This contains information about the legitimate interest assessment, as laid out by the ICO, with regards to how we process your data.
1. Purpose Test
We are processing the data in order to inform industry professionals of information related to their field of expertise.
By processing the data, we benefit from identifying potential clients and creating a pipeline of prospects.
No third-party benefits from the processing of your data.
There are no wider public benefits from processing.
The benefits of processing your data to our organisation are important to create growth and stimulate business development.
If we do not process prospects data, there would be a significant impact on our business growth and lead generation activities.
We follow the suggested general digital marketing guidelines suggested by the Direct Marketing Association.
Since we only process business emails, there are no ethical issues relating to our processing of data.
2. Necessity Test
The processing is necessary for that purpose as we want to place ourselves as a choice for their selection process. As this is a lead generation campaign to find net new leads, we can only use Legitimate Interest as the legal basis for processing.
This processing will help our lead generation activities and contribute towards both ourselves and the companies we speak to.
We cannot achieve the same purpose without processing.
We process the data using the lowest possible amount of personal data which includes only business emails and business information
We do not keep or hold any personal information on potential prospects aside from the aforementioned data.
By following a marketing code, we try to make our processing as obvious and un-intrusive as possible.
We offer potential prospects the chance to unsubscribe and take steps to ensure that processing will be fair and justified.
3. Balancing Test
Nature Of The Personal Data
We only have business details and no personal information including; personal email, personal telephone, or address is kept about prospects.
We do not process any special category data or criminal offence data.
We do not process any data which people are likely to consider particularly private.
We will never process children’s data or data relating to other vulnerable groups.
The data we process about people is entirely in a professional capacity.
We may not have an existing relationship with the individual, but we will only process the data if there is a high chance that our communication will definitely be of interest to the individual, and they have a job title relevant to our offering.
We are provided with data from a data provider and we are happy to provide any information, on request, about our data provider.
As previously stated, we are supplied data from a third-party data provider who uses publicly available information and who has taken every step to ensure data was collected in a fair way and we feel, to a high degree, that we can be covered by their collection activities. We are happy to provide any information, on request, about our data provider.
Our intended purpose and method is widely understood. This is a tried and tested method and our purpose is clearly outlined in our offerings.
We reasonably expect our prospects to expect processing and will only offer relevant content, suitable to the individual, unless they unsubscribe / opt-out of marketing material.
We do not anticipate any other factors, in the particular circumstances, that would mean they do not expect the processing. If we are made aware of any circumstances we will cease to process immediately, and ensure steps are taken to ensure they are not processed.
The possible impact of processing is limited due to the nature of the data we use.
Individuals retain complete control of their data and can unsubscribe / opt-out, request deletion and speak to the data provider.
Due to the nature of the data we process, there is little likelihood of any potential impact for the individual.
The severity of any impact on the individual would be minor, due to the nature of the data we process.
We are happy to explain the process and methodology of this processing to individuals.
We adopt all relevant security procedures and safeguards to minimise the risk to the individual.
We offer all individuals an opt-out in the form of an unsubscribe link found in all our marketing communications.
After assessing the points made in this document we feel we can rely on legitimate interests as a valid, legal basis for processing data.
We keep the minimum possible data on individuals and this data only relates to the individual in a professional context.
We only process data if we feel there is a high chance the individual will have a legitimate interest.
We take all steps to ensure the safety, privacy and rights of the individual.
We will ensure that all requests of opt-outs are honoured and will keep an anonymised list of individuals who have opted out to ensure the individual has complete control over their data.
LIA Completed by: Cyber Smart Consulting Limited
LIA Completed on: 25/05/2018
Should you have any complaints regarding the handling of your data you have the right to lodge a complaint with the Data Protection Officer at – The Data Protection Officer, Cyber Smart Consulting Ltd, 85 Great Portland Street, London, W1W 7LT.
If you have any concerns, queries or requests for us to not process your information in the way detailed in this statement please contact firstname.lastname@example.org or write to us at the above address.