Legitimate Interest Assessment
Last updated: 2 April 2026 | Tentrois Ltd
1. Purpose of This Assessment
This Legitimate Interest Assessment (LIA) documents Tentrois Ltd's Article 6(1)(f) UK GDPR balancing test for the processing of publicly available business contact data to deliver our B2B lead intelligence service.
2. Identify the Legitimate Interest
2.1 What is the purpose of processing?
To collect publicly available business information (company names, job postings, funding announcements, registry filings) and process it into qualified, enriched lead intelligence for our B2B clients. Our clients use this intelligence to identify companies that may benefit from their products and services.
2.2 Who benefits?
- Our clients — Receive qualified leads with intelligence to support sales outreach, reducing time spent on unqualified prospecting
- Tentrois — Delivers our core commercial service
- Data subjects (businesses) — May receive relevant, targeted approaches from companies whose products solve genuine business needs, rather than untargeted spam
2.3 Is this a recognised legitimate interest?
Yes. B2B direct marketing and commercial prospecting are recognised legitimate interests under UK GDPR Recital 47, which states that "the processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest."
3. Necessity Test
3.1 Will processing achieve the purpose?
Yes. Processing publicly available business data through our 6-stage pipeline (extraction, transformation, signal intersection, scoring, enrichment, delivery) is directly necessary to identify companies showing genuine buying signals and deliver actionable intelligence to our clients.
3.2 Is this the least intrusive method?
Yes. We apply multiple proportionality safeguards:
- We only collect data that is already publicly available (public job boards, news feeds, government registries)
- We do not scrape private social media profiles, personal email addresses, or personal phone numbers
- We apply an enterprise blocklist filtering out large corporations (5,000+ employees) to focus on mid-market companies where our service adds genuine value
- We apply signal intersection requiring 3+ independent growth signals before a company qualifies — ensuring we only process data for companies genuinely showing buying intent
- We apply 30-day delivery deduplication so the same company is not repeatedly surfaced
- Each lead is delivered to one client only — leads are never shared or resold
4. Balancing Test
4.1 Nature of the data
| Data Element | Sensitivity | Source |
|---|
| Company name, domain, country | Low (public corporate info) | Registries, news, job boards |
| Job posting titles and departments | Low (publicly posted) | Public ATS APIs |
| News mentions (funding, launches) | Low (public news) | RSS feeds, news APIs |
| Business contact name and title | Medium (business context only) | Public job boards, company pages |
| Business email (where public) | Medium (business context only) | Public company pages |
No special category data (Article 9) is processed. No personal/consumer data is collected.
4.2 Reasonable expectations of data subjects
When businesses post job listings on public ATS platforms, publish press releases, file company registrations, or list team members on company websites, they reasonably expect this information to be read and used for business purposes including commercial outreach.
4.3 Impact on data subjects
- Positive: May receive relevant, well-researched business approaches
- Negative (minimal): May receive unwanted but professional business contact
- Mitigations: Data subjects can object at any time (privacy@tentrois.com), and we will remove their data within 30 days. Our clients are contractually required to honour opt-out requests.
4.4 Safeguards
- Data minimisation — only business-context data collected
- Purpose limitation — data used solely for B2B lead intelligence
- Retention limits — raw data deleted after 90 days, qualified data after 12 months
- Objection mechanism — clear process at privacy@tentrois.com
- No automated decision-making with legal effects — scoring assists human sales processes only
5. Outcome
Our legitimate interests in providing B2B lead intelligence are not overridden by the rights and freedoms of data subjects, given that:
- All source data is publicly available
- Processing is limited to business-context information only
- Multiple proportionality safeguards are applied
- Data subjects can object and be removed at any time
- The impact on data subjects is minimal and expected in a business context
Decision: Processing may proceed under Article 6(1)(f).
6. Review
This assessment will be reviewed annually or when there is a material change to our data processing activities. Next review date: 2 April 2027.