ICO guidance on legitimate interests: commercial interests count, a less intrusive route defeats it (Information Commissioner's Office, 'Legitimate interests', A guide to lawful basis, at a glance)
UK law accepts commercial interests too, but a licence that could be done as well with de-identified data fails the necessity part. That again favours sending de-identified lots.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Legitimate interests can be your own interests or those of third parties. This includes: commercial interests; individual interests; and broader societal benefits. You must ensure that your use of personal information is necessary for the purposes of the legitimate interests you've identified. If you can reasonably achieve the same result in another less intrusive way, legitimate interests doesn't apply.”
Where it was read
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in these 2 guides