Northgate take data privacy seriously and will only use your information in accordance with the policy below. This means we will adhere to the relevant legislations whilst doing our best to provide you with the best level of service and security.
This policy sets out how and why we store, process and delete your data and gives you information on how to contact us to view, correct or delete that data.
Last revised: May 2018
· Northgate Plc, a company incorporated in England and Wales having a registered office at Northgate Centre, Lingfield Way, Darlington, DL1 4PZ (company number 00053171);
· Northgate Vehicle Hire Limited, a company incorporated in England and Wales having a registered office of Northgate Centre, Lingfield Way, Darlington, DL1 4PZ (company number 01434157); and
· Northgate Vehicle Sales Limited, Northgate Centre, Lingfield Way, Darlington, DL1 4PZ (company number 02337128).
· northgateplc.com; or
We take our obligations under privacy and data protection law very seriously. This policy sets out how we will use and process the personal information that you, or third parties, provide to us or we collect from you.
We are registered with the Information Commissioner’s Office, with registration numbers:
· Z6183541 – Northgate PLC;
· Z6536698 – Northgate Vehicle Hire Limited; and
· Z6318808 – Northgate Vehicle Sales Limited.
Lawfulness of our Processing
It’s lawful for us to process personal information about you in different circumstances, as follows:
1) where we process personal information about you in order to fulfil any order you place with us or otherwise to perform our contract with you;
2) for any purpose that you have consented to, where we have asked for your consent in the box that pops up when you first visit our Site and/or as part of the ordering process;
3) where we are required to do so to comply with our legal obligations; and
4) where we have a legitimate interest in processing your personal information. We have a legitimate interest where we may wish to contact you about products or services, market to you, or collaborate with others to improve our services.
WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW IS IT USED
The personal information we collect and hold about you includes:
· name, address, telephone number (including mobile phone) and email;
· the information included in any documents you send to us (such as your driving licence and passport), or when using our Site (including via your customer portal, if you use one), including to search for hire vehicles, place orders or report problems with the Site or an order;
· information you complete in relation to customer satisfaction surveys;
· your occupation or the nature of your business (if applicable);
· details about the vehicle to be hired or purchased;
· information obtained by credit reference agencies (further information is set out below);
· details about your marketing preferences and interests;
· debit or credit card details or the bank account details from which direct debits under your vehicle hire will be collected;
· information which we collect about you when you visit our Site:
o technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
o information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number;
We may use any personal information provided by you or collected by us in connection with the relevant vehicle hire or sale agreement made via the Site, or otherwise as a result of our dealings with you, including for the purposes of:
· allowing you to register to use our Site, fulfilling our contractual obligations to you (or enforcing our contract terms against you) and providing you with the services you require;
· to customise the Site according to your interests;
· to respond to any requests for advice or information and otherwise provide customer support to you;
· assessing and evaluating the quality of the vehicle hire or other services we have supplied (including the use of mystery shoppers and satisfaction surveys), complying with legal and regulatory obligations and best practice standards (including carrying out credit reference checks and taking steps to comply with our obligations under anti money laundering regulations);
· fulfilling the requirements of our insurance policies (including the requirements of our insurance providers);
· to send you a password reset link if you tell us that you have forgotten your password;
· as part of our efforts to keep our site safe and secure;
· in case we have any queries concerning any aspect of your use of our Site;
· to ensure that content from our Site is presented in the most effective manner for your device;
· to allow you to participate in interactive features of our Site when you choose to do so;
· to administer our Site and for internal operations, including troubleshooting, data analysis, testing and research; and
· to measure or understand the effectiveness of advertising we serve to you and others.
You have the right to ask us to restrict processing of your personal data and a right to object to our processing of your personal data in this way. If you exercise either of these rights you may not be able to make full use of our Site and/or we may not be able to provide you with information that you have requested us to provide to you.
We will take a copy of your driving licence if you are the person hiring a vehicle from us (either in your own right or on behalf of an organisation) when the vehicle hire commences. We will also need a copy of the driving licence of all other named drivers. We retain a copy of the driving licence for some of the purposes set out above.
We and other companies within our group may also use your personal information to contact you by e-mail, telephone, post, SMS and other electronic means (including social media), with information about services (including improvements we have made to our services), industry news, industry relevant legislation changes, promotions and offers that may be of interest to you. We may use your personal information in order to establish the services, promotions and offers that are likely to be of interest to you. We will do this marketing in accordance with any preferences you have indicated to us.
Please see the Rights in Relation to Personal Information section for information as to how to change your marketing preferences. You can also choose to stop receiving marketing e-mails or SMS messages from us by clicking on the opt out link in the SMS or e-mail and following the relevant instructions. Any changes you make to your communication preferences will be processed by us within two working days of our receipt of your instruction; however, you may still receive non-essential communications in the intervening time between the submission of your change and when we process that change.
Information we collect that is not personal information
Information that is not personal information is not protected by Data Protection Legislation but we may use such information in the following ways:
· we may anonymise data about our Site users generally and use it for a range of purposes, including ascertaining the general location of users. This anonymised data is incapable of being used to identify anyone personally; and
· we may aggregate user information so that it is impossible from the aggregated set of data to identify anyone individually, which is valuable to us for the purposes of analysing market trends. You confirm that you consent to us viewing, monitoring, collecting and recording information input by you into our Site, and to our dealing with it on an aggregated basis, in a manner that does not identify you or attribute any particular information to you. You also agree to us collating, compiling, reformatting, reproducing, adapting, translating, arranging, publishing, selling, distributing, dealing with or otherwise commercially exploiting any part of such information or otherwise making it available to any third party on such terms as we deem appropriate. Please rest assured that this will not include personal data.
WHERE WILL YOUR PERSONAL INFORMATION BE PROCESSED?
We have in place appropriate technical and security measures to prevent unauthorised or unlawful access to or use of, or accidental loss of or destruction or damage to your information. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. You are responsible for protecting against unauthorised access to your password and to your computer and we ask you not to share a password with anyone. 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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data including by taking the security measures we are required to by Data Protection Legislation, we cannot guarantee the security of your data transmitted to our Site. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
· we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
· where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
· where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
To obtain further details and a copy of the appropriate safeguards please contact the DPO.
SHARING WITH THIRD PARTIES
We may also share your personal information with:-
· our group companies (all of whom use your personal information in accordance with this policy and their statutory obligations);
· our insurers to comply with our insurance obligations;
· professional advisors and debt collection agencies to assist with the recovery of amounts owed to us by you or the organisation you represent under any agreement between you and us;
· credit reference agencies (for further information see the Credit Reference Check Policy below).
As stated above, we may commercially exploit any anonymised or aggregated information on the basis that no individuals are identified or identifiable.
VEHICLE TRACKING INFORMATION
We may install devices in your vehicles which track the whereabouts of the vehicle and provide other information about the vehicle (including for example the way it is driven). These devices are either supplied directly by us (“Northgate Telematics Devices”) or by a third party where requested by an account customer (“Third Party Tracking Devices”). If you are unclear as to the basis on which tracking devices are supplied please contact us using the details below or contact the relevant account customer.
We may disclose tracking information collected by these devices to our group companies, the relevant hire or fleet management customer and to law enforcement agencies, regulatory bodies and other third parties.
Northgate Telematics Devices
Where we provide the telematics devices, we use the devices to track the location and mileage of the vehicles and to analyse the way the vehicle is driven. We use this data to help us improve our business and where applicable to help us manage our customers' vehicle fleets. For example, we use:
· location information to enable us to identify availability of vehicles across our depots;
· mileage information to ascertain when routine maintenance is required on vehicles;
· information about the way a vehicle is driven in order to manage our fleet, improve efficiency and improve the service we provide to customers;
· information about the way the vehicle is driven if an incident occurs in relation to that vehicle (for example if an accident occurs) to assist with our internal investigations and to assist our insurers in relation to the incident (if applicable).
Our fleet management customers and hire customers may have direct access to any telematics information from devices in vehicles leased to those customers and use it for their own purposes which may include identifying training requirements for drivers and improving the efficiency of their fleet of vehicles. Please ask the business on whose behalf you are driving our vehicle directly for further information about the purposes for which they use the information.
Third Party Tracking Devices supplied on behalf of account customers
Third Party Tracking Devices are installed on request from the relevant account customer. Our use of the information collected by the Third Party Tracking Devices is on behalf of the relevant account customer who will dictate what information is collected. This may include, for example, mileage and location information and other information about the vehicle (including the way it is driven). The provider of the Third Party Tracking Devices will disclose tracking information collected by these devices directly to the relevant account customer. We do not use this tracking information for our own purposes and the data controller in relation to this information is the relevant account customer. To the extent that we access and use any of this information we do so on behalf of the account customer as a data processor. The relevant account customer is responsible for making you aware that a device is included in any vehicle that you drive which is hired from us and the purposes for which the account customer will use the information from the Third Party Tracking Devices. For further detail about how this information will be used please contact the relevant account customer directly.
Third party websites
Communication, engagement and actions taken through external social media platforms on which we may participate on are subject to the terms, conditions and privacy policies held with each social media platform respectively. We will never ask for personal information through social media platforms and we encourage users wishing to discuss sensitive details to contact us through primary communication channels such as by telephone or email. Our site may use social sharing buttons which help share web content directly from web pages to the social media platform in question. You are advised before using such social sharing buttons that you do so at your own discretion and note that the social media platform may track and/or save your request to share a web page through your social media platform account.
RIGHTS IN RELATION TO PERSONAL INFORMATION
You have the following rights in respect of your personal information:
i) a right to request from us access to your personal data;
ii) a right to request rectification of your personal data;
iii) a right to request erasure of your personal data;
iv) a right to ask us to restrict processing of your personal data and a right to object to our processing of your personal data (but if you do either of these, it may impact on your use of our Site and/or we may not be able to provide you with information that you have requested us to provide to you);
v) a right to ask us for a copy of any personal data you have provided about yourself and to have a copy of it transferred from us to another data controller (which, until 25 May 2018, may be subject to a £10 charge) 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. You can ask us to transfer this personal data directly to another controller, where technically feasible; and
vi) a right to lodge a complaint about how we treat your personal data with the Information Commissioner’s Office.
If you want to exercise any of the above rights you should contact our Data Protection Officer using the contact details in the Introduction section above.
HOW LONG WE KEEP PERSONAL INFORMATION
If you agree to be added to our mailing list, we will keep your personal information for that purpose unless and until you tell us that you want to unsubscribe or be removed from the list. If you advise that you do not want to be added to our mailing list or you ask to be removed, we will delete your personal data (aside from keeping a record that you have asked us not to send you marketing information).
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular website. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our site in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our site.
Where you have given us consent to use your personal information in any way, you have a right to withdraw that consent at any time. If you withdraw your consent, this does not affect the lawfulness of our processing activities carried out prior to such withdrawal. If you would like to withdraw your consent either follow the unsubscribe links in emails we send you or contact our Data Protection Officer using the contact details in the Introduction section above.
CREDIT REFERENCE CHECK POLICY
This policy applies if you are hiring a vehicle under an established account or an account is being set up in order to permit you to hire vehicles and in each case if you are not paying in advance for the vehicle hire. In this section “Customer” means the business hiring a vehicle from us or you, if you are hiring the vehicle for yourself.
How we will use your information?
We will search credit reference agencies for information on Customers which may include carrying out a search on you personally. In so doing we will provide current and previous names, addresses and dates of birth, of all relevant parties, so if you are providing information about third parties, you must be sure that you have the agreement of those third parties. If false or inaccurate information is given and we identify fraud, details may be passed to credit reference and fraud prevention agencies.
We will use the information provided to us by credit reference agencies to help make decisions about whether to open an account, to verify identity, for the prevention and detection of fraud and/or money laundering, and to manage accounts (including for debt recovery and cash collection purposes). We may use scoring methods to do this.
When credit reference agencies receive a search from us they will place a search “footprint” on the credit file of the Customer whether or not we decide to open an account. This “footprint” may be seen by other organisations when the Customer applies for credit in the future and may affect the Customer’s ability to obtain credit elsewhere in the near future.
Credit reference agencies will supply us with public information such as County Court Judgements (CCJs) and bankruptcies, electoral register information and fraud prevention information on applicants’ (and their known financial associates), current and previous names, addresses and dates of birth.
If the Customer is making a joint application now or has ever:-
· applied for credit with someone else;
· held joint account(s);
· been financially linked to someone else,
we will check relevant financial associates' personal accounts as well.
Links between financial associates will remain on your file and the file of your financial associates until such time as you or the relevant financial associate files for a disassociation with the credit reference agencies.
How data will be used by credit reference agencies?
The information which we and other organisations provide to the credit reference agencies about the Customer, or any person financially linked to the Customer, may be supplied by credit reference agencies to other organisations and used by them to:
· prevent crime, fraud and money laundering, for example by checking details provided on applications for credit and credit related or other facilities;
· check the operation of credit and credit-related accounts;
· verify the identity of the Customer, or any person financially linked to the Customer when applying for other facilities;
· make decisions on credit and credit related services about the Customer, or any person financially linked to the Customer;
· manage the account or credit facility of the Customer, or any person financially linked to the Customer;
· trace whereabouts and recover debts that the Customer owes; and
· undertake statistical analysis and system testing.
Credit reference agencies can also be fraud prevention agencies.
How to find out more
To find out more about credit reference agencies please contact the 2 credit reference agencies currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge a small statutory fee. These organisations are:
CreditSafe, Customer Help Desk, Bryn House, Caerphilly Business Park, Van Road, Caerphilly CF83 3GR, or call 02920886500.
Experian, Consumer Help Service, PO Box 8000 Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk.
If you have any queries about the way we handle personal information please contact our Data Protection Officer using the contact details in the Introduction section above.
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.