Legitimate Interests Assessment for Brandon & Robertson Associates Ltd.

Brandon & Robertson Associates Ltd has undertaken a Legitimate Interests Assessment and this is documented below. The Assessment conforms to the

Guidance for Legitimate Interest Assessments provided by the Information Commissioner’s Office (‘ICO’).

See ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/legitimate-interests/

Our experience spans technical, regulated, and niche B2B markets, as well as selective healthcare-related research, enabling us to support projects at regional, national, and international levels. We focus on engaging real professionals within complex organisations, applying robust recruitment processes and sector understanding to deliver reliable data collection where access is often challenging.

Identifying a Legitimate Interest

It is our aim to provide an Internet based service (The Service) for Respondents from Consumers, the Business Community as well as Healthcare professionals, including Pharmaceutical Companies and Researchers, Consultants, GPs and their Secretarial Staff and Patients, and those who need to work with healthcare professionals for healthcare purposes that enables us by means of processing data, to identify, locate and contact appropriate respondents according to their experience, qualifications, location, speciality, special interests and other available information.

Data Subject Groups have been identified who will benefit from this process including Consumers from the wider public community ( B2C), members of the Business Community (B2B) and Healthcare professionals (HCP) and their patients, all of whom would benefit from the development of improved products and services (B2C & B2B), and under Health Care (HCP) improved and safer drugs and treatment methods.

Under B2C & B2B the purpose of this process is to gather data to understand customer needs, reduce risks, identify market opportunities, and make informed, data-driven decisions regarding products, pricing, and strategy which enables industry sectors to understand competitor strengths and weaknesses, analyse market trends, and effectively reach target audiences.

Under HCP there are wider public benefits including patients, both NHS and Private who may use The Service to identify a conveniently located doctor with relevant expertise. The Service also helps pharmaceutical and medical device companies to find Specialists or GPs interested in clinical trials and research and law firms and insurance companies to find doctors to act as expert witnesses in medico-legal claims.

These benefits are very important for helping the General Public and Business community as a whole as well as patients, researchers, personal injury and clinical negligence claimants and healthcare professionals.

If we could not collect, compile and process data in the way we do The Service would cease to the detriment of all concerned.

The use of the data we collate and the purpose to which it is put in providing The Service is not unethical or unlawful in any way.

The Necessity Test

The processing we do is vital to and an integral part of The Service which uses Information Technology and the Internet for communicating with data subjects to obtain their up-to-date details and provide the service efficiently and cost-effectively to users for the related purposes.

Our approach and methodology in providing The Service is reasonable and as in-obtrusive as possible, using Information Technology and the Internet for communicating with data subjects to obtain their up to date details and provide the service efficiently and cost-effectively to users for healthcare related purposes.

We make every effort to be as inobtrusive as possible in collecting and compiling data and the intrusion to data subjects is minimal, making full use of email, telephone, fax and postal methods of communication with data subjects. As a considerable number of healthcare organisations use The Service, there is less intrusion to data subjects as they supply the data once for use by many different healthcare users who would otherwise have to contact the data subjects individually themselves. This would be considerably more intrusive.

The Balancing Test

Brandon & Robertson Associates Ltd is independent from both the users of The Service and the data subjects. We are regulated by ESOMAR, BHBIA and the ICO.

The data we collect, and process is neither particularly sensitive nor private. It mainly consists of names, work contact details (telephone, fax, email and postal addresses), qualifications, where and when qualified, specialty and special interests. Personal details will always be anonymised.

We are always happy to explain what we do with data to our data subjects, who are regularly contacted to inform them of the existing details we hold, to enable them to update these details where necessary and to re-iterate the use to which the details are put in The Service.

Inevitably some data subjects find the process obtrusive, but experience has shown this to be a very small number (< 0.1%). In addition, we pay for participation which many data subjects welcome.
The impact on any specific data subject is minimal and consists of regular contact by email, telephone, fax and post twice per year and often less.

We do not believe any of the individuals we contact are vulnerable other than in the case of patients where contact is conducted through their HCP so that specific vulnerabilities can be managed.

In order to minimise impact to data subjects, details of contact dates and responses are stored to avoid repetition of contact and deletions are marked as such to avoid contact again through subsequent research.

We offer an opt-out either on a project-by-project basis or on a blanket opt-out basis if the data subject does not wish to be included. Removal from The Service is avoided where possible as it could imply erroneously that the data subject was no longer practising.

Outcome of Assessment

The above assessment shows that The Service is of considerable benefit not only to the Controller but also to the Data Subjects concerned in assisting them to provide their experience and expertise to the relevant industry sectors. The inclusion of data subjects in the Service may result in data subjects receiving postal, telephonic, fax or email (where they have provided it) communications from the Controller. Communications may also be received from users of The Service on a related topic.

Users will normally use the location, specialty and special interests’ data provided by The Service to communicate with data subjects likely to be interested in the topic concerned. If the topic is of no interest to the data subject, it is easy to dispose of, or delete, the communication concerned. This minor inconvenience, which can easily be delegated to secretarial staff, is insignificant compared to the potential benefits of The Service to the data subjects themselves by promoting their experience, expertise, and interests to relevant organisations.

Further information is available from the ICO direct on the following link https://icosearch.ico.org.uk/s/search.html?collection=ico%7Esp-search&profile=_default&query=legitimate+interest

Signed:
Douglas Robertson

Position:
Quality Director

Review Date:
18th February 2026