Legitimate Interests Assessment (LIA)

[!NOTE] This is the Legitimate Impact Assessment performed by the developer of Citadel, as part of the development of Citadel. It can be used as a template to be used by a CISO / CIO during the Citadel deployment. The template should however be carefully analysed, verified for compliance, and adapted to the specifics of the organisation, for example with respect to data retention, local laws or use of external SIEM / SOAR solutions.

Citadel Browser Agent

Version: XX.XX
Prepared by: [Your Organisation Name]
Date completed: [YYYY-MM-DD]


1. Purpose Test

1.1 Reason for Processing Data

Citadel processes personal and technical data in order to:

  • Enable CISOs and CIOs to protect sensitive endpoints and web applications from threats
  • Detect and prevent policy breaches, malware, and shadow IT
  • Facilitate rapid and effective Digital Forensics and Incident Response (DFIR)
  • Provide proof needed for potential legal proceedings
  • Satisfy legal, regulatory, and contractual cybersecurity obligations

1.2 Expected Benefits

Benefit Description
Security improvement and Risk Reduction Real-time detection and prevention of policy breaches and malware
Compliance enhancement Enables compliance with cyber security requirements, such as IT policy enforcement, incident prevention, detection, analysis and resolution, in normative, lawful and contractual frameworks, such as ISO 27001, SOC 2, NIS2 and DORA
DFIR readiness Maintains evidence needed for incident response and forensic analysis
Cost reduction Identifies unused SaaS licences, reducing wasted spend
User safety Detects and prevents risky user behaviour or inadvertent data leakage

1.3 Third-party and Public Benefits

The expected benefits for third parties and the wider public:

  • Organisation users / clients benefit from increased security.
  • Organisation and its shareholders or stakeholders benefit from decreased risk.
  • Third parties (such as incident response / forensic providers) may benefit post-incident.
  • Broader reduction of data loss and harm to data subjects and the public sector.

1.4 Importance of the Benefits

Protecting enterprise and employee data is critical to business continuity, normative and regulatory compliance, and reputational trust. Failure to process this data would increase cyberattack exposure, risk of breaches, and legal liability.

1.5 Impact if Processing is Not Performed

Area Potential Impact
Cybersecurity Increased threat exposure, higher risk of undetected incidents
Compliance Inability to meet contractual or regulatory obligations, regarding IT policy enforcement, incident prevention, detection, analysis and resolution.
Operations Greater severity / cost of incidents, more complex forensics
User Trust Erosion of user / evidence trust, post-incident damage

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To the best of our knowledge, Citadel complies (or facilitates the compliance of organisations) with the following relevant legal and normative rules.

1. GDPR (General Data Protection Regulation)

  • Article 6(1)(f) — Legitimate interest as lawful basis for processing
  • Article 25 — Data protection by design and by default
  • Article 32 — Security of processing
  • Articles 33 & 34 — Notification of personal data breaches
  • Article 5(1)(c) — Data minimization
  • Article 5(1)(f) — Integrity and confidentiality

2. ISO/IEC 27001:2022 (Information Security Management Systems)

  • A.5.10 — Acceptable use of information and assets
  • A.5.20 — Management of technical vulnerabilities
  • A.5.23 — Information security for use of cloud services (logging, monitoring)
  • A.5.32 — Information security event logging
  • A.8.3.1 / A.8.3.2 — Management and improvement of information security events
  • A.8.7 — Monitoring activities (user activities, security exceptions, events)

3. DORA (Digital Operational Resilience Act — Regulation (EU) 2022/2554)

  • Article 9 — ICT risk management measures (monitoring & logging)
  • Article 13 — ICT-related incident detection, handling, reporting
  • Article 15 — Classification and documentation of ICT-related incidents
  • Article 21 — Information sharing (incident evidence, logs) between entities and authorities

4. NIS2 Directive (EU Directive 2022/2555)

  • Article 18 — Handling of security incidents
  • Article 21 — Cybersecurity risk management measures, controls
  • Article 23 — Incident notification to competent authorities
  • Article 24 — Notification content/timelines, evidence preservation
  • Annex I-II — Security requirements for essential/important entities

5. French CNIL Recommendations

  • Délibération n° 2021-122 du 14 octobre 2021
    Logging of security events (journalisation) — data minimization, proportionality

  • Draft “Web Filtering” Recommendations (July 2025)
    Web filtering transparency, proportionality, and privacy controls

6. NIST SP 800-53 Rev. 5 (for US-based or multinational organizations)

  • AU-2 — Event Logging
  • IR-4 — Incident Handling
  • SI-4 — Information System Monitoring

1.7 Codes of Practice and Ethics

We consider that Citadel implements (or facilitates the implementation by organisations) of the following relevant industry guidelines and codes of practise.

  • Privacy by design: data minimisation and privacy-preserving defaults
  • Transparency with users; monitoring is justified, documented, and proportionate
  • No behavioural profiling or marketing data use

Like all monitoring technology, Citadel poses an ethical dilemma: how to combine the need for information security with the right to privacy of the individual. At every step our design choices have been informed by the GDPR key principles of purpose limitation, storage limitation, confidentiality, and transparency.


2. Necessity Test

The data processed by Citadel helps to achieve the following purposes.

Purpose Processing Activity Necessary?
Security event prevention Raise policy infractions to IT staff Yes, experience has shown that training alone is not enough.
Security event detection Log events (downloads, compliance, suspicious activity) Yes, the absence of early detection means increased dwell time for attackers and increased risks.
Incident response / forensics Store endpoint / application events Yes, logs are required to understand and resolve incidents.

2.2 Proportionality and Alternatives

The following alternatives have been evaluated, to establish their impact on the efficacy and a proportionality has been established.

Purpose Less Intrusive Alternatives (if any) Outcome Proportionate?
Security / DFIR Omit (hashed) local navigation logs Inability to verify incident timelines and events. Yes
Security / DFIR Omit URL / filename in download / upload metadata Significantly reduced usefulness for DFIR Yes
Security / DFIR Log security incidents only for protected perimeter Significantly reduced usefulness for DFIR Yes

As a result the following privacy-preserving technical controls have been implemented:

  • URL masking: only events related to protected systems, or that have a direct and urgent security impact (e.g. virus detected, page blocked, possible phishing) are logged un-masked
  • Transparency dashboard: users can view which events are transmitted to the SIEM in real-time
  • Secret masking: passwords, API keys and credit cards that are masked when they appear by accident in the log events
  • Hashing URLs for non-critical / forensic events
  • Local-only storage for most non-incident data

2.3 Data Minimisation

Additionally, the following minimisations have been identified and implemented, so as to achieve the same goal with a minimum of data that is retained.

Data Type Retained? Minimisation Steps
Navigation URLs Partial Hashed and stored locally; only logged to server for protected systems or urgent security events
Browser errors / warnings Partial Only logged for protected systems or urgent security events
Download / upload metadata Partial Metadata only (no file content); logged only for protected systems or urgent security events; URLs hashed for non-protected systems
App / account usage stats Local only Stored locally only to detect minimum usage threshold; never transmitted to server
Passwords or other secrets (credit card, API key, etc) No Only local hashes and quality indicators retained regarding passwords entered in password fields, passwords entered elsewhere by mistake are masked from logs
Endpoint status Yes Only pass / fail or aggregated control state

3. Balancing Test

3.1 Nature of Personal Data Processed

An evaluation was performed of the type of data that is processed.

Data Category Description / Sensitivity Special Category?
Identifiers Username, application accounts No, unless used for special (e.g. union) accounts
Passwords & secrets High sensitivity, hashed when stored locally when entered in a password field, masked from logs if it appears by mistake No
App usage Local-only tracking to detect minimum usage threshold, but reports Yes / No indicator No
Security events Download / upload / print, browser error events - only for protected systems or urgent security events Some could be sensitive
Browser navigation High sensitivity, stored locally and hashed No
Endpoint compliance Pass / fail state, app/extension status No

The main remaining issue is the “Special Category”. This data is never processed intentionally, and extensive efforts have been made to exclude this data where possible. There remains however a residual risk of accidental capture if the user visits sensitive (e.g. health, religious) sites that are within the protected perimeter or trigger urgent security events, such as a virus, or a phishing attack.

Further analysis and measures are required if Citadel is deployed in contexts where it will process on a regular basis the personal data of children or other vulnerable people.

3.2 Reasonable Expectations

The expectations of data subjects have been evaluated as follows.

Factor Comment
Relationship Users are employees / agents of the organisation that is deploying Citadel. Security-related monitoring is disclosed and expected in a professional environment.
Transparency End-users notified (“transparency statement”, deployment briefings); real-time transparency dashboard allows users to view which events are transmitted to SIEM
Usage context Security / IT monitoring is standard in managed environments
Collection Data generated by device-user activity only; direct collection only; masking limits collection to protected systems and urgent security events
Innovation / novelty Aligned with best practice, SIEM / XDR standards, and privacy by design

3.3 Likely Impact on Individuals

Impact Area Assessment Safeguards
Privacy Minimal; URL masking ensures only security-relevant data for protected systems or critical security events is logged Data minimisation, transparency dashboard, local hashing, masking of URLs and secrets, SIEM access controls
Objection / Control Employee discomfort possible Opt-out / configuration options, internal helpdesk process.
Intrusiveness Very low: URL masking prevents logging of non-protected systems; no content captured; masking of passwords and secrets in logs Only protected systems monitored; usage is logged as Yes / No
Misuse Strict RBAC for SIEM / forensic data Role-based access, limited audit trail

Opt-out available:
Yes, via configuration or organisational process in special situations.


4. Decision and Action

Assessment Area Result Comment
Legitimate Interest Yes Organisation, user and public protection. Compliance, risk mitigation, and required investigation.
Processing necessary Yes Less intrusive means would impair security, detection or compliance.
Balancing outcome Acceptable Secret and URL masking mechanism, no detailed usage stats, minimisation, hashing, transparency, and “need to know” controls address risks.
Lawful basis Art. 6(1)(f) GDPR – Legitimate Interest Users are informed; DPIA / LIA documented and actively maintained.

5. Next Steps

  • Filing: Store this LIA and review annually, or on major technical or legal change.
  • Transparency: Summarise processing and legal basis in user privacy notices (see statement).
  • DPIA: Complete full DPIA where required by law, risk, or scale. (see template)
  • Review: Monitor for regulatory/technical updates; revise document as needed.