Data Processing & Legitimate Interest: Where do charity supporters draw the line?

data processing under legitimate interest

Data Processing & Legitimate Interest: Where do charity supporters draw the line?

Post-GDPR day, many charities are still adjusting to a new approaches to data processing, and a new way of utilising data to better serve supporters and beneficiaries. For many, the choice between where to apply consent and where to apply legitimate interest has been a difficult one. While consent, arguably more difficult to action, places responsibility firmly in the hands of supporters, legitimate interest does allow more flexibility – within reason.

Post-GDPR legitimate interest places the onus on charities to safeguard the rights and freedoms of their supporters. It is not a ‘get out of jail free’ card, and legitimate interests need to be carefully examined to make sure they’re right for everyone involved. Surely, the case for implementing legitimate interests must be different to each charity, as every case is unique, but there is a question about what supporters generally feel comfortable with, in terms of data processing. The table below is a real example of data from a charity legitimate interest assessment fastmap carried out.

Percentage of those who agree it is appropriate to use information gathered through the following data processes

data processing and legitimate interest in charity

Understandably, using a supporter’s own donation history to target communications and drive marketing insights is clearly something supporters are accustomed to and it’s something they expect to happen.

Not too far behind is the use of a supporter’s social media information or the use of cookies to track a supporter’s digital footprint. Supporters are becoming increasingly digitally savvy as digital fundraising continues to grow. Perhaps we can infer from these results that with this comes an expectation that digital tools will be used to better serve supporters’ needs.

What is no surprise, especially following a round of unprecedented fines in 2017, is that data processing that involves the use of wealth screening or delving into a supporter’s credit file is a comparatively unpopular option. However, it is interesting that the use of census data and other publicly available information is still a comfortable option. It does seem, then, that supporters aren’t too happy with charities going behind the scenes and sharing data in order to build a deeper profile.

Keep in mind that whatever the statistics say, claiming to have a legitimate interest requires careful thought, nuance and an individualised approach unique to your charity and supporters. There are clearly benefits to use legitimate interest assessments and interrogate information provided to your organisation up front, but it may also be worth investigating the use of digital fundraising tools to help deepen your relationship with your supporters and ultimately improve marketing performance.

This article was written by Aris Tsontzos, fastmap Associate and Independent Data Protection Trainer and Consultant. To find out how fastmap can help you with your data protection, data processing and legitimate interest strategy visit or get in touch with David Cole, Managing Director, fastmap on +44 (0) 20 7242 702 or

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