Legitimate Interest Assessment
Sections:
A. To identify legitimate interests
B. To apply the necessity test
C. To do a balancing test
D. Our conclusion

Introduction
This assessment has been carried out in accordance with guidance issued by the Information Commissioner’s Office (ICO), and to help ensure that our processing of personal data is lawful under the General Data Protection Regulation 2018

We have used the three-part test to assess whether it applies.

1. Purpose Test – is there a legitimate interest behind the processing?
2. Necessity Test – is the processing necessary for that purpose?
3. Balancing Test – is the legitimate interest overridden by the individual’s interests, rights or freedoms?

We have considered the following matters:-

A. To identify legitimate interests
1. Why do we want to process the data – what are we trying to achieve?
~  We want to facilitate the running of our club.
~  We want to publicise our club.
~  We want to inform, educate, and assist Members.
~  We want to contribute constructively to the wider chess community in Leeds and beyond.

2. Who benefits from the processing? In what way?
~ Our voluntary organisers/administrators by improved efficiency.
~ All our Members, by increased information, education and assistance.
~ The wider chess community, by distributing information.

3. Are there any wider public benefits to the processing?
~ It is of value to other chess players by providing information.
~ It helps to promote chess to the general public.

4. How important are those benefits?
~ Chess is considered to have educational benefit as evidenced by support from central and local government for initiatives to promote chess activity in schools and the community.
~ Chess is a valuable source of social recreation for the community

5. What would the impact be if you couldn’t go ahead?
~ The Club would not function as well and may cease to exist
~ The wider chess community would be detrimentally affected by reduction in competition and venue.
~ Individuals may lose the opportunity to play chess in a club that is suitable for their social and recreational needs.

6. Would your use of the data be unethical or unlawful in any way?
~ No.

B. To apply the necessity test
1. Does this processing actually help to further that interest?
~ Yes, no practical alternative has been identified.

2. Is it a reasonable way to go about it?
~ Yes, it accords with the reasonable expectations of Chess Club Members

3. Is there another less intrusive way to achieve the same result?
~ None identified.

C. To do a balancing test
1. What is the nature of your relationship with the individual?
~ An informal and voluntary social and recreational club run by volunteers with no membership charges or financial or constitutional basis.

2. Is any of the data particularly sensitive or private?
~ No.

3. Would people expect you to use their data in this way?
~ Yes.

4. Are you happy to explain it to them?
~ Yes.

5. Are some people likely to object or find it intrusive?
~ No, that is not anticipated.

6. What is the possible impact on the individual?
Sharing of some low sensitivity data is unlikely to cause serious problems if there is a data breach.

7. How big an impact might it have on them?
~ Minimal

8. Are you processing children’s data?
~ No.

9. Are any of the individuals vulnerable in any other way?
~ None identified at present, but responsible attitude will be taken if the situation presents in future.

10. Can you adopt any safeguards to minimise the impact?
~ Any impact is already considered low, but in the event of such arising a sympathetic and responsible approach will be adopted.

11. Can you offer an opt out?
~ Yes.

D. Our conclusion
We believe that we have legitimate interests which are not overridden by the risks we have identified.