Introduction

This Privacy Policy sets out how Days Fleet uses and protects any personal information that you provide to Days Fleet when you use our products, services and website.  Days Fleet is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be personally identified when using our website, products and services, then you can be assured that it will only be used in accordance with this privacy policy.

 

1. Scope

All data subjects whose personal data is collected in accordance with the requirements of the General Data Protection Regulation (“GDPR”).

 

2. Responsibilities

The entire Management Team is responsible for ensuring that this notice is made available to data subjects prior to Days Fleet collecting / processing their personal data.

 

3 . Privacy Notice

3.1 Who are we?

Days Fleet is a UK based vehicle leasing and fleet management company; funding lease vehicles and associated services to the private and public sector.   If you have any queries about this privacy notice or wish to exercise any of the rights mentioned in it, please contact our Data Protection team at [email protected] or in writing to Days Fleet, Swansea Road, Garngoch, Swansea, SA4 4LL.

 

In this Privacy Policy, your ‘personal information’ means information or pieces of information that could allow you to be identified.  You do not have to give us any personal data, but if you choose not to do so this may prevent us from providing you with information, services or from being able to fulfil our contractual obligations to you. Your personal information is required before you can enter into a contract with us, or it is required during the life of that contract, or it is required by laws that apply to us.

The personal data we may collect from you is:

 

Information you give us directly:

We may collect information from you directly when you provide us with personal information, e.g. sign up to receive information, use applications, buy a product or service from us, complete a survey, visit our premises, or make a comment or enquiry. The types of information we may collect from you directly include your:

  • name and job title
  • contact information including email address and phone number
  • vehicle make, model and registration number
  • home address and postcode
  • driver licence details
  • credit card or other payment information
  • other information relevant to our products and services
  • visual images via CCTV at our premises

 

Information given to us indirectly by other parties:

We may collect information about you indirectly when we are contacted by a third party acting on your behalf i.e. a broker.  We are reliant on the third party being authorised to pass the data to us and that it is accurate.  The types of information we may collect about you indirectly include your:

  • name and job title (including Directors’ details if applicable)
  • contact information including email address and phone number
  • vehicle make, model and registration number
  • home address and postcode
  • driver licence details
  • credit card or other payment information
  • other information relevant to our products and services

When a broker or other third party processes your personal information as a data controller in its own right, its own privacy policy will apply and you should ask them for a copy if you do not have one by the time you are introduced to us.

 

Information collected automatically when you use the Days Fleet Sites:

We (and third-party service providers acting on our behalf) use cookies and other tools (such as web analytic tools and pixel tags) to automatically collect information about you when you use Days Fleet sites; subject to the terms of this Privacy Policy and applicable data laws and regulations. The types of information collected automatically may include:

  • information about the type of browser and device you use
  • details of the web pages you have viewed
  • your IP address
  • the hyperlinks you have clicked
  • the websites you visited before arriving at a Days Fleet Site

 

The personal data we collect from you will be used for the following purposes:

  • internal record keeping
  • we may use the information to improve our products and services
  • we may use the information for the purpose of carrying out our services
  • we may periodically send promotional emails about new products, special offers or other information which we think you may find interesting, using the email address which you have provided
  • from time to time, we may also use your information to contact you for service level reasons
  • to consider and assess your application for a service

 

The special categories of personal data concerned are:

  • Health data
  • Convictions and offences associated with driving licences

 

3.2 Lawful Basis for Processing

Days Fleet will only collect, use or disclose your personal information where it is fair and lawful to do so. Data protection laws require us to explain our legal grounds for processing your personal information. We use the term processing to describe everything we do with your personal information from its collection, right through to its destruction or deletion.  This includes sharing your data with other organisations.

We may ask you to provide additional consent if we need to use your personal information for purposes not covered by this Privacy Policy. You are not obliged to provide such consent but if you decide not to then our ability to carry out services may be restricted. If you provide additional consent, the terms of that consent shall prevail in the event of any conflict with the terms of this Privacy Notice.

The legal grounds that are relevant to Days Fleet are:

  • Processing which is necessary to perform our contract with you or taking steps prior to entering into it (during the application stage).  We use this ground for:
    a) administering and managing your account, updating your records; and
    b) sharing your personal information with other payment services providers
  • Processing which is necessary for our own legitimate interests or for those of other organisations (where we have listed at clause 3.4 below), where these interests are not outweighed by any prejudice to your rights and freedoms. We use this ground for:
    a) administering and managing your account, updating your records;
    b) to test the performance of our products, services and internal processes;
    c) to adhere to best practice under the regimes of governmental and regulatory bodies such as the       Information Commissioner’s office and the British Vehicle Rental & Leasing Association;
    d) to carry out searches at Credit Reference Agencies;
    e) for market research and analysis and developing statistics;
    f) for direct marketing communications; and
    g) when we share your personal information with those organisations listed in clause 3.4
  • Processing which is necessary to comply with our legal obligations. We use this ground for:
    a) compliance with laws that apply to us;
    b) establishment, defence and enforcement of our legal rights;
    c) activities in the relating to the prevention, detection and investigation of crime;
    d) to carry out identity checks, anti-money laundering checks pre-application and at the application stage; and
    e) to deal with requests from you to exercise your rights under data protection laws.
  • Processing with your consent. We use this ground for:
    a) when you request that we share your personal information with someone else and consent to that; and
    b)  some of our processing of special categories of personal information such as about your health.

 

3.3 How and when can you withdraw your consent?

As we explain above, much of what we do with your personal information is not based on consent.  Instead, it is based on other legal grounds.  For processing that is based on your consent, you have the right to withdraw at any time.  You can do this by contacting us at [email protected]

The consequence of withdrawing your consent might be that we cannot send you some marketing communications or that we cannot take into account special categories of personal data such as about your health (but these outcomes will be relevant only in cases where we rely on explicit consent for this).

 

3.4 Who do we share your personal information with?

Depending on the circumstances we may share your personal information with:

Third Party Reason for Disclosure
Police, government, local authorities Prevention and prosecution of crime, emergencies
Credit reference agencies, trade association databases Detection and prevention of fraud
Our appointed subcontractors and service providers Fulfilment of your contract and provision of associated services
Other companies within the CEM Day Ltd group of companies Statistical and reporting purposes, underwriting decisions
Insurance companies, solicitors, debt collection agencies, other interested parties Discharging liability for actual or potential civil claims arising from your use of the vehicle

 

3.5 Retention Period

Days Fleet will store and process personal data as follows:

Type of Data Retention Period
Business Contact Details 7 years following contract termination
Prospective Customer Contact Details 3 years following last contact
Driver Contact Details Up to 12 months following contract termination or driver employment termination
Contract Signatory Identification Documents Not retained after identity verified
Driver Licence Data Up to 6 months following service termination or driver employment termination
Data held in vehicles Deleted upon vehicle return (if not already deleted by client as requested)
Bank and payment card details

Card details stored in accordance with PCI DSS

Bank details retained until contract termination

Telephone Calls

6 months

 

3.6 Credit Reference Agencies

In order to process your application, we will perform identity checks on you with one or more credit reference agencies (CRAs). To do this, we supply your name and other identifying information to the CRAs and they will give us information about you.  This will include information from your credit application about your financial situation and financial history.  CRAs will supply to us public information (including the electoral register). We will use this information to identify you, to verify the accuracy of the data you have provided to us and prevent criminal activity, fraud and money laundering.

 

3.7 Your rights as a Data Subject

At any point, while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • The right to be informed – you have the right to be informed about the collection and use of your personal data
  • The right of access – you have the right to request a copy of the information that we hold about you
  • The right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
  • The right to erasure – in certain circumstances you can ask for the data we hold about you to be erased from our records
  • The right to restrict processing – where certain conditions apply you have a right to restrict the processing
  • The right to data portability – you have the right to have the data we hold about you transferred to another organisation
  • The right to object – you have the right to object to certain types of processing such as direct marketing
  • The right to not be subject to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Days Fleet refuses your request under rights of access, we will provide you with a reason as to why; you have the right to complain as outlined in clause 3.8 below.

If you wish to exercise any of these rights against any credit reference agencies or a broker or other intermediary you will need to contact them separately.

 

3.8  Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Days Fleet (or third parties described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with Days Fleet’s data protection representatives by writing to [email protected] or Days Fleet, Swansea Road, Garngoch, Swansea, SA4 4LL.   Our complaints procedure can be viewed at www.daysfleet.com/complaints.  You also have the right to complain to the Information Commissioner’s Office, which is the regulator for data protection laws.

 

4. Safeguarding your Personal Information

We take all reasonable precautions to keep your personal information secure and require any third parties that handle or process your personal information for us to do the same. Access to your personal information is restricted to prevent unauthorised access, modification or misuse and is only permitted among our employees and agents on a need-to-know basis.

 

4.1 Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect as much as is reasonably possible.

 

4.2 Transfer of Data outside of the European Economic Area

In certain circumstances your data may be transferred outside of the EEA by Days Fleet or our sub-processors. If such transfer takes place we will ensure that your rights will be protected and will have effect as if such processing were to take place inside the EEA.

 

5. Telephone Recording

Days Fleet records all phone conversations for quality monitoring, training, compliance and security purposes.

In order to maintain high standards and protect our clients, suppliers and employees; all inbound and outbound calls are recorded and retained for a period of six months. The call recording facility is automated and recordings will only be used for the purposes specified above.

An itemised call log will be retained of all calls made and received on Days Fleet’s telephone network which will include details of the external caller’s number and the date, time and duration of the call.

We shall ensure that the use of these recordings is fair and that we comply with the requirements of the relevant legislation.

Whilst all inbound and outbound calls will be recorded, in normal circumstances a call will not be retrieved or monitored unless it is necessary to investigate a complaint, check compliance with regulatory procedures or improve standards in call handling via training and coaching.

If you have any queries regarding the above policy or would like to request a copy of a call recording please contact [email protected].

 

6. CCTV at our premises

We have installed CCTV systems in some of our premises used by customers and suppliers, for the purposes of public and staff safety and crime prevention and detection. CCTV is also installed on the outside of some of our buildings for the purposes of monitoring building security and crime prevention and detection.

Images captured by CCTV will not be kept for longer than necessary. However, on occasions there may be a need to keep images for longer, for example where a crime is being investigated.   You have the right to see CCTV images of yourself and be provided with a copy of the images.

 

7. What should you do if your Personal Information changes?

You should tell us without delay so that we can update our records.  The contact details for this purpose are: [email protected]. If you were introduced to us by a broker or other intermediary, you should contact them separately.

 

8. Changes to our Privacy Policy

We may change this Privacy Policy from time to time by posting the updated version on the Days Fleet website. We will endeavour to give you reasonable notice of any material change. We encourage you to visit frequently to stay informed about how we use your personal information.