Every processing activity needs a legal reason, recorded before the processing starts. The lawful basis register keeps one reason for each activity, the reasoning behind it, and, for your own business interest, a balancing test approved by a second person.
Who can do this
An owner, editor or contributor of your workspace can record reasons and write balancing tests. Approving a test has to be done by someone other than its author. A viewer can see the register.
Find the register
Open Records & controls → Lawful basis. Activities are grouped into In force, Missing a reason, Test pending and All. Each row shows the activity, the Legal reason, the Balancing test and its Status.
The six grounds
- To deliver what they asked for, for example running an account.
- Because the law requires it, for example identity checks a regulator mandates.
- Our own business interest, which needs a balancing test approved by a second person.
- They said yes: consent, which must be as easy to take back as to give.
- Somebody’s safety, which is rare.
- Public interest, which is rare for a private company.
Which ground applies is a legal judgement about your own processing. Asiri does not propose one.
Record a reason
Press Record a reason.
- Choose the Linked activity. The list is your record of processing activities. If the activity is not there, add it first.
- Choose the ground.
- For consent, say whether it can be withdrawn as easily as it was given. If it cannot, the register shows the basis as one that does not hold.
- Under Decision rationale, write Why this ground applies. It is optional, but write it for a stranger reading it in two years.
Press Record the reason. An activity carries one reason at a time, and a reason is never edited. Recording a new one replaces the old, and both stay readable.
The balancing test
If you rely on your own business interest, the reason is recorded but not in force until a balancing test is written and approved.
- Press Write the balancing test, or open the balancing tests from the activity's reason.
- Under Write a balancing test, give the Activity reference, the Purpose, Why it is necessary, How the interests balance and the Safeguards, one per line. Press Record test.
- Someone else approves it. In Impact assessments, open Approvals. Under Balancing tests, they enter an Approval reason and press Approve. Asiri refuses an approval by the test's author.
On the reason
The reason's page shows Which reason applies?, Why that reason fits, The balancing test and What was recorded before. The rail lists what is still needed before the reason is in force.
If the register warns that an activity is unlawful today, it is not a missed deadline. The recorded ground is not available for that activity, and a later record does not make the earlier processing lawful. Change the ground, or correct the activity, and check the position with your DPO.
Common questions
"Can we change the reason after a complaint?" You can record a new one, but the old reason stays on the record with its dates.
"Can I approve my own balancing test?" No. A second person has to.