BILETA Response to ICO consultation on draft recognised legitimate interest guidance: requesting personal information for your public tasks or official functions

This submission constitutes the British and Irish Law Education Technology Association (BILETA) response to the Information Commissioner’s Office (ICO) consultation on draft guidance for "Recognised Legitimate Interests: Requesting personal information for your public tasks or official functions." The response analyses the ICO's proposed guidance concerning the new "Recognised Legitimate Interest" (RLI) lawful basis introduced by the Data (Use and Access) Act. Specifically, it examines the condition allowing organizations to voluntarily share personal data with public authorities without performing a traditional balancing test, provided the data is requested for valid public tasks. The submission evaluates the guidance’s legal clarity, the distinction between this new basis and the existing "Public Task" basis, and the necessary safeguards to ensure such data requests remain necessary, proportionate, and transparent.