Customer Surveys, Assessment and Insight Activities

Legitimate Interest Assessment (LIA) – Customer Surveys, Assessment and Insight Activities

Organisation

Investor in Customers Ltd

Processing Activity

Investor in Customers receives customer contact information from client organisations for the
purpose of conducting customer feedback surveys, gathering customer insight, producing
assessment reports and supporting customer experience improvement activities.
The processing may include:

• Distribution of customer feedback surveys
• Collection of survey responses
• Analysis of customer feedback
• Benchmarking and assessment activities
• Production of reports and recommendations
• Customer experience improvement programmes
• Accreditation and award assessments
  Investor in Customers acts primarily as a Data Processor on behalf of client organisations. However,
  this assessment has been completed as part of Investor in Customers’ accountability obligations to
  demonstrate that the processing is necessary, proportionate and aligned with the reasonable
  expectations of survey recipients.

1. Purpose Test

What is the purpose of the processing?

The purpose of the processing is to gather customer feedback and insight on behalf of client
organisations in order to:

• Understand customer experiences and perceptions
• Identify strengths and opportunities for improvement
• Support service improvement initiatives
• Measure customer satisfaction and loyalty
• Support accreditation, assessment and award activities
• Enable organisations to improve customer outcomes

Is there a legitimate interest?

Yes.

Client organisations have a legitimate interest in understanding the experiences, needs and
perceptions of their customers.
Investor in Customers has a legitimate interest in delivering contracted assessment, accreditation
and customer insight services.
Survey respondents may also benefit from having their feedback considered and used to improve
products, services and customer experiences.

What benefits are expected from the processing?

The processing enables organisations to:

• Better understand customer needs
• Improve products and services
• Identify service issues
• Improve customer outcomes
• Make evidence-based decisions
• Monitor customer experience performance
  Investor in Customers is able to deliver independent customer insight and assessment services that
  support continuous improvement.

Do any third parties benefit from the processing?

Yes.

Benefits may extend to:

• Existing customers
• Future customers
• Employees
• Service users
• Stakeholders
  Improved services and customer experiences may positively affect a wider customer base beyond
  those directly participating in the survey.

Are there any wider public benefits?

Yes.

Customer feedback programmes help organisations improve service quality, fairness, accessibility
and responsiveness.

The processing supports the wider promotion of customer-focused practices, continuous
improvement and better customer outcomes across both private and public sector organisations.

How important are the identified benefits?

The benefits are considered significant.

Customer feedback is a widely recognised mechanism for improving organisational performance and
customer outcomes. Without customer insight, organisations would have a reduced ability to
identify issues, improve services and respond effectively to changing customer expectations.

What would be the impact if the processing could not take place?

Client organisations would have fewer opportunities to gather structured customer feedback and
identify areas for improvement.

This could reduce their ability to understand customer needs, monitor customer satisfaction and
improve customer outcomes.

Investor in Customers would be unable to deliver key elements of its assessment and accreditation
services.

2. Necessity Test

Is the processing necessary to achieve the stated purpose?

Yes.

Obtaining customer feedback directly from customers is necessary to understand customer
experiences and perceptions accurately.

The processing enables:

• Collection of customer feedback
• Independent assessment of customer experience
• Analysis of customer perceptions
• Evidence-based reporting and recommendations

Will this processing actually help achieve the purpose?

Yes.

Customer surveys provide direct insight from customers regarding their experiences, expectations
and perceptions.

Is the processing proportionate to the purpose?

Yes.

Only limited personal data is processed for survey administration purposes.

Typically, this includes:

• Name
• Email address
• Organisation (where applicable)
• Survey responses
• Associated survey administration data

The processing is directly relevant to the purpose and limited to information necessary to conduct
the survey and analyse results.

Can the same purpose be achieved without the processing?

No.

Without processing customer contact information, surveys could not be distributed to respondents.
Without collecting responses, meaningful customer insight could not be generated.

Can the purpose be achieved by processing less data or by using a less intrusive method?

The processing is already limited to the minimum data required to administer surveys and analyse
responses.

Alternative approaches such as generic public surveys, telephone research or postal questionnaires
would generally be less efficient, less representative and potentially more intrusive.

Investor in Customers seeks to minimise the amount of personal data processed wherever possible.

3. Balancing Test

Would individuals reasonably expect this processing?

Yes.

Customers would generally expect organisations they deal with to seek feedback regarding products,
services and customer experiences.

Customer satisfaction surveys and feedback requests are widely recognised business practices.

Where surveys are conducted, customers are informed that Investor in Customers is acting on behalf
of the client organisation.

What is the impact on individuals?

The impact on individuals is considered low.

Participation is voluntary.

Survey recipients can choose whether or not to complete the survey.

Responses are typically analysed and reported in aggregated or anonymised form wherever possible.

Is any special category data or criminal offence data processed?

No.

Investor in Customers does not intentionally collect or process special category personal data or
criminal offence data as part of standard survey activities.

If respondents voluntarily disclose such information within free-text comments, it is not actively
used, analysed or reported unless strictly necessary and appropriate safeguards apply.

Is the data likely to be considered particularly private?

Generally no.

The data processed relates primarily to customer experiences, opinions and perceptions regarding
products and services.

The processing does not normally involve information relating to private life, health, finances, family
relationships or other highly sensitive matters.

Are children or vulnerable individuals involved?

The processing is not generally directed towards children.

Investor in Customers’ services are primarily delivered within business and organisational
environments.

Where client organisations serve vulnerable groups or younger individuals, additional safeguards
may be considered on a case-by-case basis.

Is the data processed in a personal or professional capacity?

The data may be processed in either a personal or professional capacity depending on the nature of
the client organisation and customer relationship.

Regardless of context, Investor in Customers limits processing to information necessary for survey
administration, analysis and reporting.

Could the processing cause harm?

The risk of harm is considered low.

Participation is voluntary.

Survey recipients may choose not to respond.

Survey results are normally reported at an aggregated level and individual responses are not
routinely attributed to identifiable individuals.

No automated decision-making or profiling takes place.

Are there any other ethical issues with the processing?

No significant ethical concerns have been identified.

The processing supports transparency, accountability and service improvement.

Investor in Customers seeks to ensure that feedback activities are conducted fairly, respectfully and
proportionately.

Compliance with Relevant Legislation and Guidance

Investor in Customers is committed to complying with:

• UK General Data Protection Regulation (UK GDPR)
• Data Protection Act 2018
• Privacy and Electronic Communications Regulations (PECR) where applicable
• Applicable ICO guidance
• Contractual obligations agreed with client organisations

Investor in Customers operates under appropriate Data Processing Agreements and maintains
suitable technical and organisational measures to protect personal data.

Safeguards

Investor in Customers implements the following safeguards:

• Processing is limited to information necessary for survey administration and analysis.
• Survey participation is voluntary.
• Respondents are provided with appropriate privacy information.
• Personal data is handled securely.
• Access is restricted to authorised personnel.
• Data Processing Agreements are in place with clients where required.
• Survey responses are anonymised or aggregated wherever possible.
• Personal data is retained only for as long as necessary.
• Appropriate technical and organisational security measures are maintained.

Individuals retain their rights under UK GDPR.

Assessment Outcome

Having considered:

• The legitimate interests of Investor in Customers and its clients;
• The benefits to organisations and customers;
• The reasonable expectations of survey recipients;
• The low-risk nature of the processing;
• The safeguards in place;

Investor in Customers concludes that the legitimate interests pursued are not overridden by the
rights and freedoms of the individuals concerned.

The processing is therefore considered lawful under Article 6(1)(f) UK GDPR (Legitimate Interests),
subject to the client organisation having an appropriate lawful basis for providing customer contact
details and conducting customer feedback activities.

Review

This Legitimate Interest Assessment should be reviewed annually, or sooner if there are significant
changes to processing activities, legislation, client requirements or ICO guidance.

Approved By
SD Clapp (Operations Director)

Date: 10/6/26