Privacy

Privacy notice for the Devon Vocational Profile (Identify Digital)

Devon County Council (DCC) has commissioned Identify Digital to create the Devon Vocational Profile. DCC is collecting and or processing your personal data as a Data Controller under United Kingdom General Data Protection Regulations (UK GDPR). Legislation and our ICO registration number is Z6475582. This privacy notice concerns the processing of personal data that takes place when you create a Profile on the Devon Vocational Portal. This is being managed by the Youth and Inclusion Team at DCC.

This notice explains what information we collect, why we collect it and how we keep it secure. It also explains your rights and our legal obligation. Should you wish to find out more about Devon County Council’s data protection policies please contact our Data Protection Officer.

We will notify you of any changes to this privacy notice

This privacy notice was last updated 15 September 2025. If we use your personal data for any new purposes, updates will be made to the policy information and changes communicated, where necessary in accordance with current data protection legislation. Any queries relating to this privacy notice please contact the Data Protection Officer.

What information are we processing?

The portal will collect and store the following data when you register on the Portal:

  • Name
  • Date of birth
  • Email address
  • Name and postcode of school attended.
  • Physical or mental support needs
  • Whether or not you have an Education, Health, and Care Plan (EHCP)
  • Job ideas and interests
  • Work experience and work history.
  • Skills and qualities

Purpose of collecting or processing your personal data

  1. The portal will collect information from you when your profile is initially created.
  2. DCC will assess the data monthly to be able to report on the use of the portal by using aggregated data to include age and which school’s users that have created profiles attend.
  3. DCC will use the data to monitor the portal to ensure the authenticity of accounts being created and to ensure that users are within the Devon boundary.

The legal basis for us collecting your personal data

Where we are collecting personal data about you for the purposes outlined in this privacy notice, we rely upon your consent.

As the profile will include information about your physical health and support needs and whether you have an EHCP the UK GDPR stipulates that we need to have second legal basis as this information is sensitive. Therefore, when we are processing this information, we rely upon your explicit consent:

Personal data that is collected for any of the purposes outlined in this notice is never used for direct marketing purposes and is not sold on to any other third parties.

Recipients or categories of recipients that we may share your personal data with

Once you have created your profile on the portal you may choose to share the information contained in it with your:

  • school or college staff
  • family members, carers or support workers
  • prospective employers

DCC will be sharing aggregated usage data for the Vocational Profile with schools.

If we feel that it is necessary to share your personal data with professionals to ensure you or someone you work with is safeguarded from harm, we rely upon the provisions of the Safeguarding Vulnerable Groups Act 2006 and Children Act 1989 & 2004.

Where it is necessary to share medical or social care information for these purposes, we rely upon article 9(2)(h) of the General Data Protection Regulation (information necessary for medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems).

We may also need to share some personal data about you, so that we can support third party organisations to discharge their regulatory requirements. This includes organisations such as:

  • the data protection regulator (the Information Commissioner’s Office)
  • the Care Quality Commission

We may also share information to enable us to comply with court orders and other legal obligations. If this is necessary, we will only share the minimum amount of personal data needed for this purpose.

International transfers

Identify Digital have confirmed that the Data is stored securely on UK servers hosted by GURU. It is therefore understood that the Data will not be subject to any international transfers

How long will we hold your personal data?

  • Your profile will be kept on the Portal infinitely.
  • You can choose to delete it at any time.
  • Any profiles that have not been used for two years will be deleted by DCC.

Your data protection rights

Under the UK GDPR Data Protection Legislation, you have the right to obtain a copy of their personal records held by us, this is called a Subject Access Request (SAR).

Details of how to make a request can be found here.

Further details on your rights under data protection legislation and how to exercise them, are available here.

Complaints

If you have any comments, queries or complaints about this privacy notice or the processing of your personal data please contact our Data Protection Officer.

Alternatively, if you are not happy with the way that DCC is handling your personal data, you are entitled to appeal to the Information Commissioners Office (ICO). The Information Commissioners Office enforces and oversees the Data Protection Regulations.
Contact details are below:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Email: casework@ico.org.uk

Automated decisions

Profile information will not be used for automated decisions.