Should you tell customers that you outsource?

Key takeaways

Should you tell customers you outsource? You do not need to announce it in every conversation, but you must not hide it. UK data protection law requires your privacy notice to say who receives personal data and whether it is transferred abroad. Beyond that, be honest if asked and never claim a team is somewhere it is not.

• Privacy notice: name the recipients or categories of recipients of data.
• Disclose international transfers and the safeguards used.
• Never give false information about who or where the team is.
• Customers care most about speed, accuracy and being understood.

Do customers have a right to know?

Customers have a right to know how their personal data is used. Under UK GDPR, the Information Commissioner's Office (ICO) expects a privacy notice to state the recipients or categories of recipients of personal data, and details of transfers to other countries. If an outsourced team handles customer data, the notice should reflect that.

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• GDPR and offshore outsourcing

What exactly must you disclose?

You must disclose who receives the data, at least by category, such as customer service providers, and whether data is sent outside the UK, with the safeguard relied on. You do not have to name every supplier, though you can. You remain the controller and are responsible for what the provider does with the data.

• Recipients or categories of recipients.
• Whether data goes outside the UK.
• The safeguard for any international transfer.
• How people can exercise their rights.

• Data processing agreements for outsourcing

Do you need to tell each caller?

No. There is no general requirement to tell each caller or correspondent that the person helping them works for a partner. Outsourced teams commonly answer in the client's business name. What matters is that nothing said is false. If a customer asks where the team is based, the answer should be truthful.

• Keeping company culture when part of the team is outsourced

What must you never do?

Never mislead. Instructing staff to claim they are in a UK office when they are not, or to deny working for a partner, risks breaching consumer protection law on misleading practices and damages trust when discovered. Using a consistent business name and tone is fine. Inventing locations is not.

What do customers actually care about?

Customers care about being answered quickly, getting the right answer and not having to repeat themselves. Those depend on training, system access and authority to resolve issues, not on who employs the person. A well-briefed partner team usually improves the things customers notice.

• Quality assurance for outsourced teams

When should you be openly proactive?

Be proactive in business-to-business relationships where clients have their own compliance duties, in regulated sectors, and wherever a contract restricts subcontracting. Check your customer contracts before outsourcing work for those clients. Some firms also choose to describe their UK and overseas teams openly as a strength.

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• Outsourcing to Sri Lanka from the UK

What does this look like in practice?

A pattern we see with UK firms that worried about telling customers: the question almost never comes up, and when it does, a straightforward answer such as our customer team includes colleagues at our partner in Sri Lanka is accepted without fuss. Global Bridge Labs (GBL) itself works as a UK and Sri Lanka delivery partner and says so.

• See client work
• BPO Solutions for UK businesses

Disclosure checklist

Complete these before the outsourced team goes live.

• Privacy notice updated with recipients and transfers.
• Processor contract and transfer safeguard in place.
• Customer contracts checked for subcontracting clauses.
• A truthful, agreed answer if customers ask.
• No scripts that state a false location.
• Staff briefed on the same answer.

• Data security with an outsourced team
• Ethical outsourcing for UK businesses

Next step

Tell us what customer data an outside team would handle. We will outline what your privacy notice and contracts need to cover. This is general information, not legal advice.