What is “legitimate interest assessment” for data sourcing?

A Legitimate Interest Assessment (LIA) is a documented analysis required when using legitimate interest as your GDPR lawful basis for processing personal data.

The three-part test:

Purpose test: Identify your specific legitimate interest. Business development can qualify, but must be articulated clearly. Generic statements aren't sufficient.

Necessity test: Demonstrate that processing this data is necessary to achieve that interest. Could you accomplish the goal without this specific data or processing?

Balancing test: Weigh your interest against the individual's rights and expectations. Consider: Would they expect this use? What's the impact on them? What safeguards exist?

Documentation requirements:

Record your analysis in writing

Include specific reasoning for each test

Review and update when circumstances change

Be prepared to produce the assessment if challenged

For cold email data sourcing: The balancing test is often the challenge. Recipients may not expect sales contact based on where their data was published. Volume and frequency matter. Relevance to their professional role helps justify the balance.