Contract analysis

1. Introduction and Purpose 1.1 Background to the Assessment This Data Protection Impact Assessment ("DPIA") is conducted pursuant to Article 35 of the UK General Data Protection Regulation ("UK GDPR") and the General Data Protection Regulation (Regulation (EU) 2016/679) ("EU GDPR"), which require a data protection impact assessment to be carried out where a type of processing — in particular one using new technologi

2. Systematic Description of Processing Operations In accordance with Article 35(7)(a) of the UK GDPR and EU GDPR, this section provides a systematic description of the envisaged processing operations, including the purposes of processing and, where applicable, the legitimate interests pursued by the controller. 2.1 Nature of the Processing The marketing profiling and targeted advertising activities on the NorthCloud

3. Assessment of Necessity and Proportionality In accordance with Article 35(7)(b) of the UK GDPR and EU GDPR, this section assesses the necessity and proportionality of the processing operations in relation to their purposes. 3.1 Lawful Basis Analysis The lawful bases currently relied upon or proposed for the marketing profiling and targeted advertising activities on the NorthCloud freemium tier are as follows: Conv

4. Consultation with Stakeholders In accordance with Article 35(2) and (9) of the UK GDPR and EU GDPR, the controller has sought the views of relevant stakeholders in the preparation of this DPIA. 4.1 Internal Stakeholders Consulted The following NTP internal stakeholders were consulted during the preparation of this DPIA: Sanjay Mehta — Data Protection Officer, Northgate Telecommunications PLC. Mr Mehta was consulte