Legitimate Interests Assessment (LIA)

Company: Active Planning Leads Ltd.
Registration Number: 12862897
Data Protection Registration (ICO): ZA800152
Address: The Old Chapel, 33 Church Street, Coggeshall, Essex, CO6 1TX

Date of Assessment: 05 April 2025

1. Purpose of the Processing (Purpose Test)

1.1. What are we doing with the data?
Active Planning Leads Ltd. collects publicly available information from local planning authorities across the UK and Northern Ireland. This includes applicants’ names, addresses, and details of proposed projects, which we manually re-key and format into our own proprietary database. We do not scrape, automate, or directly copy the planning authority’s format, and we do not contact the data subjects ourselves.

We provide this data to vetted commercial clients who intend to send a one-off postal letter offering services relevant to the applicant’s planning project (e.g. architects, builders, landscapers).

1.2. Why are we doing it?
- Enable our clients to provide relevant, professional services to planning applicants.
- Support small and local businesses in connecting with potential customers.
- Make constructive use of public domain data for economic activity and innovation.

1.3. Is there a legitimate interest behind the processing?
- The commercial interests of our clients, who use direct mail to offer services closely related to the applicant’s declared project.
- The interests of the planning applicant, who is likely to benefit from receiving useful service offers tailored to their planning intentions.
- The interests of Active Planning Leads Ltd. in providing a legal and socially beneficial data service.

2. Necessity Test

2.1. Is the processing necessary to achieve the purpose?

Yes.
- There is no realistic, less intrusive way to achieve the same outcome.
- Public domain data is essential to enabling timely and relevant marketing.
- Processing is limited to the minimum necessary: we only process name, address, project type, and any publicly disclosed contact details.

3. Balancing Test

3.1. What is the nature of the data?
- The data is public domain information, published by planning authorities.
- It is not special category data.
- It includes names, addresses, project types (e.g. "rear extension"), and sometimes phone numbers or emails when voluntarily disclosed.

3.2. Would individuals expect their data to be used in this way?
- Very likely.
- Planning applicants are adults of sound mind who knowingly and voluntarily submit planning applications into the public domain.
- It is reasonable to expect that submitting such information could result in interest from businesses offering related services.

3.3. Is the processing likely to cause harm or distress?
- Very unlikely.
- The data subjects receive a single postal letter, not repeated marketing or intrusive contact.
- Our clients are instructed and contractually bound to use the data once only, with no follow-up or data retention for marketing beyond the initial contact.

3.4. What safeguards do we have in place?
- Clients are contractually required to use the data solely for one-time postal marketing.
- Clients must not store or reuse data or pass it to third parties.
- We maintain a clear audit trail of data sharing and issue warnings or terminate access for misuse.
- We maintain a clear, published privacy policy informing individuals of our practices and their rights under the UK GDPR.

4. Conclusion and Outcome

We believe that our use of planning application data meets the conditions for Legitimate Interest under Article 6(1)(f) of the UK GDPR.
The processing is necessary, proportionate, and does not override the rights or freedoms of the data subjects. The balance between commercial utility and individual privacy has been carefully considered, with safeguards in place.

5. Review and Sign-Off

Data Protection Officer / Responsible Person:
Stuart Fairly - Data Controller
Active Planning Leads Ltd.
info@activeplanningleads.com
Date of Assessment: 05 April 2025
Date of Next Review: 05 April 2026
✅ Signed and approved as of 05 April 2025