A product team claims "legitimate interest" for a new profiling fea…

Question

A product team claims "legitimate interest" for a new profiling feature but has no documented balancing assessment. What should a CIPP/E-minded reviewer expect before relying on Article 6(1)(f)?

Accepted Answer

A real legitimate-interests assessment documenting purpose, necessity, and balancing against data-subject interests — Legitimate interest is not a magic stamp you slap on a feature. You need a real LIA—what you want to do, why you need that data, and whether the person's interests outweigh yours. A slogan or "competitors do it" will not cut it.

Answer

Only a marketing slogan stating that the feature creates business value

Answer

A board minute that legitimate interests is the company's preferred default basis

Answer

Proof that at least one competitor already uses the same profiling design

A product team claims "legitimate interest" for a new profiling feature but has no documented balancing assessment. What should a CIPP/E-minded reviewer expect before relying on Article 6(1)(f)?

Short Explanation

Full Explanation