2. The types of personal data we collect and use
Whether or not you become a Pupil, we’ll use your personal data for the reasons set out below and if you become a Pupil we’ll use it to manage the service you’ve asked us for. We’ll collect most of this directly during your initial booking process. The sources of personal data collected indirectly are mentioned in this Policy. The personal data we use may include:
– Full name and personal details including contact information (e.g. home address, other relevant addresses, email addresses, home and mobile telephone numbers).
– Date of birth and/or age and driving licence details (e.g. to make sure that you’re eligible to take driving lessons and to apply for a driving test).
– Other data relevant to enable us to provide services to you (e.g. details of your availability and preferences for services).
– Records of products and services you’ve obtained and how and when you use them and the relevant technology used to access or manage them, (e.g. mobile phone data to record whether texts we send you have been received).
3. Providing your personal data
We collect personal data directly from you or your personal representative, such as your parent or partner making a booking on your behalf. If you do not provide us with the information we need, we may not be able to provide you with services.
We’ll tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data so we can process your enquiry (unless you’re a customer and we already hold your details).
4. Monitoring of communications
Subject to applicable Laws, we’ll monitor and record your calls, emails, text messages, social media messages and other communications in relation to your dealings with us. We’ll do this for regulatory compliance, self-regulatory practices, crime preventions and detections, to protect the security of our communications systems and procedures, to check for profane content, for quality control and staff training, and when we need to see a record of what’s been said and done. We may also monitor activities on your account where necessary for these reasons and this is justified by our legitimate interests or our legal obligations.
5. Using your personal data: the legal basis and purposes
We’ll process your personal data:
i. As necessary to perform our contract with you for the relevant service:
(a) To decide whether we can offer service to you.
(b) To take steps to introduce an appropriate driving instructor to you.
(c) To manage and perform that contract and your account with us.
(d) To update our records; and
(e) To contact you about your account.
ii. As necessary for our own legitimate interests or those of other persons and organisations, e.g.:
(a) For good govedrnance, accounting and managing and auditing our business operations.
(b) To monitor emails, calls, other communications, and activities on your account.
(c) For market research, analysis and developing systems, and
(d) To send you marketing and other relevant communications as we believe aids good business practice.
iii. As necessary to comply with a legal obligation, e.g.:
(a) When you exercise your rights under data protection law and make requests.
(b) For compliance with legal and regulatory requirements and related disclosures.
(c) For establishment and defence of legal rights.
(d) For activities relating to the prevention, detection and investigation of crime.
(e) To verify your identity, and
(f) To monitor emails, calls, other communications, and activities on your account.
iv. Based on your consent, e.g.:
(a) When you request us to disclose your personal data to other people or organisations such as a person making or dealing with a booking on your behalf, or otherwise agree to disclosures.
(b) When we process any special cetegories of personal data about you at your request (e.g. your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation), and
(c) To send you marketing communications where we’ve asked you for your consent to do so.
You’re free to change your mind and withdraw your consent. The consent might be that we can’t do certain things for you.
6. Sharing of your personal data
Subject to applicable data protection law, we may share your personal data with:
– Other associated companies in which we have a shareholding.
– Subcontractors and other persons, (such as self employed driving instructors), who help us provide our services.
– Companies and other persons providing services to us.
– Our legal and other professional advisors, including our auditors.
– Government bodies and agencies in the UK and overseas (e.g. HMRC).
– Courts, to comply with legal requirements and for the administration of justice.
– In an emergency or to otherwise protect your vital interests.
– To protect the security or integrity of our business operations.
– To other parties connected with your account (e.g. parents or partners who may make bookings or cancel bookings on your behalf).
– When we restructure or sell our business or its assets or have a merger or re-organisation.
– Market research organisations who help to improve our services.
– Anyone else where we have your consent or where it is required by law.
7. Your marketing preferences and related searches
We’ll use your home address, phone numbers, email address and social media (e.g. Facebook, Google and message facilities in other platforms) to contact you according to your preferences. You can change your preferences or unsubscribe at any time by contacting us. In the case of social media messages you can manage your social media preferences via that social media platform.
If you have previously told us that you don’t want information on other products and services or to be included in market research, we will continue to respect your wishes. You can tell us at any time if you want to stop receiving this information.
8. Criteria used to determine retention periods (whether or not you become a customer)
We’ll retain your personal data for six years after your account has been closed or has remained inactive or has otherwise come to an end based on our legal and regulatory requirements. In some circumstances we may keep your information longer than this, for example:
– Retention in case of queries. We’ll retain your personal data as long as necessary to deal with your queries (e.g. if you have a credit or debit balance on your account);
– Retention in case of claims. We’ll retain your personal data for as long as you might legally bring claims against us; and
– Retention in accordance with legal and regulatory requirements.
9. Your rights under applicable data protection law
Your rights are as follows (noting that these rights don’t apply in all circumstances):
– The right to be informed about our processing of your personal data.
– The right to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed.
– The right to object to processing of your personal data.
– The right to restrict processing of your personal data.
– The right to have your personal data erased (the “right to be forgotten”).
– The right to request access to your personal data and information about how we process it.
– The right to move, copy or transfer your personal data, (“data portability”).
– Rights in relation to automatic decision making including profiling.
You have the right to complain to the Information Commissioner’s Office. It has enforcement powers and can investigate compliance with data protection law and can be found at ico-org-uk.
10. Data anonymisation and aggregation
Your personal data may be converted into statistical or aggregated data, which can’t be used to identify you, then used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described above.