To comply with GDPR, First Construction Finance Ltd t/a Ringrose Business Finance has carried out a Legitimate Interests Assessment, which is documented below

Purpose of Processing
We have a legitimate interest in processing Limited Companies Directors’ personal data, which is gathered from
publicly available sources relating to decision makers in UK SME’s.

Reasonable Expectations and Lawful Business Objectives
The data subjects are Company Directors with decision-making and budgetary responsibilities and can
reasonably expect to be contacted with marketing material relating to their professional roles.
Adequate, Relevant and Limited

The data collected is limited to the names of directors, their company names and email addresses.


If a data subject requests that their data is removed from the database, it is suppressed so that it cannot be
accessed or added again at a later date.

Legitimate Interest
We believe the material and information we are sending out is a legitimate interest
We have updated our privacy policy confirming our usage of legitimate interests to process some of our data.

What is Legitimate Interests?
Legitimate Interests is one of the six lawful bases for processing personal data under the GDPR (General Data
Protection Regulation). You must have a lawful basis in order to process personal data in line with the
‘lawfulness, fairness and transparency’ principle.

Legitimate interests might be your own interests, or the interests of the third party receiving the data, or a
combination of the two.

Latest guidance from the Information Commissioner says that legitimate interests may be the most appropriate
basis when:

“The processing is not required by law but is of a clear benefit to you or others; there’s a limited privacy impact
on the individual; the individual should reasonably expect you to use their data in that way; and you cannot, or
do not want to, give the individual full upfront control (i.e. consent) or bother them with disruptive consent
requests when they are unlikely to object to the processing.”