We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and the Data Protection Act 2018 and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
The information we collect may be collected via telephone; email; online live chat; our social media channels; in person from you; via our website or indirectly such as your browsing activity whilst on our website (see ‘Cookies’ below).
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Fleet Operations Limited|
|Our Data Protection Team||The data protection team at Fleet Operations Limited that support the business with data protection matters|
|Personal information||Any information relating to an identified or identifiable individual|
|Special category personal information||Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, sex life or sexual orientation
What types of personal information do we collect about you:
We may collect and use the following personal information about you:
- name and title, address, e-mail address, employment status, driving licence, telephone number and date of birth.
- your banking and financial information (including income, expenditure and previous credit history).
- if you are disabled, information about your disability or mobility requirements.
- demographic information such as postcode, preferences and interests.
- your billing information, transaction and payment card information.
- information to enable us to undertake credit or other financial checks on you.
- information about your lifestyle and home ownership.
- if you contact us online, we may keep a record of your email correspondence.
- details of any feedback you give us by phone, email, post or via social media.
- if you contact us by telephone, we may record and/or monitor telephone conversations for training and customer services reasons.
- if you enter a competition or complete a survey we will collect your name and relevant contact information.
- if you report a problem with our services we will collect your name and relevant contact information.
- if you make a complaint in connection with our services we will collect your name and relevant contact information.
Personal information we collect and/or observe about you
Based on how you have used our services in the past and your activity on our website and by telephone, we collect the following personal information from you:
- details of the services we have provided to you in the past.
- details of your visits to our website, and of the resources that you access. We may use visitor information to measure the entry and exit points of visitors to the website and respective numbers of visitors to various pages and sections of the website and details of searches performed. We may also use this information in the future to measure the usage of advertising banners, and other “click throughs” to and from the website. We have security processes in place to ensure that your personal information is held on a central database and is not accessible by any unauthorised persons. However, persons such as IT systems suppliers may need to have access to the system from time to time.
- details of the website(s) you visited before you use a link to our website, pages visited in our website, and time spent on each. Information about your computer, or mobile device. This is statistical data about our users’ browsing actions.
Personal information we collect and use for legal, compliance, regulatory and crime detection and prevention purposes
We process your personal information so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory order.
We also process your personal information for crime prevention and detection purposes.
How your personal information is collected
We collect most of this personal information directly from you —in person, by telephone, or email and/or via our website. However, we may also collect information:
- from another person acting on your behalf, such as your employer
- from our promotion partners
- from social media
- directly from a third party, e.g.:
- credit reference agencies;
- customer due diligence providers.
- from a third party with your consent, e.g. your bank or building society
- via our IT systems, e.g.
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email systems
- systems relating to physical access, such as reception logs, door entry systems etc.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide services to you||For the performance of our contract with you or to take steps at your request before entering into a contract. For example, vehicle management, accident management, fleet administration, roadside assistance, maintenance management, risk management and vehicle procurement.|
|To prevent and detect fraud against you||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you|
|Conducting checks to identify our customers, customer’s employees and suppliers and verify their identity
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator
|To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Recording calls made to our offices so we can review how we handle calls and make any necessary improvements||For our legitimate interests|
|Provide you with special assistance in relation to special categories of personal information||For the performance of our contract with you or to take steps at your request before entering into a contract; to comply with our legal and regulatory obligations; with your consent|
|Improve our products and services||For our legitimate interests|
|Ensuring business policies are adhered to, for example: policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so that we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Updating customer records||For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, for example: making sure that we can keep in touch with our customers about existing orders and new products
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, for example: to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services [and those of selected third parties] to:
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party; with your consent, i.e. to promote our business to existing and former customers|
|For debt collection and credit vetting to project our business against financial loss||For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services|
|To seek to protect and promote your health and safety and that of our other customers, staff and third parties||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party
|To seek to detect, investigate, prevent and report crime and anti-social behaviour||For our legitimate interests or those of a third party, i.e. to detect and prevent crime and anti-social behaviour|
|For resolving complaints dealing with disputes and legal proceedings||To comply with our legal and regulatory obligations|
If you have made an enquiry on our website or by telephone, your personal information may be used by us in the ways the law allows, to contact you by post or electronic means (email or text message) about our services, including exclusive offers, promotions or new services. We will only do this if you did not opt out of such marketing at the point where we collect your contact details.
If you have not made an enquiry or purchase, we will only send you information and offers by email or text message if you sign up (opt in) to receive such marketing.
We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.
What you need to do if you don’t want to receive our promotional communications
You have the right to opt out of receiving promotional communications at any time by:
- contacting us via email at firstname.lastname@example.org or writing to us at Fleet Operations Limited, Fleet House, Maries Way, Silverdale Business Park, Newcastle Under Lyme, Staffordshire, ST5 6PA.
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts where the option is provided.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
- our suppliers, sub-contractors and business partners who help us to provide our services to you, for example to process accident management claims or for vehicle delivery/collection;
- third parties we use to help deliver our services to you, e.g. payment service providers.
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- government bodies and regulatory authorities, the Financial Conduct Authority, the Police, the Driver and Vehicle Licensing Agency and other crime prevention and detection agencies.
- The courts and other dispute resolution arbitrators and mediators and other parties to legal proceedings
- third parties approved by you, e.g. social media sites you choose to link your account to or third-party payment providers;
- credit reference agencies;
- our insurers and brokers;
- our bank(s);
- our card payment facilitators, that help us process customer payments and assist us in detecting and preventing fraudulent payments or bookings;
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We may also share personal information with external auditors, e.g. in relation to the audit of our accounts.
We may disclose and exchange information with law enforcement agencies, regulatory bodies and external law firms (acting on your instructions) to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
Where your personal information is held
Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available by clicking here.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), for example:
- service providers located outside the EEA;
- if you are based outside the EEA.
These transfers are subject to special rules under European and UK data protection law.
These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
If you would like further information, please contact our data protection team (see ‘How to contact us’ below).
Your rights in relation to any personal information we hold about you
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access).
We may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. That may include information about your previous order(s) or other interactions. If someone is acting on your behalf, they will need to provide written and signed confirmation from you that you have given your authority to that person/company for them to make the request. We may not provide you with a copy of your personal information if it includes the personal information of other individuals or we have another lawful reason to withhold that information.
|Rectification||The right to require us to correct any mistakes in your personal information.|
|Withdrawing your consent||Where we rely on your consent as the legal basis for processing your personal information, as set out in section above titled ‘How and why we use your personal information’, you may withdraw your consent at any time. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, please see the section titled “What you need to do if you don’t want to receive our promotional communications’ for further details. If you would like to withdraw your consent to us processing any special categories of personal information, please contact our data privacy manager. Please note if you ask us to stop processing this information, it may mean we won’t be able to provide all or parts of the services you have requested. The withdrawal of consent may also affect an individual’s ability to fulfil their contractual or non-contractual obligation to the third party (e.g. their employer), and so we would recommend that the individual consult with the third party in the first instance.
If we have to cancel an order or other purchase as a result, you may incur a cancellation charge.
If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
|To be forgotten||The right to require us to delete your personal information.
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the personal information.
We may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
|Data portability||Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out in section titled ‘How and why we use your personal information’, you have the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that personal information to a third party.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if it contains the personal information of other individuals or we have another lawful reason to withhold that information.
|To object||The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to our data protection team see below: ‘How to contact us’
- let us have enough information to identify you (e.g. your full name and address)
- let us have proof of your identity and address; and
- let us know what right you want to exercise and the information to which your request relates.
Cookies and similar technologies
You can set your browser not to accept cookies however some of our website features may not function as a result.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Links to other websites
How to complain
We hope that our Data Privacy Manager can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 11th October 2018 and last updated on 11th October 2018.
We may change this privacy notice from time to time—when we do we will inform you via our website.
How to contact us
Our contact details are shown below:
Data Protection Team
Fleet Operations Limited
Fleet House, Maries Way
Silverdale Business Park
Telephone: 0844 567 8000