Legitimate Interests Assessment
To comply with GDPR, Vox Pops International has carried out a Legitimate Interests Assessment, which is documented below
What is Legitimate Interest?
Legitimate Interests is one of the six lawful bases for processing personal data under the GDPR (General Data Protection Regulation). You must have a lawful basis in order to process personal data in line with the ‘lawfulness, fairness and transparency’ principle.
Legitimate interests might be your own interests, or the interests of the third party receiving the data, or a combination of the two.
Latest guidance from the Information Commissioner says that legitimate interests may be the most appropriate basis when:
“The processing is not required by law but is of a clear benefit to you or others; there’s a limited privacy impact on the individual; the individual should reasonably expect you to use their data in that way; and you cannot, or do not want to, give the individual full upfront control (i.e. consent) or bother them with disruptive consent requests when they are unlikely to object to the processing.”
Crucially for marketers, direct marketing is described in the GDPR as an activity that may indicate a legitimate interest.
You can read the Information Commissioner’s guidance on legitimate interests in full on the ICO website
In order that Vox Pops International use legitimate interest as the basis for processing personal data for direct marketing purposes, the company has completed the below Legitimate Interest Assessment.
Purpose of Processing
VPI has a legitimate interest to process personal data relating to decision makers, budget holders and senior members of medium-to-large organisations in the UK and Internationally, as well as individuals who work in industries, roles or departments that our services are relevant to. The data is gathered from publicly available sources, directly from the companies/individuals concerned, or from legitimate mailing list providers such as Electric Marketing.
Lawful Business Objective
The processing of personal data in line with the above purpose is necessary in as a part of Vox Pops International’s business-to-business direct marketing activities; a lawful business objective specifically identified by the Privacy and Electronic Communications Regulations 2003 (PECR). Recital 47 of the GDPR identifies direct marketing as a legitimate use of personal information.
Reasonable Expectation
With regard to business-to-business marketing latest guidance from the Information Commissioner follows:
“Business contacts are more likely to reasonably expect the processing of their personal data in a business context, and the processing is less likely to have a significant impact on them personally”
The data subjects processed by Vox Pops International are business people who work for medium-to-large organisations. Vox Pops International’s direct marketing is targeted according to the data subject’s industry/department/role. The data subjects will exclusively receive communications that are relevant and related to their professional role. As such, the data subject can reasonably expect their data to be processed for direct marketing by Vox Pops International, as it holds relevance over their professional role in a business context.
Adequate, Relevant & Limited
The data collected may include personal data relating to the data subject’s name, employer, job title, company addresses, company landline telephone number, corporate email address or activity on Vox Pops International’s company website. If a person leaves their role, their name and contact details are deleted from the database. This is managed by regular list cleaning, validation with mailing list providers and manual deletion.
Opt Out
If a data subject requests that their data is removed from the database, it is removed from the database and blocked from our email marketing software, such that it cannot be used for direct marketing or contacted again at a later date. All direct marketing communication from Vox Pops International will include a clear option for the data subject to opt out.
Valuable Service
In supplying targeted promotions and offers, Vox Pops International provides a valuable service to individuals who work for medium-to-large organisations in professional roles that are relevant and related to the services offered by Vox Pops International.
