Contract analysis

1. INTRODUCTION AND PURPOSE OF THIS ASSESSMENT 1.1 Background Northgate Telecommunications PLC ("NTP" or the "Company") is a United Kingdom-headquartered public limited company (Company Number: 04837291) operating telecommunications infrastructure, managed connectivity services, and software-as-a-service ("SaaS") platforms across the United Kingdom and the European Union. In the financial year ended 31 March 2023 ("F

1. Evaluation or scoring — the Model evaluates individual subscribers and generates predictive scores regarding their behaviour (likelihood of churn).

2. Automated decision-making with legal or similar significant effect — whilst the Model does not itself make final decisions, its outputs are used to inform decisions regarding retention actions that may affect subscribers' service experience.

3. Processing of data on a large scale — approximately 2.1 million data subjects are processed.

4. Innovative use or applying new technological or organisational solutions — the deployment of a machine learning-based predictive model for individual-level churn scoring represents an innovative application of technology within NTP's operations. It should also be noted that NTP's prior regulatory history heightens the importance of conducting robust DPIAs. On 15 September 2021, the ICO issued Enforcement Notice EN

2. SYSTEMATIC DESCRIPTION OF THE PROCESSING 2.1 Nature of the Processing The NorthCloud AI-driven customer churn prediction model is a machine learning system designed and operated by NTP's Data Science team (which reports to Laura Dearden, VP, Product & Engineering) to analyse multiple categories of customer data and generate a predictive assessment of the likelihood that individual NorthCloud subscribers — both ent

3. ASSESSMENT OF NECESSITY AND PROPORTIONALITY 3.1 Lawful Basis The lawful basis relied upon by NTP for the processing of personal data through the Churn Model is legitimate interest under Article 6(1)(f) GDPR / UK GDPR. NTP's legitimate interest in the processing is the reduction of customer churn on the NorthCloud platform, the improvement of service quality and customer satisfaction, and the maintenance of the com

4. IDENTIFICATION AND ASSESSMENT OF RISKS 4.1 Risk Framework The risks identified in this Section 4 have been assessed using a risk assessment methodology consistent with the guidance provided by the ICO (How do we do a DPIA?, updated March 2023) and the EDPB (Guidelines on Data Protection Impact Assessment, WP 248 rev.01). Risks are assessed on a matrix with two dimensions: Likelihood — the probability that the risk