Data Protection Privacy Policy Statements

Using Your Personal Data: The Legal Basis and Purposes

We will use your personal data:

1.         As necessary to perform our contract with you to provide a service:

a)         to take steps at your request before entering into a contract

b)         to decide whether to enter into a contract

c)         to manage and perform the contract

d)         to update our records

e)         to trace where you live if we have to contact you about a service

f)          to send you marketing communications directly relating to your contract


2.         As necessary for our own legitimate interests or those of other people and organisations, e.g.:

a)         for good governance, accounting, and managing and checking our business processes

b)         to manage and provide services

c)         to monitor emails, calls, and other communications, related to the services we provide

d)         for market research (to find out what you think of us), analysis and developing statistics


3.         As necessary to comply with a legal obligation, e.g.:

a)         when you use your rights under data protection law and make requests

b)         to comply with legal and regulatory requirements and related disclosures

c)         to determine and defraud legal right

d)         for activities relating to the prevention, detection and investigation of crime

e)         to check your identity

f)          to manage and provide services

g)         to monitor emails, calls, and other communications, related to the services we provide


4.         Where necessary to perform a public task, e.g.:

a)         some of our functions are carried out on behalf of local authorities, including Devon and Somerset County Councils, to fulfil their statutory obligations

b)         this will be when we perform a task in the public interest, or for official functions

c)         these tasks will always have a clear basis in law


5.         Based on your consent, e.g.:

a)         to send you marketing communications where we have asked for your consent to do so

b)         when you ask us to disclose your personal data to other individuals or organisations, or otherwise agree to disclosures

You are free at any time to change your mind and remove your consent. The result might be that we can’t do certain things for you.

Your Right To Erase the Personal Data We Hold

If you would like the Trust to erase the data which we hold about you, please contact us.

The right to erasure does not apply if processing is necessary for one of the following reasons:

  • ​To comply with a legal obligation
  • For the performance of a task carried out in the public interest or in the exercise of official authority
  • For archiving purposes in the public interest, scientific research, historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievements of that processing
  • For the establishment, exercise or defence of legal claims

Sharing Of Your Personal Data

  • If the relevant data protection law allows, we may share your personal data with:
  • Local authorities for whom we provide services, including Devon and Somerset County Councils
  • Companies, organisations and individuals acting on our behalf who help us provide services
  • Companies, organisations and other individuals who provide services to us
  • Organisations for whom we supply a service
  • Our legal and other professional advisors, including our auditors
  • Government bodies and agencies in the UK and overseas (e.g. HMRC who may in turn share it with relevant overseas tax authorities and with regulators e.g. the Financial Control Authority, the Information Commissioner’s Office)
  • Courts, to comply with legal requirements, and for the administration of justice
  • In an emergency or to otherwise protect your vital interests
  • To protect the security or integrity of our business operations
  • Market research organisations who help to improve our products or services
  • Anyone else where we have your consent or where it is required by law

Your Marketing Preferences and Related Searches

We will use your home address, phone numbers, email address and social media (e.g. Facebook, Twitter, Instagram and message facilities on other platforms) to contact you according to your preferences. You can change your preferences or unsubscribe at any time by contacting us. In the case of social media messages, you can manage your social media preferences via that social media platform.

You can unsubscribe to our email mailing lists at any time, by following the unsubscribe link.

Criteria Used to Determine Retention Periods

The following criteria are used to determine data retention periods for your personal data:

  • ​Retention in case of queries We will keep your personal data as long as necessary to deal with your queries
  • Retention in case of claims We will keep your personal data for as long as you might legally bring claims against us
  • Retention in accordance with legal and regulatory requirements We will keep your personal data after we have provided a service based on our legal and regulatory requirements.

Data Aonymisation and Aggregation

Your personal data may be turned into statistical or aggregated data which can’t be used to identify you, then used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described above.

Your Rights Under Relevant Data Protection Law

Your rights are as follows (noting that these rights do not apply in all circumstances):

  • ​The right to be informed about our processing of your personal data
  • The right to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed
  • The right to object to processing of your personal data
  • The right to restrict processing of your personal data
  • The right to have your personal data erased (the “right to be forgotten”)
  • The right to request access to your personal data and information about how we process it
  • The right to move, copy or transfer your personal data (“data portability”)
  • Rights in relation to automated decision making including profiling

If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance, or directly to the Information Commissioner’s Office at