My, perhaps unfair, impression of GDPR is that it has very little concrete and specific rules, and a whole lot of "you'll know when the court delivers the verdict".
My impression is that GDPR is actually pretty clear, but people involved in PI processing business have a strong cognitive dissonance about it. It's GDPR telling them "don't do that", vs. them thinking "I must do that, so GDPR is unclear on how can I do that".
GDPR is very specific. You must have written policies describing what you do with data, what you do if there’s a breach, how people can find out what data you hold, how people can have their data deleted. And you must have consent to contact someone unsolicited. If you don’t have consent you must have legitimate interest. Legitimate interest includes the words “reasonably expect” but that’s pretty standard for laws.
