1. Who we are
Steering Developments Ltd (“we”, “us”, “our”) adapts and converts vehicles for disabled drivers and passengers, and supplies related mobility products. We are the controller of the personal information described in this policy, which means we decide how and why it is used.
This policy explains what personal information we collect when you visit our website, contact us, or buy or use our products and services, and how we protect it. It is written to comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (as amended by the Data (Use and Access) Act 2025) and the Privacy and Electronic Communications Regulations 2003 (PECR).
Our details
- Registered name: Steering Developments Limited
- Company number: 02646099, registered in England and Wales
- Registered office: Unit 5 Eastman Way, Hemel Hempstead, Hertfordshire, HP2 7HF
- ICO registration number: ZA671671
- Email: info@steeringdevelopments.co.uk
- Telephone: 01442 212918
If you have any questions about this policy or how we handle your information, please contact our data protection lead, Stuart Parker, using the details above.
2. The information we collect
We collect only what we need to answer your enquiry, carry out an assessment and supply, fit and support your vehicle or equipment.
| Type of information | Examples |
|---|---|
| Identity and contact | Name, address, email, telephone number, and details of anyone acting on your behalf (such as a relative, carer or occupational therapist) |
| Vehicle | Registration, make, model, VIN, mileage, and photographs or measurements of the vehicle |
| Scheme and funding | Motability Scheme reference, lease or agreement details, grant or charity funding references |
| Driving | Driving licence details, where needed to confirm adaptations are suitable or for handover |
| Payment | Invoices, payment records and billing address (card payments are processed by our payment provider; we do not store full card numbers) |
| Communications | Emails, call notes, enquiry forms and feedback |
| Website and technical | IP address, browser type, pages visited and cookie data (see section 6) |
Health and disability information. To recommend and fit the right adaptation, we may need information about your mobility, physical measurements, wheelchair or scooter, and any relevant medical condition or assessment report. This is special category data under UK GDPR and we give it extra protection. We only collect it when it is necessary for your adaptation, and we limit access to the staff who need it.
Where it comes from. Mostly from you directly. We may also receive it from Motability Operations, your dealership, a driving or mobility assessment centre, your occupational therapist, or someone you have asked to act for you.
3. How we use your information and our lawful basis
UK GDPR requires us to have a lawful basis for each use of your personal information.
| What we do | Lawful basis |
|---|---|
| Respond to enquiries and provide quotes | Steps before entering a contract, or our legitimate interests in answering people who contact us |
| Assess, design, fit, test and hand over adaptations | Performance of our contract with you (or with Motability or your dealer) |
| Servicing, warranty work, safety recalls and aftercare | Contract; legal obligation; legitimate interests in keeping adapted vehicles safe |
| Invoicing, payments and keeping accounts | Contract; legal obligation (tax and company law) |
| Meeting Motability Scheme and industry quality requirements | Legitimate interests; contract |
| Running and securing our website | Legitimate interests |
| Sending news and offers | Your consent, or legitimate interests for existing customers (see section 6) |
| Handling complaints and legal claims | Legal obligation; legitimate interests |
Health and disability information is used only on the basis of your explicit consent, or where it is needed to establish, exercise or defend legal claims. You can withdraw consent at any time, but we may then be unable to complete an adaptation safely.
We do not use your information for automated decision-making that has legal or similarly significant effects on you, and we never sell your personal information.
4. Who we share your information with
We share information only where needed for the purposes above, and only as much as is necessary:
- Motability Operations and Motability-approved dealers, where your adaptation is supplied through the Motability Scheme
- Vehicle and equipment manufacturers and suppliers, for parts, warranty claims and product safety recalls
- Mobility and driving assessment centres, occupational therapists and funders (such as charities or grant bodies), where you have asked us to work with them
- The DVLA, DVSA, insurers and vehicle approval bodies, where the law or a vehicle modification requires it
- Service providers who act on our instructions, such as IT and email providers, website hosting, accounting software, payment processors and couriers
- Our professional advisers, such as accountants, auditors, solicitors and insurers
- Police, courts or regulators, where we are legally required to
Our service providers may only use your information to provide services to us and must keep it secure under a written contract. If our business is sold or restructured, your information may transfer to the new owner, who must continue to protect it.
5. How long we keep it, and how we protect it
We keep personal information only as long as we need it, then delete or anonymise it securely.
| Record | How long we keep it |
|---|---|
| Enquiries that do not go ahead | 2 years from last contact |
| Customer, job and invoice records | 6 years after the end of the financial year they relate to (tax and company law) |
| Adaptation, fitting and safety records for a vehicle | 10 years after fitting, because of product safety and liability law |
| Health and assessment information | Only as long as needed for the adaptation and its aftercare, then no longer than the job record above |
| Marketing preferences | Until you unsubscribe, then a suppression record so we don’t contact you again |
| Website analytics | 2 years |
Security. We use appropriate technical and organisational measures, including access controls, password-protected systems, secure storage of paper records and staff training. Only staff who need your information can see it.
International transfers. We mainly store information in the UK. Some of our IT providers may store data outside the UK. Where they do, we make sure the transfer is lawful — for example, to a country the UK recognises as providing adequate protection, or under the UK International Data Transfer Agreement or Addendum.
6. Cookies and marketing
Cookies. Cookies are small files placed on your device when you visit our website. We use:
- Strictly necessary cookies — needed for the site to work, such as remembering your cookie choices. These don’t need your consent.
- Analytics cookies — such as Google Analytics, to understand how visitors use the site so we can improve it.
- Third-party content — such as embedded videos or maps, which may set their own cookies.
You can change your choices through your browser settings.
Marketing. We will only send you marketing emails or texts if you have agreed, or if you are an existing customer and the messages are about similar products and services. Every message includes an easy way to unsubscribe, and you can also contact us to opt out at any time. We do not pass your details to other companies for their marketing.
7. Your rights and how to complain
Under UK data protection law you have the right to:
- access the personal information we hold about you
- have inaccurate information corrected
- have information erased in certain circumstances
- restrict how we use it in certain circumstances
- object to our use of it where we rely on legitimate interests, and to direct marketing at any time
- data portability — receive information you gave us in a commonly used electronic format
- withdraw consent at any time, where we rely on consent
To use any of these rights, contact us by email, phone or post. You don’t have to pay a fee. We will respond within one month, and may ask for proof of identity first.
Complaining to us. If you are unhappy with how we have handled your personal information, contact us at info@steeringdevelopments.co.uk, by phone on 01442 212918, or by post to the address in section 1. We will acknowledge your complaint within 7 days and aim to resolve it without undue delay, keeping you informed of progress.
Complaining to the regulator. If you are not satisfied with our response, you can complain to the Information Commissioner’s Office (ICO) at ico.org.uk/make-a-complaint.
8. Changes to this policy
We may update this policy from time to time. The latest version will always be on this page, with the date it was last updated.