Guardtech Cleanrooms Legitimate Interest Assessment
Last edit: 5 February 2021 (to be reviewed every six months)
Guardtech Cleanrooms LTD has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO. Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding Guardtech Cleanrooms and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation of operators working within relevant organisations and specific job functions related to the products and services we as company offer, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from Guardtech Cleanrooms in a direct marketing or sales capacity, could be legitimately interested in our communications. It is also deemed that direct marketing and sales is necessary in the context of promoting Guardtech Cleanrooms to professionals in business in order to increase awareness of our various cleanroom-related solutions in our particular marketplace.
Why do we have a Legitimate Interest Assessment (LIA)?
It helps us to ensure that our data processing is lawful. By recording our LIA, it helps us demonstrate our compliance and accountability obligations under Articles 5(2) and 24 of the current GDPR regulation.
Why do we want to process the data we have – what are we trying to achieve?
We believe that all of the products and services we offer are of interest to our customers, and indeed help them to run their businesses successfully. We need to process the data we have in order to maintain an effective channel of communication between Guardtech Cleanrooms and our customers in order to meet their needs effectively.
Who benefits from the processing? In what way?
We benefit from the processing because it makes those channels of communication much easier to establish and maintain, while our existing clients, and potential new clients, benefit as they have access they might otherwise have missed out on to products and services that help them to run their businesses more efficiently, effectively and successfully.
Are there any wider public benefits to the processing?
The wider public benefits are that many of the products and services we provide help to make cleanrooms and laboratories much safer spaces for the people working in them. Therefore, it is in the interest of public safety that we are able to communicate with firms about how we may be able to assist them.
How important are those benefits?
Vitally important. For example, laboratory staff working in cleanrooms with dangerous fumes need access to specific equipment designed to protect them and their product – and this is included among the products we supply. We also build the cleanrooms themselves, and so they also need to meet certain standards to ensure the safety of the users is not compromised.
What would the impact be if you couldn’t go ahead?
It could damage the success of our business going forward and open up our existing customers, as well as potential new clients, to engaging with firms less competent, qualified and experienced as us to take care of their various cleanroom needs.
Would your use of the data be unethical or unlawful in any way?
Our use of the data would be in no way unethical or unlawful – and we would never send out needless spam. Instead, we aim to send out communications no more than once per week, most likely every fortnight or month, and they would always be safe, relevant and appropriate to the recipient’s business needs.
Does this processing actually help to further that interest?
This processing helps to further the interests of both our business and our customers’/potential customers’.
Is it a reasonable way to go about it?
Our direct marketing communications are a reasonable way to approach potential and existing customers, with safe, relevant and appropriate content.
Is there another less intrusive way to achieve the same result?
We believe that direct email marketing is the least intrusive way to communicate with existing and potential customers whose businesses would benefit greatly from our range of cleanroom products and services.
What is the nature of your relationship with the individual?
We have either done business with the individual previously, been given permission to contact them having met them in person at a trade show or event, they opted in to receiving our communications via our website or we are confident that we have a legitimate interest to contact them with news, products or services we believe will benefit the successful operation of their business as per this Legitimate Interests Assessment.
Is any of the data particularly sensitive or private?
We only retain the name, email address, company name and job title of the people we send direct marketing communications to – none of which is particularly sensitive and certainly not private.
Would people expect you to use their data in this way?
We believe that everyone on our contacts list would not just expect us to use data in this way, but more often than not be pleased to hear about the products and services we can offer them to help their business.
Are you happy to explain it to them?
Are some people likely to object or find it intrusive?
We believe it is very unlikely that anyone would object to our data handling or find our communications intrusive, but we always give recipients of our emails the opportunity to unsubscribe and, if they do so, we will immediately remove them from our contacts list.
What is the possible impact on the individual?
There is likely to be no real negative impact on the individual – the greatest possibility is that they discover something on our communications that has a positive impact on their business.
How big an impact might it have on them?
Our communications could potentially have a hugely positive impact on the recipients. As mentioned earlier in regards to technicians using harsh chemicals, our products could potentially help to save lives by keeping operators safe.
Are you processing children’s data?
We never process children’s data.
Are any of the individuals vulnerable in any other way?
None of the individuals on our list are vulnerable in any way – and our practices would never put them in any sort of danger or cause them harm.
Can you adopt any safeguards to minimise the impact?
The biggest safeguard we adopt to minimise impact is to ensure the content of our communications is always relevant and appropriate to our recipients. There is never any dangerous or offensive content – instead, hopefully, we will more often than not provide our recipients with news, products and services which have a positive impact on the efficient and successful operation of their enterprise.
Can you offer an opt-out?
We always offer an opt-out in direct marketing communications and always honour it if recipients wish to be withdrawn from our list.
Guardtech Cleanrooms statement on the data/contacts we hold
All of the contacts in our records have, to our greatest possible knowledge and genuine business intentions, a role within their organisation which means they are either directly or indirectly responsible for a cleanroom or controlled environment, or have a legitimate, genuine and relevant interest in the products and services we offer from a business perspective.
This is based on previous encounters through doing business with these contacts, receiving inquiries from them/having an existing open dialogue with them already about services, having received their details at various events or, in some cases, identifying them from our own in-house research based on the relevance of our services to their business needs.
This is to the extent that not only would our products and services be of interest to the successful running of their business, but in most cases would actually be essential – from the perspective of helping to keep their staff safe, helping to ensure the quality of their products are not compromised and helping to ensure that they achieve the necessary ISO standards to meet national and international requirements for delivering the best possible product in their chosen field.
All the contacts we send our marketing materials to either have a cleanroom already – and so are required by law to address ongoing provisions that we can assist with in that field – or may have a legitimate need for a cleanroom in the future and thus require our various services imminently. For example, a business which makes parts for the Automotive industry may not currently be producing any product that needs to be kept from spoiling/decontamination at present, but with the addition of a cleanroom/controlled environment, it could potentially open their business up to producing a raft of new parts and help their firm to grow and expand/become more viable/hire more staff in the future/improve the quality of their output/product. Therefore, the products and services we offer can have a direct impact on improving the businesses we serve in myriad ways.
We have no reason to believe that the way we process our data carries any particular risks whatsoever to the contacts involved. We take great to ensure that our contacts lists are maintained in safe, secure spaces and we only intend to use these contacts to send them direct marketing materials (and nothing else non-business-related) from our business that relate specifically to products and services which are relevant to their businesses. We also ensure that we never ‘bombard’ our contacts with news, offers and information, and have absolutely no intention of ‘spamming’ them. Instead, we believe that it is only necessary to contact them when we have a legitimate reason for doing so, and thus intend to only do so one or two times per month at most. This is unless we decide to create a regular newsletter of some kind in the future, but if this occurs we will review our LIA and the impact of our communications on our contacts.
We offer our contacts the opportunity to opt out of receiving our email communications in every email we send and if they inform us that they do not wish to hear from us any more in a direct marketing context, we remove them from our lists/archive their details to ensure their wishes are adhered to.