If you are an individual:
This privacy notice applies to information held about you. It explains what information we collect about you, how well use that information, who well share it with, the circumstances when well share it, and what steps well take to make sure it stays private and secure.
Wherever we say you or your this means you as our customer.
If you are a business:
This privacy notice applies to information held about you and the individuals connected to your business by us as data controllers, as described below. It explains what information we collect about you and individuals who are connected to your business, how well use that information, who well share it with, the circumstances when well share it, and what steps well take to make sure it stays private and secure.
Full name of legal entity: Sleaford Taxi Company Limited
Email address: firstname.lastname@example.org
Postal address: Pride Parkway, East Road, Sleaford, Lincolnshire, NG34 8GL
Telephone number: 01529 303333
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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).
· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
· Contact Data includes billing address, delivery address, email address and telephone numbers.
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
· CCTV data includes images collected of you either at our premises or in the vicinity of our vehicles.
· Data that you have provided to us.
We do not knowingly collect the following Special Categories of Personal Data about you: details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
It is possible that we collect details about your race and ethnicity when processing CCTV images.
In relation to processing CCTV, this is necessary for reasons of substantial public interest in order to:
prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
assist in the personal safety of staff, visitors and other members of the public and to act as a deterrent against crime;
to support law enforcement bodies in the prevention, detection and prosecution of crime; and
assist in the defence of any civil litigation.
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.
· Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
· CCTV operations. We may record and store information about you from CCTV at any of our premises or attached to our vehicles.
· Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, other similar technologies.
· Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
· Identity and Contact Data from data brokers or aggregators, and travel brokers and/or agents .
· Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
· Where we need to perform the contract we are about to enter into or have entered into with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order and carry out your instructions including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Carry out travel arrangements such as picking up and dropping off
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Investigating and resolving complaints
(d) Recovering money which you owe
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business including:
(a) troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
(b) undertaking risk management
(c) protecting our legal rights and complying with our legal obligations
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
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.
· Subcontractors who we might engage to carry out some or all of the services we provide to you.
· Service providers who provide IT and system administration services.
· Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
· HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
We require all third parties 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.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
Some data we are required to maintain for a minimum period of time, for example:
· CCTV video recordings on our premises or on our vehicles for a couple of months, or longer where it is necessary for the establishment, exercise or defence or legal claims;
· Details of individuals, sales ledgers and invoices (comprising names, addresses, telephone numbers, email addresses, payment details) for private transport clients for the period when the client is using our services, then for a period of 7 years for tax or potential litigation purposes (which are legitimate interests of our business), or longer where it is necessary for the establishment, exercise or defence or legal claims.
· Details of individuals, quotations, booking history, sales ledgers and invoices for our other clients (on two different management systems) for the period when the client is using our services, then for a period of 7 years for tax or potential litigation purposes (which are legitimate interests of our business), or longer where it is necessary for the establishment, exercise or defence or legal claims. We may also continue to obtain and record the clients consent to us processing their data throughout the period in which we provide services for the client.
· Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.