Legitimate Interest Test

These are the factors that we have taken into account when determining whether the processing of people’s personal data for the purposes of direct marketing is a legitimate interest of Collecting Seashells.

 Date of assessment             7 March 2022

 Assessors                             Tilly Wilson (Collecting Seashells Ltd), Katie Jones (Collecting Seashells Ltd) and David Lowe (Crimson Crab Ltd)

 

Identify the legitimate interest(s)

Comment
Why do you want to process the data – what are you trying to achieve?

For the purpose of

  • Informing our customers – future, past and present – of our products.·
  • Improving the products and services that we offer

Who benefits from the processing? In what way?
  • Customers – they will continue to be aware of our products and periodic offers that we may choose to give them.
  • Collecting Seashells – the company, and its employees, is reliant on the completion of sales in order to remain as a viable and going business concern. Direct marketing will help maintain that viability.

Are there any wider public benefits to the processing?

·         No.

How important are those benefits?

Not applicable.

What would the impact be if you couldn’t go ahead?

The financial sustainability of the company would be affected, which would in turn have an impact on local labour markets and the money provided to the government through taxation.

Would your use of the data be unethical or unlawful in any way?

No.

Necessity test

 

Does this processing actually help to further that interest?

Yes.

Is it a reasonable way to go about it?

Yes.

Is there another less intrusive way to achieve the same result?

No.

Balancing test

 

What is the nature of your relationship with the individual?

They are people who have previously bought our products.

Is any of the data particularly sensitive or private?

No.

Would people expect you to use their data in this way?

Yes.

Are you happy to explain it to them?

Yes – a privacy notice is available on the company’s website, as is all the information contained in this document.

 Are some people likely to object or find it intrusive?

This processing is not intrusive. Although some people may object to it, we have provided clear information and accessible channels for them to exercise their information rights if this is the case.

What is the possible impact on the individual?

None, other than they may wish to buy our products.

How big an impact might it have on them?

Not applicable.

Are you processing children’s data?

 No

 Are any of the individuals vulnerable in any other way?

No.

Can you adopt any safeguards to minimise the impact?

Not applicable.

Can you offer an opt-out?

Yes – we have provided clear information and accessible channels for them to exercise their information rights.