Lapsed or finished clients: what to send whom, within the GDPR

Whether a client counts as 'lapsed' depends on your sector and the treatment. A hair salon expects someone back within a few weeks, a laser clinic only after a full course, and with tattoo removal there comes a point where the client is simply done. So start by separating clients who would normally return from clients who have finished their treatment. Send the first group a reminder and the second a thank-you with a review link and a referral link. In the Netherlands you can usually email existing clients without asking for consent first, as long as you follow a few rules.

Lapsed or finished: two different clients

A lapsed client would normally come back but has not. Think of someone who has a haircut every month, a recurring facial or maintenance for injectables. Staying away is then a signal.

A finished client has completed a course of treatment. Someone who has had a tattoo removed will not come back for it, and that is the whole point. The same often goes for a full course of laser hair removal. A reminder is pointless then, but you do want to stay in touch.

Set the moment yourself, per treatment

No single period fits every salon or clinic. Look at the natural rhythm of each treatment and decide per treatment when you follow up. For example:

• Hair salon or barbershop: the rhythm follows hair growth and style. If a regular skips their usual appointment, follow up.
• Recurring facial: use the schedule you advise yourself. If someone goes past that advice without a new booking, she has lapsed.
• Injectables maintenance: the doctor decides when a check-up or new treatment makes sense. Follow up around that moment, and never advertise the product itself.
• Laser hair removal: during the course, a missed appointment means a lapsed client. After the final session of the series, the client is finished.
• Tattoo removal: after the last session the client is finished. A long gap between sessions is often just part of it.

In your booking system, list clients per treatment whose last visit was before a given date, and note whether each is still mid-course or done. In accounts we review, we often see every client who has not been in for a while getting the same email.

What do you send a lapsed client?

With a lapsed client, it is all about rebooking. Keep it personal and make the step small: one message mentioning the last treatment, a reason to come now and a link to your diary. No discount is needed; that way clients do not learn to wait for a deal.

Example: 'Hi Sanne, your last facial with us was in June. Would you like to book the next one? You can see our free slots here: [link]. Rather not hear from us? Unsubscribe here: [link]. Best wishes, Eva at [salon name].'

No response? Send one or two follow-ups at most, a few weeks apart: something new that suits what she had before, and finally a question about whether she still wants to hear from you. That keeps your list clean.

What do you send a finished client?

Someone who has completed a course is often your best ambassador. Shortly after the last session, send a thank-you with a link to write a Google review and a referral link they can use to send someone else your way, possibly with a gift as thanks.

Keep a few rules in mind:

• Never give anything in exchange for a review. Google's review policy prohibits offering discounts, gifts or free services for a review. Ask every client, not just the happy ones; selective requests are not allowed either.
• So link the gift only to the referral, and keep the two clearly separate in your message.
• Let the client share the link themselves. Do not ask for friends' email addresses so you can email them: those people are not your clients and have not given consent.
• Take extra care with medical treatments. Do not offer a gift that promotes a medical treatment, never name the product for botox or fillers, and if in doubt, check whether your gift fits the rules for your profession.

Example: 'Hi Mark, your final session is done, thank you for your trust. Would you share how you found the treatment? You can do that here: [review link]. Know someone still in two minds? Send them this link and, as a thank-you, you will receive [gift]: [referral link].'

Skin clinics: a related follow-up treatment

A skin clinic is well placed to suggest a next step. Someone who has finished treatment for one concern may be interested in a treatment that builds on it, such as skincare after a course. Using treatment history, you can send a more targeted message than a general newsletter.

There is an important caveat. Treatment records can count as health data, which the GDPR treats as special category data with extra protection. So do not simply select clients by concern or treatment. Have it checked whether and how you may do this, for example by letting clients explicitly choose at intake whether they want tips about follow-up treatments.

What does the law allow?

In the Netherlands, marketing by email, WhatsApp and other electronic messages falls under the anti-spam rule in the Telecommunications Act: you need consent in advance, with an exception for existing customers. The Dutch regulators ACM and the Autoriteit Persoonsgegevens describe it as follows:

• The person must genuinely have been a client, meaning they bought or booked something from you.
• The message is about your own products or services that relate to what the client bought before. Advertising for another business is not covered.
• You gave the client the chance to object when you collected their details, and you do so again in every message.
• Unsubscribing is quick and free, with no complicated questionnaire.
• You are recognisable as the sender, using your own business name rather than an alias.

After an opt-out, send no more marketing. Keep a record of it so the person does not return at the next import. Someone who only asked a question or downloaded a guide but never booked is not an existing client, so you need their consent.

For WhatsApp, WhatsApp's own business policy requires that the recipient has agreed to receive messages, so ask for that separately, for example when they book. Never send the same message on three channels at once. This is a summary, not legal advice. If you are unsure about your own situation, have it checked.

Measure what it brings in

Count each group separately: how many lapsed clients rebook, how many finished clients write a review, how many new clients arrive through a referral link and how many people unsubscribe. Use a separate link for each message.

The next step

Start with one treatment: work out its rhythm, split the list and write one message for each group. If you would like help, book the free Clinic Scan. Thomas calls you briefly first, we analyse nine areas and in a 30-minute call you get a tailored proposal. You are free to carry out the plan yourself.

Frequently asked questions

When does a client count as lapsed?

It differs by sector and by treatment. Look at the natural rhythm of the treatment: if someone does not come back when that rhythm says they should, they have lapsed.

Can I give a gift for a review?

No. Google's review policy prohibits offering anything in exchange for a review. A gift as thanks for a referral is possible, kept separate from the review request.

Can I email lapsed clients without consent?

Usually yes, if the message is about your own services related to what they had before, you are clearly the sender and every message has an easy unsubscribe link. If you use treatment records to select recipients, check first whether that is allowed, because they may count as health data.