Legitimate Interests Assessment

Date Created: 1st February 2024
Company: Harasty Consulting
Review Date: 1st July 2024

Purpose of Processing:

We process business contact information to conduct cold calls aimed at promoting our products/services to potential business clients. Cold calling is essential for directly reaching potential business clients, allowing us to provide immediate explanations of our products/services and address any questions or concerns they may have.

Data Processed:

We store and process only the relevant contact and account information necessary for this purpose, including:

  • Names
  • Company Name
  • Phone Numbers
  • Business Email Addresses
  • LinkedIn URLs

Reasonable Expectations:

Individuals operating in a business context have reasonable expectations of being contacted about products and services relevant to their business. This aligns with the general industry practice and the nature of their roles.

Necessity Test:

Cold calling is a necessary marketing strategy to:

  • Identify and reach potential clients directly.
  • Provide detailed information about our products/services.
  • Address potential clients’ immediate queries and concerns.
  • Alternative methods, such as email campaigns or social media advertising, do not provide the same level of direct engagement and immediate response.

Balancing Test:

Impact on Data Subjects:

  • The data processed is strictly business-related.
  • The potential impact on the individuals is minimal and primarily professional, rather than personal.

Safeguards and Mitigation:

The safeguards include:

  • Clear opt-out mechanisms are provided during each call.
  • A do-not-call list is maintained and respected.
  • Data subjects are informed of their rights under GDPR.
  • Regular audits are conducted to ensure compliance with GDPR requirements.

Legitimate Interests:

Our legitimate interests in processing this data include:

  • Business growth through direct marketing efforts.
  • Building relationships with potential clients.
  • Efficiently conveying the benefits and features of our products/services.

These interests are balanced against the data subjects’ rights and freedoms, ensuring that our activities do not disproportionately impact them. By providing clear opt-out options and respecting privacy requests, we ensure that our legitimate interests do not override those of the individuals.

Conclusion:

The processing of business contact information for cold calling is justified under our legitimate interests. The data is handled with due consideration of individuals' rights and freedoms, ensuring compliance with GDPR. This assessment will be reviewed regularly or upon any significant changes in processing activities.

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