Our Privacy Principles
1. Personal information you provide is processed fairly, lawfully and in a transparent manner.
2. Personal information you provide is collected for a specific purpose and is not processed in a way which is incompatible with the purpose which we collected it.
3. Your personal information is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
4. Your personal information is kept accurate and, where necessary kept up to date.
5. Your personal information is kept no longer than is necessary for the purposes for which the personal information is processed.
6. We will take appropriate steps to keep your personal information secure.
7. Your personal information is processed in accordance with your rights.
8. We will not transfer your personal information to another country or an international organisation outside the European Economic Area unless required to do so by law. Where this is necessary we will take the required steps to ensure that your personal information is protected. Such steps may include placing the party we are transferring information to under contractual obligations to protect it to adequate standards.
9. We do not sell your personal information and we also do not permit the selling of customer data by any companies who provide a service to us.
Via our telephone calls with you, which may be recorded
When you provide your details to us either online or offline
We also collect your personal information from:
What personal information do we collect?
The information that we collect will depend on our relationship with you. Where other people are named on your contract, we may ask you to provide the information below in relation to those people too, if this is relevant to your contract.
Where we are the data controller of personal information we may collect the following:
Contact details such as name, email address, postal address and telephone number.
Details of any other persons included on the contract.
Identification information such as your date of birth, national insurance number and payroll number.
Driving licence details including details of convictions.
Salary Information including but not limited to Gross Salary, Hours Worked, Pension Status.
Information relevant to use of a car at work such as insurance information, MOT and Road Fund Licence details, details of usage.
Information relevant to any insurance claim or your involvement in the matter giving rise to a claim.
Your marketing preferences.
How do we use your personal information?
We may process your personal information for several different purposes and these are set out in more detail below. Under data protection laws we need a reason to use and process your personal information and this is called a legal ground. We have set out below the main reasons why we process your personal information and the applicable circumstances when we will do so.
Processing is necessary for us to provide you with quotes for a lease vehicle, administer your lease contract, manage complaints, process mileage and expense claims and verify your own vehicle for use at work. If you do not provide such information, we will be unable to offer you a lease vehicle and/or you will not be able to use your own vehicle at work.
Where we have a legal or regulatory obligation to use such personal information, for example, when our regulators, the Financial Conduct Authority (FCA) and our data protection regulator, the Information Commissioner's Office (ICO) wish us to maintain certain records of any dealings with you.
Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claims or where we want to pursue any legal claims ourselves.
We will only ask for your consent when signing up for a new or replacement lease car, when registering your own car for use at work and to be able to provide you with marketing information (including information about other products and services). Without your consent, we cannot supply a lease car, enrol you in GreyFleet or be able to supply you with details of our services and offers.
Where we have appropriate legitimate business need to use your personal information such as maintaining our business records, developing and improving our products and services, all whilst ensuring that such business need does not interfere with your rights and freedoms and does not cause you any harm.
Why we need your personal information
Personal information we may process for the purpose adjacent shall include, but shall not be limited, to the types of information set out below
Legal Grounds for Processing
To provide you with a quote.
Your contact details, salary details and your age.
Legal ground: such use is necessary to provide your quote.
To administer, provide and service your lease car contract.
Your contact details, salary details, your age, your driving licence details including details of any convictions and the details of any others named on your contract as additional drivers.
Legal grounds: such use is necessary to provide your contract and we have a legitimate business need to use your personal information to administer your contract and handle any issues, fines or insurance claims.
To validate your private vehicle and licence for use at work.
Your contact details, your age, your driving licence details including details of any convictions.
Legal grounds: such use is necessary to validate your vehicle for use at work.
To communicate with you and resolve any complaints you may have.
Your contact details and any information relevant to your contract.
Legal grounds: such use is necessary to provide your contract and we have a legitimate business need to resolve any complaints.
Complying with our legal or regulatory obligations.
Details about you, other related parties, your product or service, depending on the nature of the obligation.
Legal ground: such use is necessary for us to comply with our legal or regulatory obligations.
Providing improved quality, training and security (for example, with respect to recorded or monitored phone calls or online chat); technology may include voice analytics.
Details about you and other related parties, your product or service having been discussed with you or your representative during a telephone conversation with us.
Legal ground: we have a legitimate business need to provide secure and quality services.
Providing marketing information to you (including information about other products) in accordance with preferences you have expressed.
Your name contact details, marketing preference.
Legal ground: you have provided your consent.
Who do we share your personal information with?
This might include:
Where you have named an alternative contact (such as a PA) to speak with us on your behalf. Once you have told us your alternative contact, this person will be able to discuss all aspects of your contract with us and make changes on your behalf.
A dealership or lease company in respect of delivering your vehicle.
A lease company or collection agent in respect of collecting your vehicle.
An Insurer/Broker, Solicitors and Recovery Agents in respect of an accident claim.
A body repairer in respect of repair works following an accident.
A hire car company in respect of a replacement vehicle while your vehicle is off road.
An Insurance Company in respect of your private policy where you have given us permission to do so.
The DVLA in respect of obtaining your driving licence details.
The police, government agencies, councils, parking authorities or other third parties in respect of Parking fines, Speeding fines, Bus Lane Contravention, Dart charge or other applicable fines or charges.
A third-party mileage/expenses provider where your employer has specified the use of such.
The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
Our third-party services providers such as IT suppliers, auditors, lawyers, document management providers and tax advisers.
Regulatory authorities such as the Financial Conduct Authority and the Information Commissioner’s Office.
Selected third parties in connection with the sale, transfer or disposal of our business.
How long do we keep records for?
The right to access your personal information:
You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing.
The right to rectification:
We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us and ask us to update or amend it.
The right to erasure:
In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal information we collected is no longer necessary for the original purpose or where you choose not to proceed with a contract or use your vehicle at work. However, this will need to be balanced against other factors, for example according to the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.
Right to restriction of processing:
In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to process your personal information.
Right to data portability:
In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for looking after your personal information.
Right to object to direct marketing:
You can ask us to stop sending you marketing messages at any time.
The right to withdraw consent:
For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. Please note in some cases we may not be able to provide a contract, or you may not be able to use your vehicle at work if you withdraw your consent.
The right to lodge a complaint:
You have a right to complain to the ICO at any time if you object to the way in which we use your personal information. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
You can make any of the requests set out above using the contact details provided to you. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we can't comply with your request, we will tell you why.
In some circumstances exercising some of these rights will mean we are unable to continue providing you with a service which may result the termination of your contract, you will be liable for any termination fees or you will be unable to continue using your own vehicle at work.
We may use your information to provide you with details of products and services that may be of interest to you, but we will only do this where you have provided your consent. You can always change your mind by contacting us and telling us you no longer wish to be contacted.
We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you wish to unsubscribe from emails sent by us, you may do so at any time by following the unsubscribe instructions that appear in all emails. Otherwise you can always contact us to update your contact preferences. In such circumstances, we will continue to send you service related (non-marketing) communications where necessary.
Please note that we may retain any data provided to us on our websites for a limited period, even if you do not complete your quote. The information may be used to enquire as to why you did not complete your quote or for us to better understand your needs but only if you have agreed for us to contact you.
If you wish to contact us about Data Protection, the details are below:
Red Lion House
If you would like to contact the UK’s Information Commissioner’s Officer direct; please write to the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Telephone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number https://ico.org.uk/global/contact-us/email/