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LEGITIMATE INTERESTS ASSESSMENT for Example Company Ltd

Example Company has undertaken a Legitimate Interests Assessment and this is documented below. The Assessment conforms to the Guidance for Legitimate Interest Assessments provided by the Information Commissioner's Office ('ICO').

See ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/legitimate-interests

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

Question	Answer
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

Question	Answer
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: