What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to data portability.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Personal Data do we Collect and Process?
Our clients are the Data Controller and they provide us with information they have collected at the time you entered into a legal contract with them and whilst they administered your account. We may process some or all of the following personal data in order for us to carry out the instructions we recieve from clients (this may vary according to your relationship with us):
- Date of birth;
- Email addresses;
- Telephone numbers;
- Business name;
- Agreement reference number;
- Vehicle identifier;
- Vehicle insurance information.
Your personal data is processed from the following sources:
- Clients’ agents and representatives;
- Government bodies;
- Credit reference agencies;
- Public and consented databases;
- Other private organisations that may hold information that may be required to permit our clients to enforce their rights under a financial agreement.
How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for your performance of a contract with a client, because you have consented to the use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- In the performance of a contract with our client;
- To enforce a legal right;
- Communicating with you. This may include responding to emails or calls from you;
- The prevention, detection and investigation of theft and fraud.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods:
- We will keep all the information for a minimum of 2 years from the date we close an account;
- Information may be kept for longer periods where we have reported circumstances to the police or to comply with our contractual obligations.
How and Where Do You Store or Transfer My Personal Data?
We will not store your personal information in countries outside of the UK or the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). However, we may in certain circumstances be required to transfer some or all of your personal data to countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- Policies to protect data at rest and in transit;
- Segregation of personal data;
- Implementation of security measures to prevent unauthorised access to your personal data;
Do You Share My Personal Data?
In some circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
As part of our data processing we may also disclose some of your personal data to third parties, such as insurers, credit reference agencies, recovery agents or the police.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
If you are not satisfied with aspect of how we handle your personal data, you have the right to lodge a complaint with the Information Commissioners’ Office. The contact details are: –
Information Commissioners Office
T: 0303 123 1113 / 01625 545 745
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details in Part 1 by:
Email to: firstname.lastname@example.org
Telephone: 0161 50 50 20 7
By post to: Legate Group Limited, Central Building, Carrington Business Park, Manchester M31 4DD
Changes to this Privacy Notice
We may change this Privacy and Processing Statement from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available via our website or in writing on request..