“...processing is necessary for the purposes of the legitimate interests pursued by the controller *or by a third party*”
Sent from my iPhone
> On 13 Nov 2019, at 08:44, Darren Davies <[log in to unmask]> wrote:
>
> Thanks for all the points made, I am lost with the legitimate interest when it comes to voluntary disclosure. The legitimate interest sits with the utility company but they aren’t requesting information, we would need to voluntarily disclose and it wouldn’t be our legitimate interest. Unless the thought process is that we are using our legitimate interest to avoid the liability (which is incorrectly billed to us) then I can see this working. If they made an application for the information I would have no issues sharing it, I am just stalling at the voluntary disclosure element.
>
> -----Original Message-----
> From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
> Sent: 12 November 2019 21:03
> To: [log in to unmask]
> Subject: Re: [data-protection] Pro-active disclosure to utility company
>
> I struggle to see an issue here.
>
> What is wrong with legitimate interest? Clearly available as it is not part of your public task. The LIA will take about 2 minutes - clearly no unwarranted prejudice.
>
> ICO point about no PN looks like nonsense. Issue one before you make the disclosure. If they raise an objection it will fail.
>
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