Legitimate Interest Assessment

Legitimate Interest Assessment (LIA)

Investor in Customers

Processing Activity

Sending business-to-business marketing communications by email to:

• Existing clients
• Former clients
• Organisations that have previously purchased services
• Individuals who have made enquiries about Investor in Customers’ products or services
• Individuals who have requested information or proposals
• Event and webinar attendees
• Award entrants and participants
• Ambassador programme delegates
• Business contacts who have engaged with Investor in Customers in a professional capacity
• Successor contacts within organisations that are existing clients, former clients, programme
  participants or organisations that have previously expressed an interest in Investor in
  Customers’ services

Communications may include:

• Customer experience insights and best practice
• Industry news and updates
• Investor in Customers products and services
• Accreditation, assessment and award programmes
• Training and development opportunities
• Events, webinars and workshops
• Research, guides and thought leadership content
• Relevant service updates and offers

1. Purpose Test

What is the purpose of the processing?
Investor in Customers wishes to maintain relationships with existing clients, former clients,
prospective clients and professional contacts who have previously engaged with the organisation.

The purpose of the communications is to:

• Maintain professional relationships
• Promote relevant products and services
• Share industry insights and thought leadership
• Inform contacts about events, training and development opportunities
• Provide updates relating to customer experience, employee experience and organisational
  improvement
• Re-engage organisations that have previously expressed an interest in Investor in Customers’
  services

Is there a legitimate interest?

Yes.

Investor in Customers has a legitimate commercial interest in marketing its products and services,
maintaining relationships with business contacts and supporting business growth.

Recipients also benefit from receiving relevant information, guidance, resources and opportunities
aligned with their professional interests and previous interactions with Investor in Customers.

Additional Legitimate Interests Considerations

What benefit is expected from the processing?

The processing enables Investor in Customers to maintain professional relationships, promote
relevant products and services, share valuable customer experience insights, support business
development and facilitate ongoing engagement with organisations that may benefit from its
services.

It also enables organisations and individuals to remain informed about developments, opportunities,
events, training and resources relevant to customer experience, employee experience and
organisational improvement.

Do any third parties benefit from the processing?

Yes.

Client organisations, prospective clients, delegates, award participants and other professional
contacts may benefit from receiving information, guidance, resources and opportunities that
support organisational performance, customer experience improvement and professional
development.

Are there any wider public benefits?

Yes.

Investor in Customers promotes good practice in customer experience, employee engagement and
organisational improvement. By sharing insight, research, training opportunities and best practice,
the processing may contribute to higher service standards, improved customer outcomes and better
organisational performance across multiple sectors.

How important are the identified benefits?

The benefits are considered significant.

The processing supports both the legitimate commercial interests of Investor in Customers and the
professional interests of recipients who have previously engaged with the organisation. It also
supports the wider objective of promoting customer-focused business practices.

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

Investor in Customers would be less able to maintain relationships with existing and former clients,
respond to previous expressions of interest, promote relevant services or share valuable insight and
learning opportunities.

Organisations that have previously engaged with Investor in Customers may miss opportunities to
access information, support, training, recognition programmes or services that could benefit their
customers, employees and stakeholders.

Compliance with Data Protection and Privacy Legislation

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)
• Applicable ICO guidance relating to direct marketing and legitimate interests

Marketing communications include clear opt-out mechanisms and recipients are able to object to
processing at any time.

Compliance with Other Relevant Laws and Standards

Investor in Customers seeks to conduct all marketing and relationship management activities fairly,
transparently and professionally.

The organisation follows recognised business practices and principles relating to responsible
marketing, transparency and customer-focused communication.

Industry Guidance and Codes of Practice

Investor in Customers seeks to align its practices with relevant ICO guidance and recognised
standards relating to customer experience, professional conduct and responsible business communication.

Ethical Considerations

Investor in Customers recognises the importance of balancing its commercial interests against the
rights and expectations of individuals.

The organisation seeks to ensure that communications are:

• Relevant
• Proportionate
• Professional
• Respectful of individual preferences
  The processing is not considered intrusive and is limited to business-related communications that
  recipients would reasonably expect based on their relationship with Investor in Customers.

2. Necessity Test

Is the processing necessary to achieve the stated purpose?

Yes.

Investor in Customers operates within a specialist business-to-business environment where ongoing
communication is often expected following enquiries, proposals, assessments, events, training
programmes, award participation or previous purchases.

The processing enables Investor in Customers to:

• Follow up on previous enquiries
• Maintain relationships with former and existing clients
• Inform contacts about relevant services and opportunities
• Share information likely to be of professional interest
• Maintain relationships at an organisational level where individual contacts may change over
  time
• Re-engage organisations that may benefit from Investor in Customers’ services

Will this processing actually help achieve the purpose?

Yes.

The processing directly supports Investor in Customers’ ability to maintain professional relationships,
communicate with relevant organisations and individuals, share information about its services and
promote opportunities that may be beneficial to recipients.
Without this processing, Investor in Customers would be significantly less able to engage with
organisations that have previously expressed an interest in its services or maintain ongoing business
relationships.

Is the processing proportionate to the purpose?

Yes.

The processing is limited to business-related communications sent to individuals who have an
existing or previous relationship with Investor in Customers, or who have demonstrated an interest
in its products or services.

Can the same purpose be achieved without the processing?

No.

Investor in Customers could not effectively maintain ongoing relationships, provide relevant updates
or communicate information about its services without processing contact information.
The purpose relies upon being able to identify and communicate with appropriate individuals within
client, former client and prospective client organisations.

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

The processing has already been limited to the minimum data necessary to achieve the stated
purpose.

Only limited business contact information is processed, typically:

• Name
• Job title
• Organisation
• Business email address
• Contact history
• Engagement history
• Marketing preferences where recorded

Alternative methods such as postal marketing, general advertising or telephone contact would be
less targeted, less efficient and potentially more intrusive.
Email communication provides a proportionate and widely accepted method of maintaining
professional business relationships and sharing relevant information.

Investor in Customers does not process special category data, personal lifestyle information or any
information beyond what is reasonably required for business-to-business communication and
relationship management.

3. Balancing Test

Would individuals reasonably expect this processing?

Yes.

The individuals concerned have either:

• Purchased services from Investor in Customers
• Participated in an assessment, award or training programme
• Requested information
• Requested a proposal or quotation
• Attended an event or webinar
• Downloaded resources
• Held discussions regarding Investor in Customers’ services
• Otherwise engaged with Investor in Customers in a professional context

It is reasonable to expect that Investor in Customers may continue to communicate with them
regarding relevant products, services, events, updates and opportunities.

This includes individuals who enquired about services but did not proceed with a purchase. Such
individuals may still have an ongoing professional interest in customer experience, employee
experience, organisational improvement, accreditation, awards or training services.

In some circumstances, Investor in Customers maintains relationships primarily with organisations
rather than specific individuals. Where a contact leaves an organisation, changes role or is replaced,
Investor in Customers may identify and contact an appropriate replacement individual within that
organisation where there is a legitimate business reason to do so. This may include maintaining
existing client relationships, supporting ongoing programmes, discussing previous enquiries or
providing information relating to services that are relevant to the organisation.

Such communications will be limited to professional business contact details and will relate to the
organisation’s existing or previous relationship with Investor in Customers.
What is the impact on individuals?

The impact on individuals is considered low.

Communications are:

• Business-related
• Relevant to the recipient’s professional interests
• Sent infrequently and proportionately
• Not intrusive in nature

Recipients retain full control over whether they continue to receive communications.

Is any special category data or criminal offence data processed?

No.

Investor in Customers does not process special category personal data or criminal offence data for the purposes covered by this assessment.

Is the data likely to be considered particularly private?

No.

The information processed is limited to business contact information and professional engagement history. This typically includes an individual’s name, job title, organisation, business email address and records of previous interactions with Investor in Customers.

The processing does not involve information relating to an individual’s private life, finances, health, personal relationships or other sensitive matters.

Are children or vulnerable individuals involved?

No.

Investor in Customers’ products and services are aimed at businesses, organisations and working professionals.

The organisation does not knowingly market to children and does not intentionally process children’s personal data for marketing purposes.

The processing is not specifically directed at vulnerable individuals.

Is the data processed in a personal or professional capacity?

The data is processed primarily in a professional capacity.

Communications are sent to individuals in connection with their employment, business role or professional responsibilities.

In some cases, sole traders, consultants or business owners may use personal contact details for business purposes. Where this occurs, Investor in Customers will continue to ensure communications remain relevant, proportionate and aligned with the individual’s reasonable expectations.

Could the processing cause harm?

The risk of harm is considered low.

The processing is limited to professional business communications relating to products, services, events, training and resources that are relevant to the recipient’s relationship with Investor in Customers.

Recipients are able to opt out at any time and are not subject to automated decision-making, profiling or any activity likely to have a significant impact on their rights and freedoms.

Are there any other ethical issues with the processing?

No significant ethical concerns have been identified.

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)
• Applicable ICO guidance relating to direct marketing and legitimate interests

Marketing communications include clear opt-out mechanisms and recipients are able to object to
processing at any time.

Investor in Customers also seeks to align its practices with recognised standards of responsible
business communication, transparency and customer-focused marketing.

Safeguards

Investor in Customers implements the following safeguards:

• Communications are relevant to the recipient’s relationship with Investor in Customers.
• Only limited business contact information is processed.
• Marketing communications are professional and proportionate.
• Every marketing email contains a clear and simple unsubscribe mechanism.
• Opt-out requests are actioned promptly.
• Individuals can object to processing at any time.
• Marketing databases are reviewed periodically to ensure data remains accurate and
  relevant.
• Contacts who have not engaged with communications or had any meaningful interaction
  with Investor in Customers for an extended period (typically 24-36 months) may be removed
  from marketing lists unless another lawful basis for retention applies.
  • Where a contact has left an organisation, Investor in Customers may update records using
    publicly available business information to identify an appropriate replacement contact. Any
    such processing will be limited to business contact information relevant to the organisation’s
• Personal data is processed in accordance with UK GDPR, the Data Protection Act 2018 and
  the Privacy and Electronic Communications Regulations (PECR).

Assessment Outcome

Having considered:

• The legitimate business interests of Investor in Customers;
• The reasonable expectations of recipients;
• The professional nature of the relationship;
• The limited and proportionate processing involved; and
• The safeguards in place;

Investor in Customers concludes that its legitimate interests in conducting direct marketing,
maintaining professional relationships and engaging with organisations that have previously
expressed an interest in its services are not overridden by the rights, freedoms or interests of the
individuals concerned.
The processing is therefore considered lawful under Article 6(1)(f) UK GDPR (Legitimate Interests).

Review

This Legitimate Interest Assessment should be reviewed annually, or sooner if there are significant
changes to marketing activities, business operations, applicable legislation, PECR requirements or
ICO guidance.

Approved By

SD Clapp (Operations Director)

Date: 10/06/2026