Legitimate Interest Assessment Template

Part 1: Purpose Test

1.1 Why do you want to process the data?
To send marketing emails, product information and company information in order to maintain and grow the marketing reach of our business.

1.2 What benefit do you expect to get from the processing?
Generating new business leads whilst increasing and maintaining awareness of our products, our brand, our services and solutions.

1.3 Do any third parties benefit from the processing?
No.

1.4 Are there any wider public benefits to the processing?
The content we produce is freely available via our website or social media. Our marketing emails are used to promote content and features that may otherwise be missed.

1.5 How important are the benefits that you have identified?
Important to us. As a provider of software solutions and services, our email database is a primary method of making contact with existing customers, and reaching out to potential customers.

1.6 What would the impact be if you couldn’t go ahead with the processing?
A reduction in our marketing reach which could impact generated leads. Reduced customer engagement and awareness of Sensorpro and our services.

1.7 Would your use of the data be unethical or unlawful in any way?
No

Part 2: Necessity test

2.1 Will this processing actually help you achieve your purpose?
Yes - we believe so.

2.2 Is it a reasonable way to go about it?
Yes - we believe so.

2.3 Can you achieve the same purpose by processing less data, or by processing the data in another more obvious or less intrusive way?
We do not believe so.

Part 3: Expectations test

3.1 What is the nature of your relationship with the individual?
Some individuals on our mailing list are existing customers – so we know these individuals directly. Some have directly expressed interest in our products, services and solutions via our website or at an event. Depending on the circumstances, we may or may not know these individuals directly.

3.2 How has the data been obtained? If supplied from a third party what did they tell the individual about reuse?
If the individual is an existing customer, the data is obtained via our internal systems (such as a CRM or the account management module in our software).

3.3 Do you have the means and processes to keep the information up to date?
We believe we have the technical means, but there are no strict processes in place to ensure this.

3.4 Is any of the data particularly sensitive or private?
We do not believe the data we hold and process to be of a sensitive nature.

3.5 Would people expect you to use their data in this way?
We believe the majority of individuals would expect their data to be used in this way.

3.6 Are you happy to explain it to them?
Yes.

3.7 Are some people likely to object or find it intrusive?
A small number may object, but we do not consider our messaging to be excessive or intrusive. We aim to ensure that our messaging is relevant and of interest to the individual. If it is not, we provide an easy way for them to opt-out of receiving future emails.

Part 4: Impact test

4.1 What is the possible impact on the individual?
We believe the possible impact on the individual to be mostly positive. The messages we send aim to be informative of the industry and our solutions. We believe these messages to be of potential interest to the individual, however if the impact on the individual is negative, they can opt-out at any time.

4.2 How big an impact might it have on them?
If negative, we believe the impact on the individual to be minor. Our email marketing campaigns focus on quality over quantity. We aim to send individuals no more than 2 emails per month and ensure that the content we share will not cause offense.

4.3 Are any of the individuals vulnerable in any other way?
We do not believe individuals to be vulnerable in any other way.

4.4 Can you adopt any safeguards and technical measures to minimise the impact?
We can adopt technical measures to ensure that only engaged individuals continue to receive messages from us. An ‘engaged’ individual can be identified using Sensorpro's "last response date" and star rating (indicating activity level). Individuals who are not engaged for more than a year should be removed from our list.

4.5 Can you offer individuals an opt-out?
Yes.

Part 5: Decision

Outcome date: 22nd August 2019
Outcome: We can rely on legitimate interests for this processing

Credit: sensorpro.net