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The Agency Guide to Ethical Demand Generation

14 min

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Synopsis:

How legislation is shaping modern buyer expectations
Why prioritising first-party data is the first step in ethical demand generation
The importance of transparent data collection for building trust and client loyalty

Recommended audience:

This article is tailored specifically for marketing agency professionals operating within the EMEA region.

B2B marketing agencies have traditionally leveraged a combination of in-person sales, referrals, and events with digital practices to craft marketing campaigns that fulfill client objectives.

The goal of these campaigns is typically to find and engage potential buyers through customised marketing strategies that prioritise the prospects most likely to convert.

Technological innovation continues to enable more targeted, data-driven strategies. As buyers increasingly favour independent research and self-guided discovery, B2B marketers must rethink how they meet client expectations and deliver exceptional value—all while upholding the highest standards of ethics and strict compliance with data privacy regulations.

In this article, we highlight how demand generation best practices can complement traditional tactics to enable buyers, build trust, and maintain regulatory compliance.

What is ethical demand generation?

Ethical demand generation is a marketing approach that prioritises transparency, trust, and respect for client privacy while driving interest and engagement.

It involves collecting and using data responsibly, obtaining irrefutable consent, and delivering value-driven content that aligns with the buyer’s needs without manipulative or intrusive tactics. The goal is to build long-term, trust-based relationships while generating demand in a way that respects ethical standards and regulatory compliance.

How to navigate the buyer’s journey with ethical data practices

As agencies craft buyer nurturing strategies for their clients, it is crucial to align with the evolving expectations of today’s privacy-conscious prospects.

The buyer’s journey is no longer a straightforward path to purchase—modern buyers prefer to conduct their own research and engage with vendors only when they are ready to do so (6sense, 2024). This shift requires agencies to develop nurturing strategies that address these buying behaviours and enable self-discovery.

This necessitates a combination of traditional, relationship-building practices such as word of mouth, referrals, and in-person networking with precision targeting based on intent, account, and buyer intelligence.

In this buyer-centric scenario, clients should be positioned as trusted consultants and resources to meet the needs of their prospects. This can be achieved by delivering relevant, personalised buyer-led content tailored to each stage of the process.

Demand generation plays a vital role in building trust and relationships as prospects move from awareness to consideration, and eventually, to conversion.

To ensure this approach does not breach privacy regulations such as the GDPR and other regional laws, agencies must collect and use data ethically. By integrating ethical data practices, agencies can provide tailored experiences that meet the needs of prospects without overstepping boundaries.

As it stands, the General Data Protection Regulation (GDPR) is the cornerstone of data privacy in Europe.

To align with it, agencies and media planners must:

Obtain clear, unambiguous consent before collecting personal data
Use opt-in-led (not opt-out) mechanisms for marketing communications
Clearly explain why you are collecting the data and how it will be used
Allow users to easily withdraw consent or request deletion
Minimise data collection and only collect what is necessary for prospect nurturing
Important note

Europe is not one market—it is many. Be mindful of regional cultural expectations, such as:

Germany and Austria

Extremely privacy-conscious
Requires double opt-in for email lists

France

Very strict on unsolicited outreach
CNIL (local regulator) is active

UK

Follows UK GDPR, which is similar to EU GDPR, but governed by the ICO, meaning it could evolve apart from its EU equivalent
Subject to Privacy and Electronic Communications Regulations (PECR), which outline rules for sending marketing messages, using cookies, and ensuring communication security

Nordic countries

Value transparency and prefer educational or value-driven content before hard sells

Regional laws are governed by regional regulators, such as the ICO in the UK, CNIL in France, and BfDI in Germany. Marketers should always refer back to the regulations specific to the region they wish to launch campaigns.

Below is a list of best practices to keep in mind when sourcing data:

Provide easy-to-understand privacy policies that outline data collection and usage
Allow users to voluntarily provide data
Use clear opt-in forms for newsletters or gated content
Request consent before tracking users with cookies
Avoid gathering more information than needed
Store client data in a secure CRM platform and limit access to authorised users

By leveraging data ethically for demand generation strategies, marketing agencies can enhance relevance, build trust, and guide buyers smoothly from awareness to purchase, improving conversion rates and long-term loyalty.

Example of a B2B buying journey informed by ethical marketing practices

Prospect clicks on a display ad after searching target keywords on a search engine
Prospect is directed to the website linked to the ad
Prospect subscribes to a newsletter, assured that their data will remain private and that they can opt-out at any time
The prospect’s data is securely stored in a CRM with two-factor authentication and access controls, ensuring only authorised personnel can work with it
Prospect receives a newsletter, clicks through to two articles, and reads them in full
Prospect receives a personalised nurture email via the CRM, inviting them to a webinar aligned with their demonstrated interests
Prospect attends webinar
Prospect requests a product demo

"There are no limits to the market if you're not in a highly regulated environment. Going global doesn't mean going everywhere. You need to be very specific, which countries you want to go after and why. And the same with compliance. If you are in a highly regulated industry like finance, for example, you need to take into account all of the legal regulations or restrictions that may arise when you go into a certain market.”

Eustachy Bielecki

Global Demand Generation
Lead - Campaigns,
DeepL

Best practices of ethical demand generation

Ethical data collection is critical, but it is just one aspect of a much more complex buyer-focused strategy.

Below are four best practices for creating high performance demand generation campaigns with ethics and the observance of the applicable laws and regulations.

1. Prioritise first- and zero-party data

What is first-party data?

First-party data is data that is provided directly from clients through an organisation’s proprietary channels.

First-party data, collected directly from user interactions, enables agencies to create personalised, data-driven strategies that respect privacy regulations and enhance client relationships.

First-party data can be collected from:

Forms
Social communities
Sales and CS interactions
Account registrations

What is zero-party data?

Zero-party data is data that has been intentionally and proactively shared by clients.

Zero-party data offers highly actionable insights that reflect the users’ explicit interests. This data is ideal for creating personalised experiences because it is voluntarily shared and aligns with privacy expectations.

Zero-party data can be collected from:

Surveys
Live and in-person events
Webinars
Questionnaires
Chatbots
Reviews
Polls
Direct communication

Considering that second- and third-party data originates from outside the organisation, agencies should prioritise the use of zero- and first-party data. These data sources are not only the most accurate and relevant, but also fully compliant with evolving data privacy regulations, making them indispensable in a modern marketing strategy.

Understanding the different types of data and the advantages of first-party sources will be crucial for navigating this shift.

Important note

Specific types of data have their own privacy consideration. This can vary across sectors.

Most regulated sectors (beyond GDPR) Close
Sector
Data type
Added regulation or restriction
Healthcare
  • Patient health records
  • Genetic and biometric data
  • Clinical trial data
  • EU Clinical Trials Regulation (CTR)
  • Health-specific rules from national authorities are applicable (e.g., CNIL in France, BfArM in Germany)
  • In many countries, secondary use of health data for research or marketing is highly restricted
  • May require approval from ethics committees and data protection authorities
Finance
  • Transaction data
  • Credit history
  • KYC/AML information
  • Payment Services Directive 2 (PSD2)
  • Anti-Money Laundering Directives (AMLD)
  • EBA Guidelines
  • Profiling for creditworthiness is subject to GDPR automated decision making provisions
Education (Minors)
  • Student performance
  • Behavioural tracking
  • Parental contact info
  • Some EU member states ban data collection for advertising purposes in schools
  • Minor and parental consent is required
  • Digital learning platforms must meet strict national procurement and data use standards (e.g., Germany’s Kultusministerkonferenz)
Defense/ Government
  • Classified data
  • Staff biometrics
  • Sensitive operational data
  • National security exemptions under Article 23 of GDPR allow states to enforce stricter secrecy laws.
  • Data often cannot leave the country
  • High thresholds for background checks, vendor risk assessments, and sovereign cloud requirements
Research
  • Personal and experimental data
  • Genetic, behavioural, or survey data
  • Often requires dual-layer consent: one for collection, another for future use
  • Ethics approval and Data Management Plans (DMPs) mandatory for EU-funded research
Children’s Tech
  • User behaviour
  • Location or device data
  • Local age or parental consent required
  • ePrivacy rules applicable
  • France, the Netherlands, and Sweden have cracked down on behavioural advertising to minors
Religion/Ethnicity

Religion, ethnicity, and political opinions

  • Classified as special category data
  • Explicit consent required
  • In many European countries including France, Spain, Germany, Austria and Sweden, collecting this type of data is prohibited

2. Centre your strategies around buyer enablement

Buyer enablement is about equipping potential buyers with the tools and resources they need to make informed decisions at their own pace. For agencies working with clients, adopting a buyer-centric approach signals respect for the preferences of prospects and their privacy—establishing a foundation of trust from the outset.

This strategy is centred around fostering long-term relationships, rather than chasing quick wins, making sure to avoid intrusive sales tactics. By focusing on trust and a buyer-first mindset, agencies can strengthen client-buyer connections, ultimately boosting client lifetime value (CLTV).

What is client lifetime value (CLTV)?

Client lifetime value (CLTV) is the predicted net value a business expects to derive from a client throughout their engagement, accounting for purchases, retention, and associated costs. As a key metric, it helps assess client-centric strategies and long-term profitability.

The simplest way to calculate CLTV is by using the following formula: CLTV = (Average Purchase Value x Purchase Frequency) x Client Lifespan

Agencies that embrace this approach can help their clients achieve significant benefits: higher-quality prospects, improved client retention, and better conversion rates. These results drive sustainable growth, ensuring long-term success for both the agency and its clients.

3. Build trust with buyers through content

Prospects are unlikely to complete a form fill without a compelling reason to share their personal information. For example, tailored, high-value content that directly addresses their unique business challenges. When leveraging content to nurture B2B prospects, it should be thoughtfully crafted using data and insights specific to the target audience, directly addressing their needs.

This approach not only increases the value of the content, but also fosters trust and positions your client’s organisation as a credible authority. By consistently delivering valuable information, your client becomes a trusted resource, allowing buyers to move seamlessly through their research journey and into the sales cycle.

4. Maintain security and data privacy

Data privacy regulations have fundamentally transformed how B2B firms manage and protect data—and, as a result, have informed how prospects expect their data to be handled. 81% of buyers reportedly factor in an organisation’s history with data breaches in their purchasing decisions (G2 Buyer Behaviour Report 2024).

As a result, compliance is no longer just a legal necessity but also a vital aspect of building trust. These regulations mandate businesses to secure explicit consent, safeguard client data, and maintain transparency in how they handle it. Clients are unlikely to partner with agencies that do not meet these needs.

As a rule, agencies should implement robust data security protocols, including encryption, secure access controls, and regular audits to prevent data breaches. Cybersecurity training for employees is also essential, as human error can often lead to vulnerabilities that can be exploited by malicious agents.

How to operationalise compliance

Building processes that are privacy-first, GDPR-compliant, and scalable across countries can still be effective for prospect generation, nurturing, and personalisation.

This can be achieved by taking the following structural approach:

First, establish your agency’s legal bases for data processing. This includes:

Requesting consent for email marketing, profiling, and cookies
Defining what user behaviour or preferences you want to track, while using lightweight, privacy-friendly analytics methods
Maintaining a record of processing activities (ROPA) per Article 30 of GDPR

Consider hiring a data protection officer (DPO) or consultant to fulfil this role. This individual can also assist with creating standardised consent mechanisms for cookies, preference centres and opt-in forms. Privacy tools can also be used, but be wary of non-EU hosted tools that may not meet the standards of the GDPR.

Important: In some regions, like Germany, Austria, and Switzerland, double opt in is required for email lists.

Next, create a data governance workflow that tracks:

What data is collected
Where it is stored
Who processes it (including third parties)
How it is shared
All requests for data access, correction and deletion data audits for all client campaigns

Training your team is essential for ensuring all internal policies and external regulations are adhered to. Create playbooks for training teams on privacy-first marketing, that includes:

Consent wording templates
Lead generation workflows
Data breach protocols
Cookie and email consent best practices
Country-specific rules (France, for example, requires the explicit purpose for data collection)
Policies on data retention (how long it can be stored)
How to vet vendors

Case study: Ethical demand in action

For German client DeepL, INFUSE’s demand experts partnered closely with the marketing team to develop a fully compliant, ethically grounded demand generation strategy. The initiative prioritised high-value content creation and responsible activation across key channels to expand DeepL’s enterprise reach—without compromising data integrity or regulatory compliance.

Launching in early 2024, the engagement began with the establishment of foundational channels and the refinement of DeepL’s ideal customer profiles (ICPs). With these ethical cornerstones in place, INFUSE and DeepL collaborated to build a full-funnel content activation program designed to generate qualified pipeline while respecting user privacy.

Over the course of four carefully executed campaigns, targeting parameters were progressively refined. The third and fourth campaigns focused specifically on DeepL’s ABM list, generating critical insights that informed how to better personalise future outreach—without resorting to intrusive tactics.

Throughout the program, INFUSE applied its ethical demand methodology by:

Leveraging first-party data and opt-in engagement
Applying precision targeting to minimise waste and avoid audience fatigue
Complying fully with German data protection laws and regulations

This case reflects how a strategic, ethical approach to demand generation can empower growth, build trust with enterprise buyers, and deliver sustained marketing performance—all while putting transparency and compliance first.

Key takeaways

As an ethical strategy, demand generation focuses on building long-term relationships with prospects, fostering trust, and offering personalised, valuable content that nurtures them throughout their journey
With privacy regulations like GDPR and CCPA, agencies must prioritise the use of first-party and zero-party data. By leveraging first-party data, validated intent signals, and buyer-led strategies, agencies can identify and engage the right accounts at the right time without relying on non-compliant third-party data
Agencies must implement robust data security practices. Transparency in data collection and offering flexible consent options are key to building trust and protecting client information
Ethical demand generation prioritises buyer enablement and client lifetime value (CLTV) over short-term wins by focusing on nurturing lasting relationships with clients

Empower B2B client campaigns with demand generation

INFUSE demand experts are ready to work with you to develop high-performance strategies to boost client outcomes and revenue.