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EPISODE · Aug 27, 2025 · 4 MIN

More ICO guidance! Recognised legitimate interests

from The Privacy Partnership Podcast with Robert Bateman · host treborjnametab1

More draft ICO guidance! This time, about one of the Data (Use and Access) Act's most important concepts: "Recognised legitimate interests". The "recognised legitimate interests" are data processing activities that, frankly, the government would like you to do more of.Unlike regular old legitimate interests, you won't need to conduct a "balancing test" before processing personal data for these purposes: So long as the processing is "necessary", you can just go right ahead and do it.So far we have five "recognised legitimate interests":• Public task disclosure request• National security, public security and defence• Emergencies• Crime• SafeguardingSome of these, namely "emergencies" and "safeguarding", are defined quite tightly.Others are not. There's no definition of terms like "national security", "defence", or "crime", so expect to see controllers relying on these conditions in a broad range of circumstances.As always, please get in touch if you need any help preparing for these provisions to take effect. 

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More draft ICO guidance! This time, about one of the Data (Use and Access) Act's most important concepts: "Recognised legitimate interests". The "recognised legitimate interests" are data processing activities that, frankly, the government would like you to do more of. Unlike regular old legitimate interests, you won't need to conduct a "balancing test" before processing personal data for these purposes: So long as the processing is "necessary", you can just go right ahead and do it. So...

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More ICO guidance! Recognised legitimate interests

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