Let’s move our focus towards the fairness and transparency of the process because having a legitimate ground is not enough. The way of processing is also vital for the respect of all the guarantees provided to the protection of personal data.
It is not possible to achieve fairness if the controlling party does not disclose all the information necessary for the individual to make a decision. Transparency is essential for the individuals to assess and freely decide if they wish to let his/her personal data be processed for “X” purpose and under “X” conditions. Fairness and Transparency start with how personal data is obtained.