The SAVVI Information Governance Framework

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Select the GDPR Lawful Basis

Select and justify one Lawful Basis from GDPR Article 6. See the ICO guidance at . The ICO provides a Lawful basis interactive guidance tool at
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What are the lawful bases for processing?

The lawful bases for processing are set out in Article 6 of the UK GDPR. At least one of these must apply whenever you process personal data:
(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
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Each lawful basis needs to be considered individually, taking into account the ICO Guidance. It is likely that, for a SAVVI Purpose, as a public body …
where you have a statutory-obligation/duty to provide a service, select (c)
otherwise, where you have established a remit/power to provide a service, select (e)
otherwise, where the purpose is essential to saving lives, select (d)
otherwise, in limited circumstances there may be a case for a Public Body to select (f)
A SAVVI vulnerability initiative would be unlikely to use (a), or (b)

Steps


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Select a GDPR Article 6 Lawful Basis

See Read the ICO guidance and select one Article 6 Lawful Basis.

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Extra steps if Legitimate Interests’ was selected

The ICO provide an assessment template at

… which helps to determine if Legitimate Interests is appropriate.


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No Lawful Basis?

If no appropriate lawful basis is selected, the data processing cannot continue.


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