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The Murvi Club Legitimate Interest Assessment
If you want to rely on legitimate interests, you can use the three-part test to assess whether it applies. We refer to this as a Legitimate Interests Assessment (LIA) and you should do it before you start the processing.
An LIA is a type of light-touch risk assessment based on the specific context and circumstances. It will help you ensure that your processing is lawful. Recording your LIA will also help you demonstrate compliance in line with your accountability obligations under Articles 5(2) and 24. In some cases an LIA will be quite short, but in others there will be more to consider.
First, identify the legitimate Interest(s). Consider:
Why do you want to process the data — what are you trying to achieve?
We are administering an association whose membership is open to owners of Murvi motor caravans and past owners at the discretion of the management committee.
We have the need to be able to communicate with members by telephone, post and e-mail.
We have the need to use the registration number of member’s Murvi motor caravan to assist in identifying them.
Who benefits from the processing? In what way?
The members benefit from the processing by receiving the association’s newsletter and other relevant documents, being advised about association activities and being invited to renew annual membership.
If they so choose, members benefit from the processing bycommunicating with one another by using the e-mail chat line.
If they so choose, members benefit from the processing by having their membership number, name, post town, phone numbers, email address and registration number shared with other members.
Are there any wider public benefits to the processing?
There are no wider public benefits to the processing.
How important are those benefits?
This question is not applicable.
What would the impact be if you couldn’t go ahead?
We would not be able to fulfil our obligations to association members.
Would your use of the data be unethical or unlawful in any way?
Our use of the data would not be unethical or unlawful in any way.
Second, apply the necessity test. Consider:
Does this processing actually help to further that interest?
It is necessary to process the data to be able to administer the association in line with member expectations.
Is it a reasonable way to go about it?
It is reasonable to administer the association using conventional communication methods.
Is there another less intrusive way to achieve the same result?
Communicating in the manner described is the least intrusive way to communicate.
Third, do a balancing test. Consider the impact of your processing and whether this overrides the interest identified:
What is the nature of your relationship with the individual?
The association is a social organisation to which individuals apply to join as members.
Is any of the data particularly sensitive or private?
None of the data is particularly sensitive or private.
Would people expect you to use their data in this way?
Yes, the members would expect the association to use the data to communicate with them on association matters.
Are you happy to explain it to them?
We are happy to explain to the individuals what we use their data for.
Are some people likely to object or find it intrusive?
If any person objected to the processing, they would not complete the application form gathering the data and would not be accepted as members of the association.
What is the possible impact on the individual?
We can think of no possible impact on the individual
Are you processing children’s data?
We do not process children’s data.
Are any of the individuals vulnerable in any other way?
The association has no way of knowing if individuals are vulnerable in any other way.
Can you adopt any safeguards to minimise the impact?
We can think of no possible impact.
Can you offer an opt-out?
A member is free to resign from the association at any time.
adopted by committee 22nd April 2018