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1 Introduction

The Trustees and staff of the Great Torrington Town & Lands Charity and the Great Torrington Almshouse Charity are committed to protecting the privacy and security of personal information held by the Charities.


We may collect information from you depending on the nature of your relationship with us, for example as tenant/s, resident/s (beneficiaries), tradesman, Trustee/s, staff and other third parties.


The Trustee/s are the data controller under the General Data Protection Regulation (GDPR). This means that we are responsible for deciding how we collect, hold, use and protect your personal information and we are required to give you certain information about how and why we do this.


Office staff are the data processors responsible for processing the data under the General Data Protection Regulation (GDPR).


This Data Protection & Privacy Policy describes how we collect, hold, use and protect personal information that relates to you or any individual connected to you, both during and after the time when you are tenant/s and resident/s (beneficiaries), tradesman and other third parties, Trustee/s or staff.


2 Personal Information we may collect about you

Personal information means, broadly, information that identifies (or that could, with other information that we hold or are likely to hold) a living individual. This could include any information provided to us in relation to your or another’s actual past.


Most of this information will be supplied by you directly with your consent, although we may sometimes receive information from outside agencies.


We may hold any or all of the following personal information about you:

  • Personal details such as your name, gender, date of birth, email address, postal address, telephone and/or mobile number:

  • Family circumstances such as details about current relationship status and marital/relationship history, details of family and dependents, next of kin and emergency contact information:

  • Employment details such as length of service, employment and career history:

  • Financial details such as income, salary, assets and investments, bank account details to process payments.


We may also hold other information about you which is known as ‘special category’ data and requires a higher level of protection – for example, information relating to physical or mental health. Where we collect this type of information about you, we will take appropriate steps to get your consent to our collection and use of this information.


We collect your personal information when you, your employer, or another person contact us online, by phone, text, email or post. We also obtain your personal information where this is provided through any other correspondence that you, your employer or another person may have with us. We may also collect personal information about you from other third parties including tracing agencies and from public sources.


It is important that the personal information we hold about you is accurate and up-to-date. Please let us know if your personal information changes.


3 What we may use your personal information for

The Trustees may use your personal information for the following purposes:


  • To administer/provide a service that you request or to perform a contract to which you are party, for example, a tenancy agreement or beneficiary (resident of an Almshouse Flat):

  • To carry out our obligations arising from any agreement that we have with, or concerning you and to provide you with the information, benefits and services:

  • Complying with our record keeping duties:

  • To occasionally contact you (by email, text, phone, fax or mail) to notify you of changes to our services:

  • Complying with any present or future law, rule, regulation, guidance or directive, and complying with any industry or professional rules and regulations.


We use your personal information in the ways described above for one or more of the following reasons:


  • We need to comply with a legal obligation to which we are subject: and/or

  • It is necessary in our legitimate interests (or those of a third party) to do so, and your interests and fundamental rights do not override those interests. For example, our legitimate interests may include:

  • Providing any clarification or assistance in response to your communications:

  • Improving our service to you:

  • Complying with all laws as well as data requests from regulators, governments, courts and law enforcement authorities.


We will only use your personal information for the purposes for which we collected it, unless we reasonably need to use it for a different reason that is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will explain the legal basis which allows us to do so.


4 Keeping your personal information safe

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also have a Data Security Breach Policy & Procedure in place to deal with any suspected data security breach, should one arise.


5 Sharing your personal information

We may share or disclose your personal information to any of the following recipients:


  • Our service providers (contractors):

  • Other third parties as required by the law, for example, governments and law enforcement authorities, local and foreign courts, tribunals and arbitrators or other judicial committees:

  • If we share your personal information then we require the transferee to implement appropriate security measures to protect your personal information and to treat it in accordance with the law. Except where the transferee is a data controller in its own right, we only permit the transferee to process your personal information in accordance with our instructions.


6 How long do we retain your personal information?

We will hold your personal information (and any personal information collected in respect of any individual connected with you) on our systems for as long as necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting or reporting requirements. The period may depend on the type of data and the purpose for which it is held.


7 Your rights regarding the personal information you provide to us

You may request details of the personal information we hold about you under the General Data Protection Regulation, this is known as a data subject access request.


Please note that proof of identification may be required when making the request. The Charities will then have one month in which to respond.


You have the right, in accordance with the law:


  • The right to access personal data we hold on you

  • The right to correct and update the personal data we hold on you

  • The right to have your personal data erased/destroyed

  • The right to object to processing of your personal data or to restrict it to certain purposes only

  • The right to data portability

  • The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained

  • In relation to personal information processed on the grounds of the legitimate interest of a third party, to object to the processing of your personal information

  • Rights in relation to automated decision making and profiling

  • The right to lodge a formal complaint with the Information Officer’s office

If you would like to exercise any of the rights described above, please let us know – contact details are under item 12 How to contact us.


8 What if you do not provide us with your personal information?

If you do not provide us with the information we require, we may be unable to provide you with the services you have requested, or comply with our statutory or contractual obligations.


9 Changes to our data protection arrangements

From time to time, we may update this Data Protection & Privacy Policy arrangements described above.



  • CCTV system is installed in the Almshouse only. Clearly visible and readable notices are provided where CCTV is used:

  • CCTV images are only made available to third parties, police, other agencies/parties working to investigate crime, public safety and anti-social behaviour:

  • CCTV images are retained for as long as is necessary or, where applicable, until enforcement action is completed, after which they are over-written. However storage onsite is limited and is automatically over-written once the drive is full.


11 Making complaints to us

If you believe that the Charities have not handled your information correctly you have the right to make a complaint to the Steward – contact details are under item 12 How to contact us.


You can also contact the Information Commissioner’s Office (ICO):

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Tel: 0303 123 1113


This Data Protection & Privacy Policy does not provide exhaustive detail of all aspects of the Charities collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests should be sent to the Steward.


12 How to contact us

If you have any questions, comments or requests about this Data Protection & Privacy Policy, please contact:


The Steward, Great Torrington Town & Lands Charity, Great Torrington Almshouse Charity,

25 South Street, Torrington, North Devon, EX38 8AA

T: 01805 623517 Email: This email address is being protected from spambots. You need JavaScript enabled to view it.