The Legitimate Interest Impact Assessment (LIIA) is a crucial document required when organizations operating under Irish jurisdiction wish to process personal data based on legitimate interests under Article 6(1)(f) of the GDPR. This document should be completed before commencing any processing activities that rely on legitimate interests as their legal basis. It contains detailed analysis of the necessity of processing, evaluation of impacts on individual privacy rights, and documentation of safeguards implemented to protect data subjects. The LIIA helps organizations demonstrate compliance with accountability principles under Irish data protection law and GDPR, while providing a structured approach to balancing business needs with privacy rights. It serves as evidence of due diligence in decision-making regarding data processing activities and should be regularly reviewed and updated as circumstances change.
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1. Purpose of Assessment: Identifies the specific data processing activity being assessed and explains why legitimate interests is being considered as the lawful basis
2. Identification of Legitimate Interest: Details the legitimate interest(s) being pursued, whether commercial, individual, or societal
3. Necessity Test: Demonstrates why the processing is necessary and proportionate to achieve the identified legitimate interests, including consideration of less intrusive alternatives
4. Data Processing Details: Specifies what personal data will be processed, how it will be processed, and the data retention period
5. Impact Assessment: Evaluates the potential impact on individuals whose data is being processed, including consideration of reasonable expectations
6. Safeguards and Mitigating Measures: Describes the measures implemented to protect individuals' rights and reduce risks
7. Balancing Test: Weighs the legitimate interests against the individuals' interests, rights, and freedoms
8. Outcome and Decision: States the conclusion of whether legitimate interests is appropriate as the lawful basis and any conditions attached
1. Consultation Process: Documents any consultation with affected individuals or representatives - include when stakeholder consultation has been conducted
2. Special Category Data Considerations: Additional assessment required when processing special category data - include when sensitive personal data is involved
3. Cross-border Considerations: Assessment of international data transfers - include when data will be transferred outside the EEA
4. Technology Risk Assessment: Evaluation of specific technological risks - include when new or complex technology is being used
5. Periodic Review Schedule: Timeline and criteria for reviewing the assessment - include for long-term or evolving processing activities
1. Data Flow Map: Visual representation of how personal data flows through the organization for this processing activity
2. Risk Assessment Matrix: Detailed risk scoring and evaluation matrix showing identified risks and their mitigation measures
3. Stakeholder Consultation Results: Summary of feedback received from any consultations conducted with affected individuals or groups
4. Technical and Organizational Measures: Detailed documentation of security measures and other safeguards implemented
5. Review Log: Record of previous reviews and updates to the LIIA, including dates and key changes
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