The Legitimate Interest Impact Assessment (LIIA) is a crucial compliance document required under UAE data protection law when organizations wish to process personal data based on legitimate interests. This assessment becomes necessary when organizations cannot rely on consent or other legal bases for processing personal data. It must demonstrate compliance with UAE Federal Decree-Law No. 45/2021 and related regulations, including specific requirements from free zones such as DIFC and ADGM where applicable. The document serves as both a compliance tool and a record of decision-making, requiring regular updates as processing activities or circumstances change. It helps organizations demonstrate accountability and transparent decision-making in their data processing activities while ensuring alignment with UAE's data protection framework.
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1. Executive Summary: Overview of the assessment's purpose, scope, and key findings
2. Purpose and Context: Detailed explanation of the data processing activity being assessed and its business context
3. Data Processing Details: Specific information about the personal data being processed, including categories, sources, and retention periods
4. Legitimate Interest Assessment: Analysis of the legitimate interest being pursued and why it's appropriate
5. Necessity Test: Evaluation of why the processing is necessary and whether there are less intrusive alternatives
6. Balancing Test: Assessment of data subject interests, rights, and freedoms against the legitimate interest
7. Risk Assessment: Identification and evaluation of risks to data subjects
8. Safeguards and Mitigating Measures: Description of measures implemented to protect data subject interests
9. Compliance with UAE Data Protection Laws: Specific analysis of compliance with UAE Federal Decree-Law No. 45/2021 and other relevant regulations
10. Conclusion and Recommendations: Final determination on legitimate interest validity and any required actions
1. Cross-Border Transfer Assessment: Required when processing involves data transfers outside the UAE
2. Special Category Data Considerations: Required when processing involves sensitive personal data categories
3. Industry-Specific Compliance: Required when processing is subject to specific sector regulations (e.g., healthcare, financial services)
4. Free Zone Considerations: Required when processing activities fall under DIFC or ADGM jurisdiction
5. Marketing Activities Assessment: Required when legitimate interest involves direct marketing purposes
6. Employee Data Processing: Required when assessment involves processing of employee personal data
1. Data Flow Diagram: Visual representation of how personal data flows through the processing activity
2. Risk Assessment Matrix: Detailed risk scoring and evaluation matrix
3. Stakeholder Consultation Results: Summary of any consultations conducted with stakeholders or data subjects
4. Technical and Organizational Measures: Detailed description of security and privacy measures implemented
5. Relevant Policies and Procedures: List and summary of internal policies supporting the processing activity
6. Review and Update Log: Record of assessment reviews and updates
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