Smart Fleet Solutions is committed to protecting your personal data. We collect personal information about people who come into contact with us for various reasons.
It also explains your privacy rights and how the law protects you including how we comply with the General Data Protection Regulation (“GDPR”) and other related legislation which relates to the use of personal data.
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
In this document, “we”, “our”, or “us” refer to Smart Fleet Solutions.
DPO Contact: DataProtectionOfficer@SmartFleetSolutions.com
Alternative Contact: HR@SmartFleet.co.uk
Our registered office is at:
You have the right to make a complaint at any time. As recommended by the ICO, please contact us to try to resolve the issue directly. Should we not be able to resolve your issues directly, then you should log your complaint with the ICO: https://ico.org.uk/
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:
We will only use your personal data when the law allows us to. The information below explains the purposes for which we use different categories of personal data and the legal basis or bases which we believe applies to those uses. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
We collect personal data in a number of ways, for example, via e-mail, telephone, if you write to us, or through any face to face interactions. You might also provide information to us via social media or text message.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
When you create an account with us, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e- mail to which you would reasonably expect us to reply.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at firstname.lastname@example.org. However, if you do so, you may not be able to use our website or our services further.
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
For example, we may process your data on this basis for the purposes of:
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
We may process your identity and contact data, technical data and profile data, for the purposes of administering and operating our IT systems etc. This includes troubleshooting, data analysis, testing, system maintenance and support. This helps us to continually improve our systems and the services we can offer. We process your data in this way on the basis that this is necessary for our legitimate interests in managing, administering and improving our services.
We may also process your identity and contact data if you receive any of our service provisions either directly or via a third party where we provide services to the organisation which you represent or are a customer thereof. We process your data in this way for example to maintain your details on our records for future communications, and on the basis that it is necessary for our legitimate interests to ensure that the services we provide are properly managed. This will include using information for the proper administration of our business for example in ensuring that we receive payment or for providing services such as vehicle delivery to your address.
If you send us an enquiry, we may process your identity and contact data to respond to that enquiry. We process your data in these ways on the basis that it is necessary for our legitimate interests in the operation of our business in order to respond to and deal with new enquiries.
We might in some cases, collect special categories of data from you. We may need to collect this type of data from you to understand your vehicle needs. We may also collect this type of data where you require reasonable adjustments to be in place. More information about this is provided above where we outline the purposes for which personal data is used.
We only process special categories of data in this way on the basis that you have given your express consent to us to process it.
From time to time we might also appoint external third parties to help us with our services such as transport delivery services or remote repair.
Those third parties might also include for example our suppliers. We therefore, may make your data available to those entities if reasonable to do so as a part of our usual business practices. We will only provide the data that they need to perform their services.
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are set out in our Data Retention Policy.
To find out more, please contact us at DataProtectionOfficer@SmartFleetSolutions.com
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We take the issue of data privacy seriously. We have in place appropriate security measures in place which are aimed at helping to keep your data secure and we take reasonable steps to protect the confidentiality of the personal information supplied by you. Additionally, we limit
access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We utilise a combination of hardware and software adhering to IT security best practice in order to keep our electronic records secure, although this cannot be guaranteed. We have procedures in place to help keep our paper records secure. We also only disclose your details to those individuals within our organisation who have a need to know them for proper performance of their duties. Please note however, that the transmission of information via the internet can never be guaranteed as entirely secure and therefore any transmission of data is at your own risk.
We require our service providers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Those rights are listed below. Please contact us if you would like to exercise any of them. You have the right to:
You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security
measure to ensure personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests in which case, we will keep you updated.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Requests by your web browser to our servers for web pages and other content on our website are recorded. We may record information such as your geographical location, your Internet service provider and your IP address. We may also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed into our website.
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.
|Policy Issue Date||September 2020|
|Policy Owner Position||DPO|
|Policy Owner Name||Michael Nolan|
|Latest Policy Version||Version 2|
|Next Review Date||September 2021|