Legitimate Interests Assessment
PART 1: PURPOSE TEST
Why do you want to process the data?
To continue to send marketing messages in order to maintain the growth of City Financial Models Ltd.
What benefit do you expect to get from the processing?
Increased sales, but also continued engagement with our customers by sending them updates of our products and services.
Do any third parties benefit from the processing?
We do not share your information with third parties, unless to comply with our legal obligations.
Are there any wider public benefits to the processing?
No.
How important are the benefits that you have identified?
The maintenance of a clean accurate list of customers, prospects and suppliers is essential to the smooth operation of our business.
What would the impact be if you couldn’t go ahead with the processing?
Loss of sales.
PART 2: NECESSITY TEST
Will this processing actually help you achieve your purpose?
Yes, our contact list is our principal means of reaching current and new customers.
Is the processing proportionate to that purpose?
Yes.
Can you achieve the same purpose without the processing?
No.
Can you achieve the same purpose by processing less data, or by processing the data in another more obvious or less intrusive way?
No.
PART 3: BALANCING TEST
NATURE OF THE PERSONAL DATA
Is it special category data or criminal offence data?
No.
Is it data which people are likely to consider particularly ‘private’?
No. It is either publicly available or has been already been collected through direct contact with the individual. For unsolicited B2B communications, we collect and process only company name, name, job title, work email address, work postal address and work phone numbers.
Are you processing children’s data or data relating to other vulnerable people?
No.
Is the data about people in their personal or professional capacity?
Professional.
REASONABLE EXPECTATIONS
Do you have an existing relationship with the individual?
Yes, in some cases, but in others we make unsolicited communications where there is an existing or potential commercial relationship.
What is the nature of your relationship with the individual?
We are either a supplier or prospective supplier to, or a client of, the organisation that the individual represents.
Would people expect you to use their data in this way?
Yes.
LIKELY IMPACT
What is the possible impact on the individual?
We are simply sending messages, which can be opted out of at any time. We believe any impact our messages have will be largely positive.
Will individuals lose any control over the use of their personal data?
No, they can update their information anytime.
Are some people likely to object or find it intrusive?
A very small minority of people may object, but we don’t believe our messaging to be excessive or intrusive, given that the individual can unsubscribe at any time.
Would you be happy to explain the processing to individuals?
Yes.
Can you adopt any safeguards to minimise the impact?
We take every reasonable step to minimise the impact of our data processing.
Can you offer an opt-out?
We offer an opt-out on all marketing emails.
MAKING THE DECISION
Can you rely on legitimate interests for this processing?
Yes.
