Privacy Notice

    Privacy Notice – End Users & Website

    The Data Controller connected with this Privacy Notice is Full Fibre Limited (Full Fibre), a company incorporated and registered in England & Wales and registered with the Information Commissioner’s Office (ICO).

    Registered Office: 2 Pynes Hill Court, Pynes Hill, Exeter, Devon, EX2 5AZ
    Telephone: 0333 121 0505

    1. Purpose

    Your personal data will be collected and retained for the following purposes:

    1.1. Network Safety & Continuity – As the network provider for your fibre broadband service, Full Fibre will retain your data for the purpose of maintaining the network and aiding continuity of service for you, the End User.

    1.2. Service Availability – Your data will be processed for the purpose of keeping you informed about our network availability in your area and which of our partners (internet service providers – ISPs) can provide you with a full fibre broadband connection.

    2. Lawful Basis

    2.1. The retention and processing of your data for the purpose outlined in paragraph 1.1 are under the Lawful Basis of Legitimate Interest. Full Fibre has undertaken a legitimate interests assessment (LIA) and concluded that the benefits to the data subject on balance outweigh the potential risks to the rights and freedoms of the data subject.

    2.2. The collection of your data for the purpose outlined in paragraph 1.2 is under the Lawful Basis of Consent. This is because you have asked us to keep you updated, by electronic mail, or telephone, regarding our full fibre broadband network. For this under the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), we require your consent.

    3. Information Collected

    The personal data we may collect and process about you in connection with these purposes is:

    3.1. Property Address (including UPRN)

    3.2. Contact Details

    3.3. IP Address

    4. Retention

    4.1. Under the Lawful Basis referred to in paragraph 2.1, your data will be retained for as long as Full Fibre’s network infrastructure is on your property and for a further 36 months from the date all infrastructure is removed from the property.

    4.2. Under the Lawful Basis referred to in paragraph 2.2, your data will be retained for 36 months from receipt; this is so we may keep you informed as our network is built and also, so that we, or our partners (ISPs) may contact you when any broadband contract you might currently have in place is due for renewal.

    If, at an earlier point, you would like us to stop communicating with you, you can ask us to cease processing your data (see paragraph 7 below)

    5. Destruction

    At the end of the relevant retention period outlined above, your data will be destroyed using an approved method, unless prohibited by court order.

    6. Data Sharing

    6.1. In order to maintain our records and operate our business, we may need to share personal data with the following processors:

    6.2. In order to try and ensure continuity of service for end users in the event of the failure of an internet service provider (ISP), we may share your details with other ISP partners, whom we know provide services in your area.

    6.3. In order to help keep you informed about the full fibre broadband services available to you over our network, we may share your data with a small number of ISP partners, at that point they should contact you and share their own privacy notice with you, so you have transparency regarding how they intend to use your data to help you.

    6.4. All of Full Fibre’s data processors process your data under our direction and are expressly prevented from using your data for any other purpose.

    6.5. Subject as provided in paragraph 6.6, where data is shared outside of the UK, the other parties are located in the European Economic Area and covered by the UK’s adequacy regulations.

    6.6. Where data is transferred outside of the UK into a jurisdiction where there is no current adequacy decision, then data is shared using the UK’s Standard Contractual Clauses.

    7. Rights of the Data Subject

    7.1. Under the General Data Protection Regulation as incorporated into UK law, (UK GDPR) and the Data Protection Act 2018, you, the Data Subject, have certain rights regarding the control and processing of your personal data.  Details regarding your rights can be found on the ICO’s website.

    7.2 Should you wish to contact Full Fibre in order to exercise any of these rights, please email our Data Protection Manager using the following email address:

    8. Security

    8.1. Recognising the importance of information security to our business and clientele, Full Fibre has put in place appropriate technical and organisational measures to secure the personal data it processes. These include (but are not limited to) data segmentation and electronic data encryption, as well as the monitoring of our information systems.

    8.2. Personal data held on paper is secured in locked cabinets with access limited to appropriately authorised personnel.

    8.3. Data Subjects should be aware that not all electronic communications are secure. We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with government advice. However, if your email service does not support TLS, you should note that any emails we send or receive may not be protected in transit.

    8.4. We will monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send complies with any applicable legal requirements.

    9. Data Protection Concerns

    Should you have any concerns regarding the way an organisation such as Full Fibre is processing your personal data, the ICO recommends that, in the first instance, you contact the organisation concerned. If the organisation does not address those concerns in an appropriate manner, you then have the option to escalate the issue to the ICO. If you wish to contact us because you have concerns about our use of your personal data, please contact our Data Protection Manager using the details provided in paragraph 7.2.

    10. Updates

    This Privacy Notice is kept under review and is updated as appropriate.  It was last updated on 04 April 2024.