The Legitimate Interest Impact Assessment is a critical compliance document required under Singapore's data protection framework. It is used when organizations seek to process personal data based on legitimate interests without obtaining explicit consent. This assessment helps organizations demonstrate accountability by thoroughly evaluating the necessity of data processing, identifying potential risks, and implementing appropriate safeguards. The document supports compliance with the PDPA while protecting both organizational interests and individual privacy rights.
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1. Purpose of Processing: Details of what personal data is being processed and why, including the legitimate interests being pursued
2. Necessity Test: Assessment of whether the processing is necessary for the stated purpose and if there are less intrusive alternatives
3. Balancing Test: Evaluation of legitimate interests against individual rights, including impact on data subjects
4. Risk Assessment: Analysis of potential risks to individuals' rights and freedoms from the processing
5. Safeguards and Mitigations: Measures implemented to protect individual rights and reduce identified risks
1. Industry-Specific Considerations: Additional assessment criteria specific to regulated industries such as healthcare or financial services
2. Cross-border Transfers: Assessment of international data transfer impacts and compliance with transfer limitation obligations
1. Data Flow Diagrams: Visual representation of how personal data flows tHRough the organization
2. Risk Matrix: Detailed risk scoring and evaluation matrix with likelihood and impact assessments
3. Mitigation Controls: Comprehensive list of technical and organizational measures implemented
4. Stakeholder Consultation Records: Documentation of consultations with affected parties and relevant stakeholders
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