Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data:

Our lawful bases for collecting or using personal information to provide and improve products and services for clientsare:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We use limited information about enquiries and past work, such as what people ask about and the outcome of previous projects, to understand what our clients need and to improve how we deliver our services. This helps us respond to enquiries more effectively and tailor our consultancy, training and facilitation work. This is necessary because reviewing patterns in enquiries and service history is the most practical way to identify what's working well and where we could improve. Without this, we couldn't develop our services in a way that reflects what clients actually need. We only use ordinary contact and service information for this purpose, not sensitive personal data, and we don't use it in any way that could negatively affect the people concerned. Improving our services in this way also benefits future clients directly, through a more effective, better tailored service. We've considered the impact on people's privacy and are satisfied the benefit outweighs any risk, since the information involved is limited and used only to understand and improve our own service delivery

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information to comply with legal requirements:

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Recognised legitimate interests - our pre-approved purpose for collecting or using personal information to comply with legal requirements:

  • We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We use contact details, correspondence, and relevant service or payment history to respond to and resolve queries, complaints or claims. This allows us to understand what's happened, address the issue properly, and put things right where needed. This is necessary because we can't investigate or resolve a query or complaint without looking at the relevant details, including any previous correspondence or records connected to it. Without this, we wouldn't be able to respond fairly or accurately. Dealing with queries and complaints properly benefits the person raising them, since it means their concern is taken seriously and addressed, and it benefits us by helping us improve how we work. We only use the information necessary to understand and resolve the specific issue raised, and we don't use it for any other purpose. We've considered the impact on the person's privacy and are satisfied this is a fair and proportionate use of their information, since it's limited to what's needed to sort out their query or complaint

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.