Our GDPR policy sets out our commitment to protecting personal data and how we implement that commitment with regards to the collection and use of personal data.

GDPR sets out seven key principles:

Lawfulness, fairness and transparency

  • We have identified an appropriate lawful basis for our processing.
  • If we are processing special category data or criminal offence data, we have identified a condition for processing this type of data.
  • We don’t do anything generally unlawful with personal data.
  • We have considered how the processing may affect the individuals concerned and can justify any adverse impact.
  • We only handle people’s data in ways they would reasonably expect, or we can explain why any unexpected processing is justified.
  • We do not deceive or mislead people when we collect their personal data.
  • We are open and honest, and comply with the transparency obligations of the right to be informed.

Purpose limitation

  • We have clearly identified our purpose or purposes for processing.
  • We have documented those purposes.
  • We include details of our purposes in our privacy information for individuals.
  • We regularly review our processing and, where necessary, update our documentation and our privacy information for individuals.
  • If we plan to use personal data for a new purpose, we check that this is compatible with our original purpose or we get specific consent for the new purpose.

Data minimisation

  • We only collect personal data we actually need for our specified purposes.
  • We have sufficient personal data to properly fulfil those purposes.
  • We periodically review the data we hold, and delete anything we don’t need.


  • We ensure the accuracy of any personal data we create.
  • We have appropriate processes in place to check the accuracy of the data we collect, and we record the source of that data.
  • We have a process in place to identify when we need to keep the data updated to properly fulfil our purpose, and we update it as necessary.
  • If we need to keep a record of a mistake, we clearly identify it as a mistake.
  • Our records clearly identify any matters of opinion, and where appropriate whose opinion it is and any relevant changes to the underlying facts.
  • We comply with the individual’s right to rectification and carefully consider any challenges to the accuracy of the personal data.
  • As a matter of good practice, we keep a note of any challenges to the accuracy of the personal data.

Storage limitation

  • We know what personal data we hold and why we need it.
  • We carefully consider and can justify how long we keep personal data.
  • We have a policy with standard retention periods where possible, in line with documentation obligations.
  • We regularly review our information and erase or anonymise personal data when we no longer need it.
  • We have appropriate processes in place to comply with individuals’ requests for erasure under ‘the right to be forgotten’.
  • We clearly identify any personal data that we need to keep for public interest archiving, scientific or historical research, or statistical purposes.

Integrity and confidentiality (security)

  • We ensure that you have appropriate security measures in place to protect the personal data you hold.


  • We have appropriate measures and records in place to be able to demonstrate our compliance.