Drivetech (UK) Limited’s main address is Drivetech (UK) Limited, The AA, Level 3, Business Services Department, Plant, Basing View, Basingstoke, Hampshire, RG21 4HG. We will refer to Drivetech (UK) Limited in our privacy notice as Drivetech. Drivetech is registered with the Information Commissioner’s Office (ICO) under registration number Z6619012.

Drivetech is the data controller in relation to the processing activities described in this notice. This means Drivetech decide why and how your personal information is processed. 

Below we have set out the types of information we hold about you and how we use your information.

Drivetech is part of the AA Group.

This policy/procedure does not form part of your contract of employment; however, adherence is a condition of employment and breaches may lead to disciplinary action.

Contractors and other external parties working with or on behalf of Drivetech UK Limited may have their contract terminated for non-compliance.

 

 

Applicability

 

We may change this privacy notice from time to time by updating this document/page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website.

We have a dedicated data protection officer (“DPO”). You can contact the DPO by writing to us at Drivetech (UK) Limited, The AA, Level 3, Business Services Department, Plant, Basing View, Basingstoke, Hampshire, RG21 4HG, marking it for the attention of the DPO or by email to dataprotection@theaa.com or ComplianceTeamMBX@drivetech.co.uk.

It is the responsibility of the Senior Leadership Team to ensure adequate resources are provided to enable the implementation of this process.

 

 

Types of Personal Data We Process

 

Personal information that we’ll process in connection with all products and services, if relevant, includes:  

  • Personal and contact details, such as title, full name, contact details and contact details history
  • Your date of birth, gender and/or age;
  • Records of your contact with us such as via the phone and, if you get in touch with us online using our online services;
  • Details of products and services you hold with us, as well as have been interested in and have held;
  • Vehicle information, such as make and model;
  • Telematics and driving information about your vehicle, driving style (including recommending improvements and assessing risk associated with your driving style), location;
  • Information we obtained from third parties, including information about risk;
  • Information about your driving licence status, entitlements and endorsements;
  • Information about your health or if you are a vulnerable customer
  • Information, and information to help improve the relevance of our products and services;

 

 

Sources of Personal Data

 

We’ll collect personal information from the following general sources:

  • From you directly;
  • Information generated about you when you use our products and services;
  • Your employers;
  • The Driver and Vehicle Licensing Agency (DVLA) and the Driver and Vehicle Agency in Northern Ireland (DVA) where we are providing licence checking services

 

Uses of Personal Data

 

We use your personal data, including any of the personal data listed above, for the following purposes:

  • To undertake and provide vehicle licensing checks with the DVLA and the DVA to your employer
  • Updating your records with the DVLA, DVA and the DVSA
  • Managing any aspect of the product or service;
  • To perform and/or test the performance of, our products, services and internal processes;
  • To improve the operation of our business and that of our business partners;
  • To follow guidance and best practice under the change to rules of governmental and regulatory bodies;
  • For management and auditing of our business operations including accounting;
  • To monitor and to keep records of our communications with you and our staff;
  • For market research and analysis and developing statistics;
  • Direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We’ll send marketing to you by SMS, email, phone, post, social media and digital channels (e.g. using Facebook, LinkedIn and Twitter). Offers may relate to any of our products and services as well as to any other offers and advice we think may be of interest;
  • To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels;
  • To develop new products and services and to review and improve current products and services;
  • To comply with legal and regulatory obligations, requirements and guidance;
  • To provide insight and analysis of our customers both for ourselves and for the benefit of business partners, either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our businesses;
  • To share information, as needed, with business partners, service providers or as part of providing and administering our products and services or operating our business; and
  • To facilitate the sale of one or more parts of our business.

 

 

Lawful Basis for Processing

 

We are allowed to use your data for the following legal reasons:

  • Where it is needed for the performance of the contract, to provide you with our products or services, such as:
  1. Operating a product or service you hold with us and managing the product or service
  2. To undertake and provide vehicle licensing checks with the DVLA and the DVA to your employer; Updating your records with the DVLA, DVA and the DVSA
  • Sharing your personal information with business partners and services providers when you to deliver and manage our products or services;
  1. All stages and activities relevant to managing the product or service including enquiry, application, administration and management of accounts; and
  2. For some of our profiling and other automated decision making to decide whether to offer you a product and/or service, particular payment method and the price or terms of this.

 

  • Where it is in our legitimate interests to do so, such as:
  1. To perform and/or test the performance of, our products, services and internal processes;
  2. To follow guidance and recommended best practice of government and regulatory bodies;
  • For management and audit of our business operations including accounting;
  1. To carry out monitoring and to keep records of our communications with you and our staff;
  2. To administer our good governance requirements, such as internal reporting and compliance obligations;
  3. For market research and analysis and developing statistics
  • Subject to the appropriate controls, helping us improve products or services, or to assess or to improve the operating of our businesses;
  • For some of our profiling and other automated decision making

 

  • To comply with our legal obligations
  • With your consent or explicit consent for some direct marketing communications, for some of our profiling and other automated decision making and for some of our processing of special categories of personal data such as your health, if you are a vulnerable customer or some criminal records information.
  • For a public interest, such as:
  1. Processing of special categories of personal data such as your health, criminal records information (including alleged offences).

 

 

Sharing Personal Data

 

In order to provide our services, we may share information with the following third parties for the purposes listed above:

  • AA Group companies
  • Business partners (e.g. your employer or fleet management company), others who are a part of providing your products and services or operating our business;
  • The DVLA, DVA, and the DVSA; 
  • Other organisations and businesses who provide services to us such as back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions

 

Withdrawing Consent

 

Where we’re relying upon your consent to process personal data, you can withdraw this at any time by contacting us in writing at: Drivetech (UK) Limited, The AA, Level 3, Business Services Department, Plant, Basing View, Basingstoke, Hampshire, RG21 4HG or via email to ComplianceTeamMBX@drivetech.co.uk

 

Transferring Personal Data

 

We’re based in the UK but sometimes your personal information may be transferred outside of the UK and the European Economic Area. If we do so we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply, for example, if you are using one our services outside of the European Economic Area.

 

 

Change to your Personal Data

 

You should tell us so that we can update our records either in writing at Drivetech (UK) Limited, The AA, Level 3, Business Services Department, Plant, Basing View, Basingstoke, Hampshire, RG21 4HG or via email to ComplianceTeamMBX@drivetech.co.uk. We’ll then update your records where possible.

 

 

Providing Personal Data

 

We’re unable to provide you with our products or services if you do not provide certain information to us.  In cases where providing some personal information is optional, we’ll make this clear.

 

 

Monitoring Processing of Personal Data

 

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications. 

We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

 

 

Other Automated Decision Making

 

We sometimes make decisions about you using only technology, where none of our employees or any other individuals have been involved. For instance, we may do this to decide: the risk associated with your driving (for example, if your employers or fleet management company asks us to do this).

We’ll do this where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent.

 

 

 

Data Retention

 

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

  • For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations;
  • For as long as we provide goods and/or services to; and/or
  • Retention periods in line with legal, regulatory, and contractual requirements or guidance.

 

 

Individual Rights

 

Here is a list of the rights that all individuals have under data protection laws.

 

They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not.

 

  • The right to be informed about the processing of your personal information;
  • The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
  • The right to object to processing of your personal information;
  • The right to restrict processing of your personal information;
  • The right to have your personal information erased (the “right to be forgotten”);
  • The right to request access to your personal information and to obtain information about how we process it;
  • The right to move, copy or transfer your personal information (“data portability”); and
  • Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

 

To exercise any of these rights, you can contact us in writing at Drivetech (UK) Limited, The AA, Level 3, Business Services Department, Plant, Basing View, Basingstoke, Hampshire, RG21 4HG or via email to ComplianceTeamMBX@drivetech.co.uk.

 

You also have the right to complain to the Information Commissioner’s Office which enforces data protection laws – https://ico.org.uk..

 

 

Your Right to Object

 

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us in writing at Drivetech (UK) Limited, The AA, Level 3, Business Services Department, Plant, Basing View, Basingstoke, Hampshire, RG21 4HG to exercise these rights.

 

 

Marketing Preferences

 

We may use your work address, phone numbers, email address and social media or digital channels (e.g. Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us in writing at Drivetech (UK) Limited, The AA, Level 3, Business Services Department, Plant, Basing View, Basingstoke, Hampshire, RG21 4HG or by following the instructions in the communication.

 

 

Contact Us

 

If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, you can contact us via email to ComplianceTeamMBX@drivetech.co.uk. Alternatively, you can write to Drivetech (UK) Limited, The AA, Level 3, Business Services Department, Plant, Basing View, Basingstoke, Hampshire, RG21 4HG, marking it for the attention of the DPO.