this whatever holds your customers' birth dates: a Collins diary, a booking-system export, the paper loyalty cards in the drawer, the sign-up form on the website. You get back a roster of who to message and on what date, the offer itself with its terms written so it cannot be argued with, the exact send wording, and a one-page note saying why you are lawfully allowed to send each one. It refuses to send to anyone whose date you cannot evidence, and it never guesses a year of birth.

## What it does

1. **Separate the dates you were given from the dates you inferred.** Go through every source and record, for each person, the date, where it came from and the date it was collected. A birth date typed by the customer into your booking form is evidence. A birth date a member of staff guessed from a "30th birthday" note on a reservation is not, and a date you worked out from a driving licence shown at the door is not yours to keep. The ICO's guidance on collecting information for direct marketing is direct about the transparency side: "You must tell people that you want to collect and use their information for direct marketing purposes. You must be clear about what you want to do and your privacy information must be easy for people to understand." If nobody ever told a customer their date would be used for marketing, the date goes in a separate list headed "collected without notice, do not send" and the skill tells you what to put on the form so next year's dates are clean.

2. **Keep the day and the month, and throw the year away.** You need 14 March to send a birthday message. You do not need 1978. Holding a full date of birth on a marketing list gives you an age, an age gives you an inference, and inferences are where this gets expensive: the ICO states that if your processing "intends to make an inference linked to one of the special categories of data", or you "intend to treat someone differently on the basis of inferred information", you are processing special category data whatever your confidence. Age alone is not a special category, but a full DOB on a marketing table invites age-banded offers nobody agreed to. Keep one exception: if the offer involves alcohol you must be able to establish the person is over 18, and you do that at the door with Challenge 25, not from a spreadsheet column.

3. **Write the lawful basis on the roster, per person, before writing a word of copy.** Two routes exist and they look identical to the customer. Route one is specific consent to marketing emails. Route two is the soft opt-in in regulation 22(3) of PECR, which applies where the details were obtained "in the course of the sale or negotiations for the sale of a product or service to that recipient", the marketing is for "similar products and services", and the person was given "a simple means of refusing" at collection and in every message since. A diner who booked a table, gave their date on the booking form and was offered an opt-out qualifies. A person who entered a prize draw at a wedding fair did not buy anything from you and does not. Put the route in a column. Any row you cannot label goes to the do-not-send list.

4. **Decide the offer in pounds before you decide the wording.** Take your actual gross profit on the item you are giving. A free dessert at £2.10 food cost, given to a table of four spending £96, is the cheapest booking you will ever buy. A free bottle of house wine at £6.40 cost, given to a table of two, is not the same thing at all. Set a minimum condition that matches the maths, state it plainly, and never dress a conditional offer as an unconditional one. CAP rule 3.23 prohibits describing a product as "free", "gratis", "without charge" or similar if the consumer has to pay anything other than the unavoidable cost of responding and collecting. A complimentary dessert that requires two main courses is not a free dessert. Call it what it is: "a dessert on us when two of you eat with us".

5. **Fix the redemption window and put the closing date in the email.** Give a window wide enough to be usable and narrow enough to plan around: the seven days either side of the birthday is the usual shape, because most people eat out on a weekend near the date rather than on it. State the exact closing date in the message. CAP rule 8.17.4.a requires "a prominent closing date, if applicable, for purchases and submissions of entries or claims", and rule 8.17.4.e says closing dates "must not be changed unless unavoidable circumstances beyond the control of the promoter make it necessary". If you are not certain you can honour it in the second week of December, do not offer it in December.

6. **Write the significant conditions once, in the email, not on a page nobody opens.** The conditions that decide whether a customer bothers coming belong in the message itself. Minimum spend. Whether it is one per person or one per table. Days excluded. Whether it can be combined with a set menu. Whether booking is required. CAP rule 8.17 requires that all marketing communications referring to promotions "communicate all applicable significant conditions or information where the omission of such conditions or information is likely to mislead", and regulation 7 of the Electronic Commerce (EC Directive) Regulations 2002 requires a commercial communication to "clearly identify as such any promotional offer (including any discount, premium or gift) and ensure that any conditions which must be met to qualify for it are easily accessible, and presented clearly and unambiguously".

7. **Guard the alcohol and the under-18s at the point the offer is designed, not at the till.** CAP rule 8.4 states that "Alcoholic drinks must not feature in promotions directed at people under 18" and that "Alcohol must not be available on promotion to anyone under 18", and rule 8.5 says promotions "must not be socially undesirable to the audience addressed by encouraging excessive consumption or irresponsible use". A birthday list built from a family restaurant's booking system will contain children. If you do not hold a reliable year of birth, and step 2 says you should not, then the drink cannot be the birthday gift. Make the default gift food or a non-alcoholic item, and let the manager upgrade it at the table for someone who is visibly and verifiably an adult.

8. **Send fourteen days before the date, and once.** Fourteen days is enough for a table to be booked and a party to be organised without the message being forgotten. One message per birthday, per year. Not a teaser, a reminder and a last chance: three messages to celebrate somebody's birthday is three chances for them to unsubscribe, and PECR requires "a simple means of refusing" in every single one of them. Every message carries the unsubscribe, the business's full trading name and a reply-to address a human reads, because regulation 23 of PECR forbids sending marketing email "where the identity of the person on whose behalf the communication has been sent has been disguised or concealed" or "where a valid address to which the recipient of the communication may send a request that such communications cease has not been provided".

9. **Record the redemption against the row, so next year you know what it earned.** Print or display a code per person, one line in the till notes, or simply a manager's tally. Record: sent, opened if you have it, redeemed, and the total spend of the table that redeemed. At the end of twelve months you will have the only number that matters, which is covers gained against gross profit given away. Keep the suppression list for anyone who unsubscribed and screen next year's roster against it before a single send. The ICO is explicit that this is allowed and expected: keeping a suppression list "isn't for direct marketing purposes", it is kept so that you can comply with an objection.

## Then it checks

1. Every row on the send roster carries a lawful basis of either "consent" or "soft opt-in, PECR 22(3)", plus the source document and the date the detail was collected, and no row reads "assumed" or "from the diary".
2. No row on the send roster holds a year of birth, and no segment, offer or wording in the output varies by the customer's age.
3. The offer text states the minimum spend, whether it is one per person or one per table, the exact closing date in DD Month YYYY form, and any excluded days, and the same conditions appear in the email body rather than only behind a link.
4. Nothing described as "free" in the output has any condition attached to it, and every conditional gift is worded as conditional.
5. No alcoholic item appears as the default gift on any roster where a reliable adult age is not evidenced for that person, and every alcohol line carries the over-18 check at the point of service.
6. Every roster row has been screened against the suppression list, and the count of rows dropped by that screen is shown in the output rather than silently removed.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is.
- Never guess, infer or buy a birth date. A date you cannot point to a source for is not a date, it is a reason for a complaint to the ICO with your name on it.
- Never let the offer vary by inferred age, gender, dietary preference or postcode. The moment a birthday offer differs by group, you are profiling, and the ICO's position is that profiling which infers anything within a special category requires an Article 9 condition on top of your lawful basis.
- Never send a second or third birthday message to the same person in the same year. Frequency is the single complaint that turns a warm customer into a spam report, and a spam report costs you delivery to everyone else.
- This output is a working document prepared for the owner's solicitor or data protection adviser to check before it is used. It sets out what published guidance says and applies it to your list; it is not legal advice on your obligations under PECR or the UK GDPR.

## Built from
- Information Commissioner's Office, "Electronic mail marketing", https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guide-to-pecr/electronic-and-telephone-marketing/electronic-mail-marketing/, no publication date shown on the page, read 14 September 2026: the two lawful routes in step 3 and the requirement in step 8 that identity is not concealed and a valid contact address is given.
- The Privacy and Electronic Communications (EC Directive) Regulations 2003, regulations 22 and 23, https://www.legislation.gov.uk/uksi/2003/2426/regulation/22 and https://www.legislation.gov.uk/uksi/2003/2426/regulation/23, made 18 September 2003, read 14 September 2026: the verbatim soft opt-in conditions that the roster's lawful-basis column is built from, and the two prohibitions quoted in step 8.
- Committee of Advertising Practice, "03 Misleading advertising" and "08 Promotional marketing", https://www.asa.org.uk/type/non_broadcast/code_section/03.html and https://www.asa.org.uk/type/non_broadcast/code_section/08.html, no publication date shown on the page, read 14 September 2026: rule 3.23 on the word "free" in step 4, rule 8.17 on significant conditions and 8.17.4 on closing dates in steps 5 and 6, and rules 8.4 and 8.5 on alcohol in step 7.
- Information Commissioner's Office, "What is special category data?", https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/special-category-data/what-is-special-category-data/, latest update shown as 9 April 2024, read 14 September 2026: the inference test quoted in step 2, which is why the year of birth is discarded and why the offer is not allowed to vary by group.
- Information Commissioner's Office, "Collect information and generate leads" and "Respect people's preferences", https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/direct-marketing-guidance/collect-information-and-generate-leads/ and .../respect-peoples-preferences/, no publication date shown on the page, read 14 September 2026: the transparency line quoted in step 1, and the suppression-list position quoted in step 9.
- The Electronic Commerce (EC Directive) Regulations 2002, regulation 7, https://www.legislation.gov.uk/uksi/2002/2013/regulation/7, made 30 July 2002, read 14 September 2026: the requirement in step 6 that a promotional offer is identified as such and its conditions presented clearly and unambiguously.

# Birthday roster builder

## You are given
One or more files holding customer records for a UK hospitality business: a booking-system export, a loyalty-card CSV, a spreadsheet, or a folder of photographed paper forms. Fields vary. Somewhere in them are names, email addresses, birth dates in mixed formats, and a note of where each record came from. You may also be given an unsubscribe or suppression list, and a plain-text description of the offer, its minimum spend and its redemption window.

## Produce
Write these files into `./birthday-offer-output/`:

1. `birthday-roster.csv` with exactly these columns: `customer_ref`, `first_name`, `email`, `birth_day`, `birth_month`, `source_file`, `source_row`, `date_collected`, `lawful_basis`, `send_date`, `window_opens`, `window_closes`, `status`. `birth_day` is 1 to 31 and `birth_month` is 1 to 12. There is no year-of-birth column and you must not add one. `lawful_basis` is exactly one of `consent`, `soft-opt-in-PECR-22(3)` or `unlabelled`. `send_date` is the birthday minus 14 days, in DD/MM. `status` is `send` or `hold`.
2. `do-not-send.csv`, same columns, holding every row whose `lawful_basis` is `unlabelled`, whose email is missing or malformed, whose birth date could not be parsed unambiguously, or which matched the suppression list. Add a final column `reason`.
3. `offer-terms.txt`, a plain-text block of the offer conditions: what is given, the minimum spend, one per person or one per table, excluded days, whether booking is required, and the closing date written as DD Month YYYY.
4. `counts.txt`: rows read per source file, rows on the roster, rows held, and a count per hold reason.

## Rules
- Never infer, estimate or complete a birth date. An ambiguous date such as `03/04` with no stated format goes to `do-not-send.csv` with reason `ambiguous date format`.
- Never write a year of birth, an age, or any age band to any output file.
- Deduplicate on lowercase email address. Where duplicates disagree on the date, hold both with reason `conflicting dates`.
- Match the suppression list on lowercase email, trimmed.
- Do not send any email, call any API, or contact any person. You produce files only.
- Use British date order and the pound sign in `offer-terms.txt`.

## Return
Print the absolute path of each file written, the four counts from `counts.txt`, and the list of hold reasons with how many rows each accounted for. If any source file could not be parsed, name it and say why rather than skipping it silently.