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
RequiredEnter the name of the maintained or academy school conducting this assessment.
Written response
Assessment owner
RequiredEnter the name and role of the person responsible for completing this assessment.
Written response
Date of assessment
RequiredEnter the date on which this assessment is completed.
- Day
- Month
- Year
Proposed start date for the new-purpose processing
RequiredEnter 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
RequiredDescribe 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?
RequiredState the specific purpose communicated or understood when the information was collected.
Written response
What is the proposed new purpose?
RequiredState 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
RequiredExplain 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?
RequiredList the data elements or categories involved. Identify any special category or criminal offence information if applicable.
Written response
Which people may be affected?
RequiredSelect 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?
RequiredDescribe 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?
RequiredConsider 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?
RequiredAddress 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?
RequiredExplain 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?
RequiredSelect 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
RequiredIf 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?
RequiredDescribe 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?
RequiredRecord 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?
RequiredList 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?
RequiredState the retention period or review rule and explain how secure deletion or disposal will be managed.
Written response
What is the compatibility conclusion?
RequiredSelect 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
RequiredSummarise 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
RequiredEnter 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
RequiredEnter 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.
RequiredTick only when the statement is accurate.
- Tick when complete
When must this assessment be reviewed?
RequiredState 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
