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Legitimate Interest Impact Assessment Template for Singapore

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Key Requirements PROMPT example:

Legitimate Interest Impact Assessment

"Need a Legitimate Interest Impact Assessment for our new customer loyalty program launching in March 2025, focusing on processing customer purchase history and preferences for personalized marketing in Singapore."

Document background
The Legitimate Interest Impact Assessment is a critical compliance document required under Singapore's data protection framework. It is used when organizations seek to process personal data based on legitimate interests without obtaining explicit consent. This assessment helps organizations demonstrate accountability by thoroughly evaluating the necessity of data processing, identifying potential risks, and implementing appropriate safeguards. The document supports compliance with the PDPA while protecting both organizational interests and individual privacy rights.
Suggested Sections

1. Purpose of Processing: Details of what personal data is being processed and why, including the legitimate interests being pursued

2. Necessity Test: Assessment of whether the processing is necessary for the stated purpose and if there are less intrusive alternatives

3. Balancing Test: Evaluation of legitimate interests against individual rights, including impact on data subjects

4. Risk Assessment: Analysis of potential risks to individuals' rights and freedoms from the processing

5. Safeguards and Mitigations: Measures implemented to protect individual rights and reduce identified risks

Optional Sections

1. Industry-Specific Considerations: Additional assessment criteria specific to regulated industries such as healthcare or financial services

2. Cross-border Transfers: Assessment of international data transfer impacts and compliance with transfer limitation obligations

Suggested Schedules

1. Data Flow Diagrams: Visual representation of how personal data flows tHRough the organization

2. Risk Matrix: Detailed risk scoring and evaluation matrix with likelihood and impact assessments

3. Mitigation Controls: Comprehensive list of technical and organizational measures implemented

4. Stakeholder Consultation Records: Documentation of consultations with affected parties and relevant stakeholders

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok³ÉÈ˰æ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions





























Clauses















Industries

PDPA 2012: Singapore's Personal Data Protection Act 2012 - Primary legislation governing personal data protection in Singapore

PDPA Regulations 2021: Supplementary regulations that provide detailed requirements under the PDPA framework

PDPA Advisory Guidelines: Official guidelines providing interpretation and practical guidance on PDPA implementation

Sector-Specific Regulations: Additional regulations specific to different industries such as healthcare, banking, and telecommunications that may affect data protection requirements

GDPR Reference: European Union's General Data Protection Regulation as a reference point due to similarities with Singapore's PDPA

ASEAN Framework: ASEAN Framework on Personal Data Protection providing regional guidelines for data protection

APEC Privacy Framework: Asia-Pacific Economic Cooperation Privacy Framework establishing principles for data protection in the APEC region

Notification Obligation: PDPA requirement to inform individuals of the purpose for collecting, using, or disclosing their personal data

Purpose Limitation Obligation: PDPA requirement to collect, use or disclose personal data only for purposes that a reasonable person would consider appropriate

Consent Obligation: PDPA requirement to obtain valid consent before collecting, using, or disclosing personal data

Protection Obligation: PDPA requirement to implement reasonable security arrangements to protect personal data

Retention Limitation Obligation: PDPA requirement to cease retention of personal data when no longer necessary for legal or business purposes

Transfer Limitation Obligation: PDPA requirement ensuring adequate protection when transferring personal data outside of Singapore

Access and Correction Obligations: PDPA requirement to provide individuals with access to their personal data and make corrections when requested

PDPC Key Concepts Guidelines: Specific guidelines from PDPC explaining key concepts and obligations under the PDPA

PDPC Protection Guidelines: Detailed guidelines on implementing security measures to protect personal data

DPIA Guidelines: PDPC's guide on conducting Data Protection Impact Assessments for high-risk processing activities

Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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