EXAMPLE Legitimate Interest Assessment Form

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Legitimate Interest Assessment Form

Assessment details Title of processing being assessed:

Feedback Survey Requests

Description of processing:

We send customers an email once a year asking them to follow a link to a survey to provide feedback information about their experience with our products and our organization. This information is used by our product development team to identify improvements to and issues with our existing products. It may also help to suggest new ideas for future products and services.

Assessor name:

John Smith

Assessment date:

11 June, 20XX

Purpose test Objectives QUESTION

RESPONSE

1. What are the objectives of the processing?

Obtain feedback about our products which is useful in their future development. Also identify any dissatisfaction amongst customers which may be addressed both with individual customers and future ones.

2. How will you know if it has achieved its purpose?

We receive an acceptable quantity of useful feedback.

3. How likely are the objectives to be met by the processing?

Very likely. We feel there will be a good response to our request.

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Benefits QUESTION

RESPONSE

1. What benefits could derive from the processing?

We develop the products in the direction that makes them more likely to be useful and attractive to our customers, which allows them to get their job done more easily and provides income for our organization.

2. How significant are these benefits?

Reasonably significant; we use the quotes for marketing (which helps with sales) and a lot of the improvement ideas from previous surveys have gone into the products and been well received by customers.

3. Who will receive the benefits of the processing?

Our organization gets the benefit of future sales revenue increases, and future customers (and current subscribers) will also benefit from improvements in our products.

Impact of not processing QUESTION

RESPONSE

1. How significant would the impact be?

We would lack quality information on whether our products are liked by our customers or the degree to which they find them useful. This means we would have to second-guess what our customers want.

2. How likely is it that the impact would be felt?

Moderately likely. We do have other sources of feedback such as support questions, but these are from a small proportion of our overall customer base.

3. Who would be impacted by not processing?

Our organization’s products would not improve as much and the customer would not see changes in the areas, they value most.

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Other issues QUESTION

RESPONSE

1. Has this processing been carried out before? If so, what were the results?

We have done a survey every year for the last four years and it has been very useful.

2. Is the processing ethical?

Yes, we ask reasonable questions of the appropriate people and the information gained is only used within our organization; it is not sold on. The processing has no personal impact on the recipients of the survey.

3. Would the processing have any negative impact? If so, what and for whom?

The email can be ignored by the recipient and there is no impact from not taking part.

4. Any other issues?

None.

Necessity test QUESTION

RESPONSE

1. How does the processing relate to the benefits expected?

Sending an email is the easiest way to conduct such as survey and the information received is used directly for the purpose described.

2. Is the processing as proposed the best way to achieve the end result?

It would be difficult to achieve via any other means. Focus groups are expensive, although the level of detail obtained may be better. Telephone surveys would only cover a small proportion of the customer base.

3. What alternatives have been considered and why were they rejected?

We could phone customers, but that would be very time-consuming and expensive both for the organization and the customer. Due to the international spread of our customers, physical meetings would be difficult to arrange, although video conferencing could be used.

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Balancing test QUESTION

RESPONSE

1. Who are the PII principals?

The PII principals are customers of our organization who have previously bought one or more of our products.

2. What is the organization’s relationship with the PII principal?

They are our customers. We have a contractual relationship, and each customer will be aware of our organization, having previously purchased directly from us.

3. What personally identifiable information (PII) is involved in the processing?

Name and email address are used to send the email. Responses may include facts about the company they work for and opinions on our products.

4. What is the likely reaction of the PII principal to the processing?

From previous experience, many are pleased to contribute; we have never had any complaints about receiving the survey. The customers recognise that they will receive a benefit from the information they provide.

5. What is the potential impact on the PII principal?

They receive an initial email and two follow-up emails. The information they provide may be used on our website.

6. How could the impact on the PII principal be lessened?

We could only send reminder emails to those that have not responded so far. This would mean extra work for us in cross-referencing who has responded before each email is sent. We would also miss the opportunity to thank people for having already responded. The customer will have the chance to unsubscribe after the first email if desired.

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Decision details Decision:

Legitimate interest applies to this processing as described.

Main reasons for decision:

The benefit to both parties is significant, and any negative impacts are small. The PII principals are existing customers and so may expect this type of email as part of their relationship with our organization.

Date of decision:

23 Jun, 20XX

Approved by:

Jane Doe

Date of approval:

30 Jun, 20XX

If approved, the contents of this form will be used to create an appropriate privacy notice to be drawn to the attention of the relevant PII principals.

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