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Establish the Lawful Reuse of Data

Personal data will have been initially collected for an original purpose, such as Health, Social Care, Policing, Education and so on. The Risk Model will propose using that data for a new Purpose, without the explicit consent of the data subject. We therefore need to establish a lawful basis for the reuse of the data.
1
You can only use the personal data for a new purpose if either this is compatible with your original purpose, you get consent, or you have a clear obligation or function set out in law.
2
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Principle (b): Purpose limitation | ICO
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Each group of Risk Factors from the same combination of
Source Organisation
Information Type
should be considered in turn.

Steps

1
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Purpose Compatibility Assessment

For each Information Type, an assessment is made to judge if the new Purpose is ‘compatible’ with the original Purpose.

See
Purpose Compatibility
⁠
in the SAVVI Information Governance Framework
2
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Is the Purpose Compatible?

If you have decided that the reuse of data, from an existing Information Type, is compatible with its original Purpose, you can skip the next step.
3
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Propose the Lawful Basis for Reusing Data for this New Purpose

For each Information Type, a lawful basis, including a specific Legal Gateway is proposed.

See
The Lawful Reuse of Existing Data
⁠
in the SAVVI Information Governance Framework
4
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Not Lawful!

If a lawful basis, together with necessary legal gateways cannot be found, the initiative should not attempt to build a cohort, but instead focus on unblocking legal access to data.
5
action.png

Make a Data Reuse Proposition

Bring all the information collected so far together into a single Proposition covering
Purpose
Risk Factors
Data Sources
Lawful Basis
Enablers

This should only contain information that would be useful to others who want to repeat the same approach, and should avoid local implementation details. Much of this information will be used when asking for the Data.
See
Make a Data Reuse Proposition
⁠
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SAVVI provides a template to capture a proposal to reuse data.
using the SAVVI Data Reuse Proposition Template.
See Templates.
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