Forms

New-purpose legitimate interests compatibility assessment

Record and evidence the assessment of whether a proposed use of personal information for a new purpose is compatible with the original purpose when relying on legitimate interests, before the new-purpose processing proceeds.

Form
CalmComplianceForm template

New-purpose legitimate interests compatibility assessment

Version
v1
Updated
7 October 2026
Reviewed
7 October 2026
Audience
Data protection leads, school leaders, governors or trustees, and staff responsible for proposing or approving new-purpose processing in maintained and academy primary and secondary schools in England.
Jurisdiction
england

Blank fields · read-only preview

When to use this form

Complete this form before processing personal information for a further purpose where the information was collected for an original purpose and legitimate interests is being considered or relied on as the lawful basis. Record the actual purposes, circumstances, people affected, compatibility analysis, any new legitimate interests assessment, and resulting safeguards.

Assessment details

School name

Required

Enter the name of the maintained or academy school conducting this assessment.

Written response

Assessment owner

Required

Enter the name and role of the person responsible for completing this assessment.

Written response

Date of assessment

Required

Enter the date on which this assessment is completed.

Day
Month
Year

Proposed start date for the new-purpose processing

Required

Enter the planned start date. The processing should not proceed before this assessment and any required approvals are complete.

Day
Month
Year

Describe the proposed processing activity

Required

Describe what the school proposes to do with the personal information, including the systems, recipients, locations, and frequency involved.

Written response

What was the original purpose for collecting the personal information?

Required

State the specific purpose communicated or understood when the information was collected.

Written response

What is the proposed new purpose?

Required

State the specific further purpose for which the personal information would be used.

Written response

Explain the relationship between the original purpose and the proposed new purpose

Required

Explain why the new purpose is connected to, expected from, or otherwise related to the original purpose. Identify any material differences.

Written response

What personal information will be used?

Required

List the data elements or categories involved. Identify any special category or criminal offence information if applicable.

Written response

Which people may be affected?

Required

Select all groups whose personal information may be used or who may be affected by the processing.

Choose all that apply

  • Pupils
  • Parents or carers
  • School staff
  • Governors or trustees
  • Visitors or volunteers
  • Suppliers or contractors
  • Other individuals
  • Other

If other, please specify

What would the affected people reasonably expect?

Required

Describe what the people affected would reasonably expect the school to do with their information in the circumstances.

Written response

What potential effects, risks, or consequences could the new purpose have for the people affected?

Required

Consider privacy intrusion, loss of control, distress, discrimination, disadvantage, unexpected decisions, security risks, and effects on children or other vulnerable people.

Written response

Which compatibility factors support or weigh against the new purpose?

Required

Address the link between the purposes, the context of collection, the nature of the information, the relationship with the individuals, their reasonable expectations, and the possible consequences.

Written response

Why is using this personal information necessary for the proposed new purpose?

Required

Explain why the purpose cannot reasonably be achieved without this processing, and identify less intrusive alternatives considered.

Written response

Is a new legitimate interests assessment required for the proposed processing?

Required

Select the applicable answer and explain the basis for it in the next field.

Choose one

  • Yes
  • No
  • Uncertain; obtain data protection advice before proceeding

Record the legitimate interests assessment or explain why a new one is not required

Required

If a new assessment is required, record the legitimate interest, the necessity assessment, the balancing assessment, and the conclusion. If one is not required, explain the reasoning and identify any advice relied on.

Written response

How will transparency information be addressed?

Required

Describe any updates needed to privacy information, notices, communications, or other information provided to the affected people.

Written response

What safeguards will apply before and during the new-purpose processing?

Required

Record measures such as data minimisation, access restrictions, retention limits, pseudonymisation, security controls, recipient restrictions, review points, and arrangements for handling objections or requests.

Written response

Who will receive or access the personal information?

Required

List internal roles, external organisations, processors, or other recipients. State where access will occur and what access limitations apply.

Written response

How long will the information be retained for the new purpose?

Required

State the retention period or review rule and explain how secure deletion or disposal will be managed.

Written response

What is the compatibility conclusion?

Required

Select the conclusion supported by the analysis. Do not allow the new-purpose processing to proceed while the conclusion is unresolved.

Choose one

  • Compatible with the original purpose
  • Compatible only if the recorded safeguards are implemented
  • Not compatible with the original purpose
  • Unresolved; obtain further data protection advice

Explain the conclusion and any conditions

Required

Summarise the reasons for the conclusion, including any conditions that must be met before processing starts and any matters requiring review.

Written response

Name and role of the person who reviewed or approved this assessment

Required

Enter the reviewer or approver responsible for confirming that the assessment is complete and appropriate for the school's circumstances.

Written response

Review or approval date

Required

Enter the date on which the assessment was reviewed or approved.

Day
Month
Year

I confirm that this assessment reflects the actual purposes and circumstances and that the new-purpose processing will not proceed until any required actions and safeguards recorded in this form have been completed.

Required

Tick only when the statement is accurate.

  • Tick when complete

When must this assessment be reviewed?

Required

State the review date or events that will trigger a review, such as a change in purpose, data used, recipients, technology, affected people, safeguards, or risk.

Written response

CalmCompliance · v1Template for adaptation

Template details

Type
Form
Version
v1
Updated
7 October 2026
Reviewed
7 October 2026

Get this template

Free, editable Word document. We’ll email you a download link. No Calm account needed.

Edit in Word or Google Docs.

We record your email and the template you request. Read our privacy policy.

New-purpose legitimate interests compatibility assessment - CalmCompliance