We have checked that legitimate interests is the most appropriate basis.
We understand our responsibility to protect the individual’s interest.
We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision.
We have identified the relevant legitimate interests.
We have checked that the processing is necessary and there is no less intrusive way to achieve the same result.
We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests.
We only use individual’s data in ways they would reasonably expect, unless we have a very good reason.
We are not using people’s data in ways they would find intrusive or which could cause them harm, unless we have a very good reason.
We do not process children’s data.
We have considered safeguards to reduce the impact where possible.
We have considered whether we can offer an opt-out.
If our LIA identifies a significant privacy impact, we have considered whether we also need to conduct a DPIA.
We keep our LIA under review, and repeat it if circumstances change.
We include information about our legitimate interests in our privacy notice.
Identifying Legitimate Interests
Q. Why do you want to process the data - what are you trying to achieve?
A. To keep those working within the Christian supply and retail trade or related businesses informed of events and activities that they would be interested through at the attendance at the Retailers & Suppliers Retreat or to receive Together magazine, a bi-monthly trade journal.
Q. Who benefits from the processing? In what way?
A. Suppliers and retailers benefit to inform and be informed.
Q. Are there any wider public benefits to the processing?
A. Not necessarily.
Q. How important are those benefits?
A. Helping to enable them to achieve their business and ministry objectives.
Q. What would the impact be if you couldn’t go ahead?
A. Major loss to the Christian supply and retail trade.
Q. Would your use of the data be unethical or unlawful in any way?
Applying Necessity Test
Q. Does this processing actually help to further that interest?
Q. Is it a reasonable way to go about it?
Q. Is there another less intrusive way to achieve the same result?
Q. What is the nature of your relationship with the individual?
A. Businesses or individuals who share a common interest in the Christian publishing and retail trade.
Q. Is any of the data particularly sensitive or private?
Q. Would people expect you to use their data in this way?
A. Yes, to be informed of trade events and to receive trade magazine.
Q. Are you happy to explain it to them?
Q. Are some people likely to object or find it intrusive?
A. Would not consider information received from us, either through correspondence or Together magazine to be intrusive.
Q. What is the possible impact on the individual?
A. To be kept informed of trade activity in a positive way.
Q. How big an impact might it have on them?
A. In a positive sense to be informed regarding the Christian supply and retail trade.
Q. Are your processing children’s data?
A. No information relating to children is held or processed.
Q. Are any of the individuals vulnerable in any other way?
Q. Can you adopt any safeguards to minimise the impact?
A. Correspondence and the mailing of Together magazine are only sent to those we have a relationship with and who we believe would want to receive information from us.
Q. Can you offer an opt-out?
A. At any time recipients can request to be removed from the mailing list and the receiving of Together Magazine.