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