Legitimate Interest Statement: Union Press Ltd, publishers of The Drinks Business
You have asked me to consider whether our mailing magazines to the people on our mailing list is covered by the Legitimate Interests of Union Press Limited and its subsidiaries (UPL).
Most of the recipients have been receiving copies of the magazines for a number of years and form the basis of our business. Copies of the magazines are mailed by our fulfillment subcontractors, PLI/Seabourne Group and Spatial Global Ltd from records maintained by ourselves.
We need to ensure that every recipient is notified that we hold information on them and that they have an absolute right to amend or delete such information. For many years all our communications have carried this notice and we intend to continue so to do. It might be sensible to include the Privacy Statement in every magazine (and of course on line).
Having considered the the three tests:
1: Identify a Legitimate Interest
UPL depends for its income largely on hard copy advertising and this in turn depends upon the number of recipients. This is a Legitimate Interest under the terms of the Act.
2: Carry out a neccessity test
There is no practical way to ensure that our readers receive the magazine other than storing the customers name and address within our in-house system. Therefore the exercise passes the necessity test.
3: Carry out a Balancing Test
The definition of this test is that the rights and freedoms of the individual whose Personal Data will be processed have been evaluated, and these interests do not override the Controllers’ Legitimate Interest. The method of storing the minimum amount of information and offering to amend or delete such at the person’s request passes this test.
For the three reasons stated above the mailing of magazines is a Legitimate Interest of Union Press Limited.
Union Press Limited, 69 Southwark Bridge Road, London SE1 9HH, Great Britain
Telephone: +442078032420 Fax: +442078032421
Company Registration no: 3606414 •. Registered in England