Introducing the new data privacy laws
2018 sees one of the biggest changes to UK data privacy laws as the General Data Protection Regulation (GDPR) was introduced across Europe on 25 May. The General Data Protection Regulation (GDPR) deals with the huge increase in customer data that is now generated from social media and online activity. Whether that’s sharing a tweet or shopping online, the new laws provide individuals with more transparency and stronger rights regarding personal data. At HGVT Training Services (hgvt.co.uk) we have always taken data privacy very seriously and we believe the introduction of the GDPR is positive – giving you more control over how organisations use and manage your data.
What does this mean for you?
What does this mean for Driver Academy Group (DAG)?
GDPR doesn’t change the ways we use your personal information. We’ll continue to value the data you share with us, treating it with respect and keeping it secure always. We’ll continue to contact you in an appropriate way about services that may benefit you, unless you’ve asked us not to. So, whilst the laws might have changed, our commitment to looking after your data stays the same.
Our Privacy Notice
We want to make it easier for you to find out how we collect, use and protect your information, so we’ve updated our Privacy Notices below.
What information we collect
We’ll only collect your information in line with relevant regulations and law. We may collect it from a range of sources and it may relate to any of our products or services you apply for, currently hold or have held in the past. We may also collect information about you when you interact with us, e.g. visit our websites or mobile channels, call us or visit one of our branches, or ask about any of our products and services.
Some of it will come directly from you, e.g. when you provide your driving licence number. It can also come from government departments such as DVLA or DVSA or other sources you’ve asked us to obtain information from. We might also get some of it from publicly available sources.
The information we collect may include:
Personal details, e.g. name, previous names, gender
Contact details, e.g. address, email address, landline and mobile numbers;
Information concerning your identity e.g. photo ID, passport information, National Insurance number, driving licence details
Information relating to your medical records, with your agreement.
How we’ll use your information
We’ll only use your information where we have your consent or we have another lawful reason for using it. These reasons include where we:
Need to pursue our legitimate interests;
Need to process the information to carry out an agreement we have with you;
Need to process the information to comply with a legal obligation;
Believe the use of your information as described is in the public interest, e.g. for the purpose of preventing or detecting crime;
Need to establish, exercise or defend our legal rights;
Need to use your information for insurance purposes.
The reasons we use your information include to:
Deliver our products and services;
Carry out your instructions, e.g. to book training and tests
Carry out checks in relation to your creditworthiness;
Manage our relationship with you, including (unless you tell us otherwise) telling you about products and services we think may be relevant for you;
Understand how you use your accounts and services;
Support our training operations;
Prevent or detect crime including fraud
Ensure security and business continuity
Provide Online Training, mobile apps and other online product platforms;
Improve our products and services;
Analyse data to better understand your circumstances and preferences so we can make sure we can provide you with the best advice and offer you a tailored service.
Protect our legal rights and comply with our legal obligations;
Correspond with solicitors, courts, financial ombudsman, lenders, recruitment services and government agencies.
Undertake system or product development and planning.
Recover money which you owe
Tracking or recording what you say or do
We may record details of your interactions with us. We may record and keep track of conversations you have with us including phone calls, face-to-face meetings, letters, emails, live chats, video chats and any other kinds of communication. We may use these recordings to check your instructions to us, assess, analyse and improve our service, train our people, manage risk or to prevent and detect fraud and other crimes. We may also capture additional information about these interactions, e.g. telephone numbers that you call us from and information about the devices or software that you use. We use closed circuit television (CCTV) in and around our sites and these may collect photos or videos of you, or record your voice.
Compliance with laws and regulatory compliance obligations
We’ll use your information to meet our compliance obligations, to comply with other laws and regulations and to share with regulators and other authorities we are subject to. This may include using it to help detect or prevent crime. We’ll only do this on the basis that it’s needed to comply with a legal obligation, it’s in our legitimate interests and that of others, or to prevent or detect unlawful acts.
Marketing and market research
We may use your information to provide you with details about HGVT Training Services products and services, and also products and services from our partners and other relevant third parties. We may send you marketing messages by post, email, telephone, text or secure messages. You can change your mind on how you receive marketing messages or choose to stop receiving them at any time. To make that change, please contact us in the usual way.
If you ask us not to send you marketing, it may take us a short period of time to update our systems and records to reflect your request, during which time you may continue to receive marketing messages. Even if you tell us not to send you marketing messages, we’ll continue to use your contact details to provide you with important information, such as changes to your terms and conditions or if we need to tell you something about your training.
We may use your information for surveys to improve our products and services and to obtain feedback from you on your course. Surveying agencies acting on our behalf may get in touch with you by post, telephone, email or other methods of communication to invite you to take part in research. We won’t invite you to take part in research using a communication method if you’ve asked us not to get in touch that way. Any responses that you provide whilst participating in market research will be reported back to us anonymously unless you give us permission for your details to be shared.
Who we might share your information with
We may share your information with others where lawful to do so including where we or they:
Need to in order to provide you with products or services you’ve requested, e.g. fulfilling your training & recruitment. We might also share your information with Manpower for recruitment purposes, and Logistics UK for further skills training.
Have a public or legal duty to do so, e.g. to assist with detecting and preventing fraud.
Need to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;
Have a legitimate business reason for doing so, e.g. to manage risk, verify your identity, enable another company to provide you with services you’ve requested, or assess your suitability for products and services. (e.g. to provide you recruitment services)
Have asked you for your permission to share it, and you’ve agreed.
We may share your information for these purposes with others including:
Other HGV Training Services Ltd Group companies and any sub-contractors, agents or service providers who work for us or provide services to us or other HGV Training Services Ltd Group companies (including their employees, sub-contractors, service providers, directors and officers);
Law enforcement, government, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities;
other parties involved in any disputes, including disputed transactions;
Anyone who provides instructions or operates any of your accounts on your behalf, e.g. Power of Attorney, solicitors, intermediaries, etc;
Anybody else that we’ve been instructed to share your information with by either you, a joint account holder.
Our card processing supplier(s) to carry out credit, fraud and risk checks.
Transferring your information overseas
Your information is stored in locations within the European Economic Area (EEA). We do not transfer your data overseas.
You have a number of rights in relation to the information that we hold about you. These rights include:
The right to access the information we hold about you and to obtain information about how we process it;
In some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so;
In some circumstances, the right to receive certain information you have provided to us in an electronic format and/or request that we transmit it to a third party;
The right to request that we rectify your information if it’s inaccurate or incomplete;
In some circumstances, the right to request that we erase your information. We may continue to retain your information if we’re entitled or required to retain it by other laws.
The right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing your information and/or to refuse that request.
You can exercise your rights by contacting us at firstname.lastname@example.org
You also have a right to complain to the UK Information Commissioner’s Office by visiting ico.org.uk