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Avanti Scout

Legitimate interests assessment/legal/legitimate-interests-assessment

The lawful basis, and the assessment that tests it

Legitimate interest is the basis this product will rely on to process publicly available review data. It is the basis that requires you to show your working, so the working is written down. This page states what that document contains and exactly where it stands, which today is drafted and unsigned.

Where the assessment stands today

Draft. Not in force, and the text is not published on this site yet.

Status
Draft
Version
0.1.0
Drafted
29 August 2026
Signed off by
Nobody. It is unsigned.
Reviewed by
Nobody qualified has read it. A data protection adviser reviews it before signature.
Processing started
No. No review data has been acquired and none of the processing described has begun.

Those six lines are read from the document itself on every build rather than typed here, so the day one of them changes this page changes with it. The version and the date come from the document front matter, and the file is recorded by its sha256 digest.

What the assessment contains

It follows the three-part structure the Information Commissioner's Office sets out, purpose then necessity then balance, and it is written before the processing rather than after it, which is the point of the exercise.

  1. Section 0What is being assessed
  2. Section 1Purpose test: is there a legitimate interest?
  3. Section 2Necessity test: is the processing necessary for that purpose?
  4. Section 3Balancing test
  5. Section 4Conclusion of the balancing test, stated
  6. Section 5Related assessment
  7. Section 6Record of this assessment

The section list is read from the document, so a section added, renamed or removed there shows here without anybody remembering to update this page.

What it concludes, and what would reverse it

The balance is assessed as falling in favour of proceeding, subject to every safeguard being in place before the first review record is ingested. The conclusion is conditional and the conditions are written into the document rather than left implicit. One materially more effective option, linking a reviewer across platforms, is refused as disproportionate, and that refusal is the clearest evidence that the balance was struck rather than assumed.

  • If the benchmark fairness gate could not be met and the product shipped anyway.
  • If cross-platform reviewer linkage, real names or contact details were ever introduced.
  • If the corpus were used for any purpose beyond producing scouting reports and the aggregate Insights line.
  • If a commercial relationship could reach a score.
  • If data were acquired by any route other than the two the assessment names.

When it is published in full, and where

It is published here, in full, in the same reviewed change that records the signature. Publishing the text before then would put a page on this site reproducing a document whose own first line says it is not in force and not published, and a page that contradicts the thing it quotes is worse than a page that is honest about waiting.

The draft is held in the product repository at docs/legal/legitimate-interests-assessment.md, and the product application renders it for review at /legal/legitimate-interests-assessment behind the same draft banner. Neither is a public publication and this page does not link to either as though it were.

A Data Protection Impact Assessment is likely to be required for this processing as well. It has not been carried out, this assessment is not a substitute for it, and it does not claim to be.