Legitimate Business Interest (LBI) Assessment

Legitimate Business Interest Assessment
This document explains the Legitimate Business Interest Assessment, as defined by the ICO, upon which Logical Office Limited relies when processing your data
1. Purpose test:
We process the data as part of our marketing to invite business professionals who use the Microsoft Windows Operating system and Microsoft Office to evaluate our CRM (Customer Relationship Management software) and free data encryption/decryption web site, based on a reasonable expectation that they have a current or anticipated requirement for such as system for themselves or to may wish to recommend it to third parties.
By processing the data, we identify potential clients and create a pipeline of interested prospects. No third-party wider public benefits from the processing of the data.
Our organisation benefits from processing the data to create sales. If we do not process data relating to prospective customers, our business lead generation activities and growth would suffer. We comply with data protection rules for holding and processing of data including staff training, data security, destruction of records and a managed un-subscribe system.
Since we only process contact details i.e. email addresses used for business purposes, telephone numbers, and where applicable, business postal addresses published on prospective customer web sites or provided to us by the prospective client, there are, in our opinion, no perceived or likely ethical issues relating to our processing of data.
2. Necessity test:
We need to process the data to make prospective customers aware of our products and services, so that we may be included as part of their selection process, or in their portfolio of useful products they recommend to their customers or third-party contacts. Due to the nature of lead generation, by necessity we rely on Legitimate Business Interest as the legal basis for processing the data. We believe that the products we offer are beneficial in nature and will assist users to become more organised, efficient and profitable. We cannot deliver this message without processing the data. We use only the minimum amount of data required to process, and we hold no data which is specifically personal/not used for business purposes. Our marketing messages are clear and unambiguous. We provide an easy and immediate unsubscribe option within all emails sent. Processing of un-subscribers is done with one working day of receipt.
3. Balancing test:
Nature of the personal data
We only use emails which are used for business purposes and business telephone numbers. We don’t hold information which is known to personal including; personal email, personal telephone, and personal postal address unless these have been provided for use in a business capacity and/or are used in a dual role for both business and personal usage.
We do not process any:
• special category criminal offence data.
• data which people are likely to consider particularly private.
• children’s data or data relating to other vulnerable groups.
• pictures of any type of individuals.
• social media information about individuals.
• details of personal interests or activities
The data we process about people is limited and entirely for professional business use.
Reasonable Expectations
If we do not have an existing relationship with the individual, we will only process the data if there is a reasonably high expectation and probability that our products and services will be of interest to the individual, and/or they have a job title relevant to our offering.
We collect data either from legitimate GDPR compliant data providers, or from interest groups, or from web site enquiries, or direct from prospective clients themselves or their web sites (for business types likely to be interested) where their business emails are published and hence in the public domain. However, we also have a database of contacts who have previously registered an interest with us and provided their details so that we can continually update them with new products and services.
As previously stated, we only acquire data from a third-party data provider who we believe based on their representations has taken steps 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 providers. Our intended purpose and method is widely understood. This is a tried and tested method we have used for years.
We reasonably expect our prospects to expect processing and will only offer relevant content, suitable to the individual, unless and until they unsubscribe or opt-out of marketing material. If we find that the individual is not likely to have a legitimate business interest in our products, we will cease communication with that individual and immediately un-subscribe them.
Likely Impact
The possible impact of processing is limited due to the nature of the data we use. Individuals may receive a communication which they consider to be unimportant or not of immediate interest, in which case they can unsubscribe, request deletion, and request details of the data provider. Unsubscribing is simply a matter of mouse clicking on an unsubscribe link, or verbally requesting the same, so the process is quick to expedite and hence there is no likelihood of suffering any consequential loss, loss of time, or any kind of significant loss arising from the processing of the data. We are happy to explain the reasons for our communication and unsubscribe procedures. We have security procedures and safeguards to minimise the risk to the individual.
Summary
Assessing the points in this document we are confident that we can rely on Legitimate Interests as a valid, legal basis for processing data. We retain only data necessary to communicate with the individual in professional capacity and only when there is a reasonable expectation that the individual will have a legitimate interest in our products and services. We respect and take steps to protect the privacy and rights of the individual and their data, and we will diligently process requests for opt-outs and will keep an anonymous list of individuals who have opted out so that the individual has complete control over their data.
Logical Office Ltd June 2018