The breaches related to marketing emails that had been sent to customers after they had unsubscribed from previous messages.
In a statement, Woolworths explained that while they acted on individual Rewards members unsubscribe requests, they did not assume that other members who shared that email address needed to be opted out as well.
Technically, as the Australian Communications and Media Authority (ACMA) alleged in its Infringement Notice - this was a breach of subsection 16(1) of the Act by sending, or causing to be sent, 798 commercial messages to electronic addresses that had an Australian link, which were not designated commercial electronic messages, without the consent of the relevant electronic account-holders. To read the publicly available Infringement Notice, click here.
After the ACMA’s investigation, Woolworths later acknowledged the breaches, and the ACMA’s findings that its systems, processes and practices were not adequate in some instances to ensure customers could unsubscribe.