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IDENTIFYING A LEGITIMATE INTEREST
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Question
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Answer
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Why do you want to process the data - what are you trying to achieve?
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Who benefits from the processing? In what way?
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Are there any wider public benefits to the processing?
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How important are those benefits?
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What would the impact be if you couldn't go ahead?
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Would your use of the data be unethical or unlawful in any way?
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THE NECESSITY TEST
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Does this processing actually help to further that interest?
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Is it a reasonable way to go about it?
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Is there another less intrusive way to achieve the same result?
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THE BALANCING TEST
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What is the nature of your relationship with the individual?
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Is any of the data particularly sensitive or private?
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Would people expect you to use their data in this way?
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Are you happy to explain it to them?
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Are some people likely to object or find it intrusive?
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What is the possible impact on the individual?
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Are any of the individuals vulnerable in any other way?
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Can you adopt any safeguards to minimise the impact?
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Can you offer an opt-out?
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OUTCOME OF ASSESSMENT
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Signed: [Signature]
[Name]
Position:
Review Date:
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