A change to UK email marketing law this year gives charitable attractions a new way to stay in touch with people who support their work. With Christmas campaigns beginning to ramp up now, here’s what museums, heritage sites, wildlife attractions and nature destinations need to know.

On 5 February 2026, the charitable purposes soft opt-in came into force under the Data (Use and Access) Act 2025. The Information Commissioner’s Office (ICO) published its final guidance on using it in April.

The change means charities can send marketing by email, text and social media direct message to people who have expressed an interest in, or offered or provided support for, their charitable purposes, without asking for consent first. Strict conditions apply.

For charitable attractions, this opens up a way to engage supporters at Christmas and build relationships that last beyond a single visit.

Could buying a ticket count as charitable support? 

One example in the ICO’s guidance will feel familiar to many attractions, a visitor buys an entry ticket to a historic mill run by a heritage preservation charity.

The charity is satisfied that the visitor has bought a service and also supported its heritage preservation work. So at the online checkout, it offers two separate opt-out boxes. One covers emails about similar products and services, such as future exhibitions or guided tours. The other covers emails about its charitable purposes, such as volunteering, donation requests and updates on its work.

If the visitor doesn’t opt out of either, the charity can contact them about both.

The same logic could apply across the sector. A family visiting a wildlife attraction may be contributing to conservation. A visitor to a historic house may be helping to preserve it. A museum visitor may care about protecting its collections for future generations.

However, a ticket purchase does not automatically qualify. The ICO is clear that a purchase which is incidental, made for convenience, or made as an ordinary consumer rather than a supporter won’t count. Buying a coffee in a charity’s café and giving an email address for a receipt is not support in this sense.

The ICO recognises some purchases as clearer signs of support. These include annual memberships, animal sponsorships, charity raffle entries and paid places at fundraising events.

Christmas is a natural moment to connect the visitor experience with the mission behind it.

For organisations that meet the ICO’s requirements, the charitable purposes soft opt-in could support:

• Christmas giving appeals: inviting supporters to contribute to conservation projects, heritage restoration or learning programmes.
  
  
• Animal adoption and sponsorship: a popular festive gift that directly funds conservation work.
  
  
• Festive volunteering: promoting ways to get involved over Christmas and into the new year.
  
  
• End-of-year impact updates: showing supporters what their donations and involvement achieved in 2026.
  
  
• Looking ahead to 2027: introducing the projects and fundraising priorities supporters could help bring to life next year.
  
  
• The aim is relevance rather than volume: messages for people who have already shown they care about what you do.

For attractions with both commercial and charitable activity, this also means separating two groups. One is people interested in visiting again. The other is people interested in supporting your wider work.

The soft opt-in does not open up your existing visitor database. To rely on it, organisations must meet all of the following requirements:

• Be a charity. The organisation must be a charity under the law of England and Wales, Scotland or Northern Ireland. Non-profits and social enterprises that are not charities can’t use it.
  
  
• Collect contact details directly. The charity itself must obtain the details. The ICO says this excludes details collected by third parties, including online fundraising platforms and trading subsidiaries. If you sell tickets or memberships through a trading company, check this first.
  
  
• Demonstrate charitable interest or support. The details must be collected when the person expresses an interest in, or offers or provides support for, the charity’s purposes.
  
  
• Keep the marketing about your own charitable purposes. Messages sent under this provision must solely further your own charitable purposes. They can’t promote other organisations, including partners, sponsors or other charities. Where you hold both types of soft opt-in for someone, a single message can cover both.
  
  
• Offer a clear opt-out when you collect details. The opt-out must be prominent at the point of collection. Adding one to a later order confirmation email does not meet this requirement.
  
  
• Offer an opt-out in every message. Every email, text or message must include a simple way to opt out.

The provision only applies to details collected on or after 5 February 2026, and it is not retrospective. Contacts already on your database who never consented aren’t automatically covered. They can come into scope when they engage with you again, provided you offer the opt-out at that point. For many attractions, Christmas bookings and gift purchases could be that moment.

You will also still need a lawful basis under UK GDPR. For most charities, this will be legitimate interests, supported by a documented legitimate interests assessment.

With Christmas campaigns approaching, now is a good time to review how you collect and manage supporter information. There are three practical areas to focus on.

Map your visitor and supporter journeys and look at every point where contact details are collected, from ticket purchases and memberships to donations and volunteering enquiries. For each one, check whether the charity or a trading company collects the data. Check whether the interaction shows support for your charitable purpose. And check whether the right opt-outs appear at the point of collection.

Check your CRM and email preferences, as your systems need to tell apart three things: commercial soft opt-in, charitable purposes soft opt-in and explicit consent. If you rely on both soft opt-ins, the ICO requires separate opt-out choices, and your CRM needs to record and respect each one.

Plan fundraising communications around supporter interests, rather than sending one Christmas appeal to every eligible contact, consider how different audiences connect with conservation, heritage, learning or community work.

The biggest gains are likely to come from deeper relationships rather than bigger lists. 

Christmas is a timely prompt, but the implications run all year.

A one-off visit might lead to a membership. An interest in conservation could lead to volunteering. Engagement with a heritage project might encourage someone to support future restoration

The ICO’s guidance gives eligible charities more flexibility to develop these relationships, provided they respect people’s preferences and meet the legal requirements.

The opportunity this Christmas is to recognise when a visitor is also a supporter, and give them good reasons to stay connected.

The soft opt-in is one of several opportunities open to charitable attractions.

Google Ad Grants offers up to $10,000 a month in search advertising credit. Canva for Nonprofits provides free design tools. Many organisations aren’t making full use of either.

Eligibility requirements apply to both. For qualifying organisations, these resources can support greater visibility, stronger fundraising campaigns and more effective use of marketing budgets.

At Navigate, we help museums, heritage organisations, cultural attractions and nature destinations find opportunities to grow their audiences and make more of their marketing.

Get in touch to explore the benefits available to your organisation and how to make the most of them.

None of these additions needs a new plan, only a bit of attention in the right places before the season gets busy. If you'd like to talk any of it through, let's have a discussion.

Email us at hello@navigate.agency or book a meeting

• ICO: Charities given new flexibility to contact supporters under data law change
• ICO: How to use the charitable purposes soft opt-in
• Fundraising Regulator: Charitable purposes soft opt-in and fundraising marketing

Fundraising Regulator: Charitable purposes soft opt-in and fundraising marketing

This article provides general marketing guidance rather than legal advice. Charitable organisations should review the ICO’s guidance and assess their individual circumstances before using the new provision.