This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (GDPR).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – A person.
Categories of data: Personal data and special categories of personal data
The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example; name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data
The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
Holt Services Limited is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Holt Services Limited, Browns Meadow, Edburton, West Sussex BN5 9LN. email@example.com. For all data matters please contact our data representative Alex Cole on 01273 857520 or email firstname.lastname@example.org
3. The purposes of processing your personal data
We may use your personal data for the following purposes:
- To contact you regarding our services, offers, or anything that may be of interest to you regarding the safety or maintenance of your vehicle
- To send you documents relating to your vehicles, for example copy invoices
- To remind you that your MOT or vehicle service is due
- To verify that the information we hold is accurate
- To maintain our accounts and records
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Email and telephone contact details
- Car registration, make, model and colour
- Notes that are taken during conversations
- Employment position (for supplier contacts)
Special categories of data
- Religion, sexual orientation, medical information and other sensitive information will only be used with your specific consent and with your prior knowledge. If this information is not necessary to our relationship with you, please do not share it with us.
We may have obtained your personal data from:
- You verbally
- You by email
- You by post
- You in person when visiting our premises
- You via an online form
- You creating an account on our website
- You requesting marketing to be sent to you
- From third parties such as other people or from websites and other publicly available sources. (Where we obtain your personal data from a third party we will inform you of the source within appropriate timeframe.)
5. What is our legal basis for processing your personal data?
Our lawful basis for processing your personal data (article 6 of GDPR) is:
In certain circumstances, we will ask for your consent to process your data and in the event that consent is required we will contact you accordingly.
Performance of a contract with you or to take steps to enter into a contract: To comply with the terms and conditions of any contract.
Compliance with a legal obligation: To comply with legal requirements and regulations relating to HMRC, employment law and any other official body.
To protect the vital interests of a data subject or another person.
For the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
For the purposes of the legitimate interests of Holt Services Limited or a third party, except where such interests are overridden by your interests or fundamental rights or freedoms. Our commercial interests and the commercial interests of third parties, marketing, the prevention of fraud and IT security.
Processing necessary for carrying out the obligations under employment, social security or social protection law, or a collective agreement.
Processing necessary to protect the vital interests of a data subject or another individual where the data subject is physically or legally incapable of giving consent.
Processing relates to personal data manifestly made public by the data subject.
Processing necessary for the establishment, exercise or defence of legal claims or where court is acting in their judicial capacity.
Processing necessary for reasons of substantial public interest on the basis of EU or Member State Law.
More information on lawful processing can be found on the ICO website.
6. Sharing your personal data
Your personal data will be treated as strictly confidential but we may have to share your personal data with the parties set out below:
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
Data management systems which comply with the safety standards of the Information Commissioner’s Office including cloud storage including accounts and CRM systems servers, computers and backups on site.
Off-site and on-site backup.
On our website and social media pages.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
8. How long do we keep your personal data?
We keep your personal data for no longer than is reasonably necessary in order to: Provide you with our services; in case of any legal claims/complaints; for safeguarding purposes and to comply with legal requirements and the requirements of official regulatory bodies.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing email@example.com at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product or service experience or other transactions.
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But if you do not do so it may mean that we cannot provide you with the products and services that you have requested, or be able to continue the performance of any contract we have with you.
10. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- You may request a copy of the personal data which we hold about you;
- Request that we correct any personal data if it is found to be inaccurate or out of date;
- To request your personal data is erased where it is no longer necessary to retain such data;
- You may request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, known as the right to data portability, (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with you);
- To withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
- Where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction placed on further processing;
- To object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests, or the performance of a task in the public interest/exercise of official authority; direct marketing and processing for the purposes of scientific/historical research and statistics).
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
11. Transfer of Data Abroad
We do not transfer personal data outside the EEA.
12. Automated Decision Making
We do not use any form of automated decision making in our business.
13. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
This version was last updated on 01/05/2019.
15. Queries, requests or concerns
To exercise all relevant rights, queries or complaints in the first instance please contact our Data Representative Adrian Harwood on 01273 857565 or email firstname.lastname@example.org
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 0303 1231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.