Glenside Commercials Ltd Privacy Notice
This notice was last updated: Friday 3rd May 2019
How Glenside Commercials Ltd uses your information
We are Glenside Commercials Ltd, a company incorporated in England and Wales with registered number 01230498.
We are also registered with the Information Commissioner’s Officer with registration number Z2692182. This registration covers the uses of personal information set out below.
What information do we collect?
GDPR defines personal data as the following:
‘Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;’
‘Special categories’ of personal data (sensitive personal data) relate to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.
We collect information about you and your vehicle when you engage with us. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for. The information we collect includes some or all of the following:
Date of Birth
National Insurance Number
Driving Licence Number
Driving Licence Endorsements
Eligibility to Work in the UK Documents
Brief Medical History
Emergency Contact Details – Name, Relationship, Address, Contact Number.
Attendance Records, Sick Leave, Annual Leave
Return to work form details
Expression of wishes
Contract of Employment
Voice recordings of calls you make to us
Personal Images and Movements – CCTV from our premises
Any information within correspondence you send to us
Vehicle information (including registration number, VIN, service reminders, mileage and warranty repair information
How do we use this information?
We will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communications from us and you can withdraw your consent or object at any time. We will never send you unsolicited ‘junk’ email or communications or share your personal information with anyone else who might.
There are various ways in which we may use or process your personal information. We list these below:
Consent – Where you have provided your consent, we may use and process your information to contact you from time to time about promotions, events, products, services or information which we think may be of interest to you. We may also with your agreed permission share your personal information with our recommended third-party partners, so that they can contact you with marketing information about their products and services.
Please note you can withdraw your consent at any time by contacting us at firstname.lastname@example.org or calling us on 02920858000 or by using the unsubscribe option included in any marketing messages you receive.
Contractual performance – We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your orders, purchases and other transactions entered into with us or our authorised selected partners.
Legitimate Interest – We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interest as a business to do so.
Processing necessary to support customers – To fulfil your requests to respond to correspondence for example arrange test drives, service requests, brochure requests or information about specific vehicles and to provide vehicle support and services. This includes sending marketing information from time to time about the product or service you have purchased from us. To identify and record when you have received, opened or engaged with our website or electronic mail and to administer competitions and promotions that you enter with us and to distribute prizes. To inform you of our opening or closing details. To also verify the accuracy of the information that we hold about you and create a better understanding of you as a customer. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access. To comply with a request from you in connection with the exercise of your rights, for example where you have asked us not to contact you for marketing purposes, we will keep a record of this in order to be able to comply with your request. To inform you of updates to our terms, conditions and policies.
Legal obligation – We may process your personal information to comply with our legal requirements for example to register your vehicle with the DVLA.
Vital Interest – Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall and we need to tell you about it.
How do we share this information?
We do not sell your information to third parties, but we do work closely with our partners Fiat Professional and IVECO and our third-party suppliers who fulfil business activities for us like roadside assistance, marketing, vehicle hire, events and market research etc. This is in order to fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets where ever possible.
We do communicating Data to IVECO Limited and their related subsidiaries and affiliates of the CNH Industrial Group in order to allow them to fulfil the obligations regarding warranty and product safety; carry out assistance services also through the authorised workshops network; answer and satisfy every customer request; send any communications of a technical and / or organisational nature; conduct surveys aimed at improving the quality of the services provided, by virtue of the legitimate interest of the manufacturer and subject to your express consent, communicating Data to IVECO Limited and their related subsidiaries and affiliates of the CNH Industrial Group with the purpose of sending commercial communications as well as advertising on their products and services, or perform market researches (“Marketing third Party”).
In the course of our activities Data may be shared and communicated to IVECO Limited and the subsidiaries and affiliates of the CNH Industrial Group, authorised workshops, service providers, based into and outside the European Union, which are under specific contractual obligation and may use it solely for the fulfilment of the purposes listed above.
Disclosure of personal information
Other than as set out above, we do not transfer personal data outside of the EEA. We will not usually disclose your personal information other than as already explained above. However, there may be circumstances where we need to share personal information other than as anticipated above. These include:
· where we are legally required to disclose the information. This includes sharing the personal information with tax authorities and law enforcement agencies for the purposes of the prevention and detection of crime;
· where we need to disclose the personal information for the purpose of or in connection with any legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights;
· disclosure is required to protect our interests, or someone else’s interests (for example, to prevent fraud);
· disclosure is necessary to protect your vital interests (for example if you are unwell at our premises, we may need to seek medical assistance);
· it is to a third party for the purposes of providing administrative or processing services on our behalf. If such disclosure is required, we will take steps to ensure that the third party protects the personal information in the same way that we do and notify you of any changes to this privacy notice; and
· to any prospective purchaser of our business assets or organisation.
Keeping personal information accurate and secure
We review the personal information we hold electronically about you on an ongoing basis. We do this by checking business details and contacts against publically available records and updating your details each time you visit or contact us. We know that you provide your personal information in good faith and expect it to be look after. This is why we take the security of your personal information seriously. This means that we have taken steps internally in order to ensure that our systems adequately protect your personal information. This includes:
· physical security measures at all our premises including internal and external CCTV images;
· locating all personal information that we control on internal servers and Microsoft Cloud servers located in the United Kingdom;
· ensuring strict access controls on a need to know basis;
· monitoring access to the personal information; and
· encryption of the personal information on our servers.
You have rights in respect of your personal information and this Section explains a bit more about those rights that are applicable to what we do with your personal information and when you can exercise them. If you would like more information about any of your rights, please contact us on the details set out below.
Where you have explicitly consented to receiving marketing communications, you can withdraw consent at any time during the application process. If you wish to withdraw consent, please do so by sending your request in writing to our contact details below.
Accessing your personal information
We want you to fully understand and be comfortable with how we use your personal information. You can contact us at any time to ask whether we process any personal information about you. If we do hold or use your personal information in any way, you have the right to access that personal information. All we ask is that:
· you make your request to access in writing to the contact details below;
· you verify your identity; and
· you are fair and reasonable with how often you make this kind of request.
Please allow us up to one month from receipt of your request in order to provide a response.
Requesting more information
We hope that you can understand that it is very difficult to cover all the possible ways in which we collect and use personal information. We have tried to be as clear and as open as we can and will continue to update this privacy notice as our use of personal information develops. However, if you have any questions regarding our use of your personal information, we will be happy to give you peace of mind by answering any questions or providing any additional information that we can. If you do have any specific questions, or need anything explaining, please get in touch on the contact details below.
You also have some additional rights that you may exercise as set out here. We may publish a policy, from time to time, to explain how we will handle such requests and what you can expect from us when you make a request to exercise your rights. If we do publish any such policy, we will provide a link to it here. In each instance we may ask you to make your request in writing to the contact addresses below and provide verification of your identity.
· You have the right to request that we rectify any inaccuracy about you that we may hold, in which case we may ask you to verify the corrected information (for example, we may ask for a recent utility bill for proof of change of address)
· You have the right to request that we erase your personal information. Please be aware that we can only comply with such a request if
1. your personal information is no longer required for the purposes it was collected for (for example, we need your personal information to say that a vehicle is ready to be collected)
2. the collection, storage or use of the personal information by us is prevented by law;
3. your personal information is not required for the purposes of establishing, exercising or defending a legal claim such as in the conduct of legal proceedings.
· You have the right to request that we restrict or refrain from processing your personal information:
1. for the time it takes us to verify the accuracy of your personal information where you have disputed its accuracy;
2. where the collection, storage or use of the personal information by us is unlawful but you decide not to ask for erasure;
3. where, we no longer need your personal information but you need them for the purposes of establishing, exercising or defending a legal claim;
4. for the time it takes to determine whether we have an overriding legitimate ground to continue to process your personal information, where you have exercised your right to object to processing.
· You have the right to data portability in respect of information we have collected from you based on consent or for the reason of entering into a contract. If you exercise this right, we will transfer a copy of the information that you have provided to us at your request.
· You have the right to object to our use of your personal information:
1. where we are using that information based on our legitimate interests, and where we do not have compelling overriding grounds to continue to use your personal information; or
2. at any time, where we use your personal information to send you the newsletter or any other type of direct marketing, in which case it will no longer be used for that purpose, but may use it for another lawful purpose.
You are important to us, and so is protecting your personal information. We have high standards when it comes to collecting and using personal information. For this reason, we take any complaints we receive from you about our use of your personal information very seriously and request that you bring any issues to our attention.
Where you are communicating with us for the purpose of making a complaint, we will only use your personal information to handle, investigate and respond to the complaint and to check on the level of service we provide. Where the complaint is about a member of our team, we may have to disclose your identity to whoever the complaint is about. You may let us know that you don’t want information that identifies you to be disclosed and we will try to respect your request; however, it may not be always possible to handle a complaint on an anonymous basis.
If you are unhappy, you can also contact the Information Commissioner’s office to make a complaint directly by clicking the following link here. https://ico.org.uk/concerns
Updating this privacy notice
We keep our privacy notice under regular review in order to ensure that it properly reflects our use of personal information. This privacy notice was last reviewed on Tuesday 11th December 2018.
How to contact us
Please contact us if you have any questions about our privacy notice or information we hold about you:
Post: Data Protection Officer, Glenside Commercials Ltd, 18 Greenway, Bedwas House Industrial Estate, Caerphilly CF83 8DW
CONSENT (SALES AND MARKETING ONLY)
☐ I have read the Privacy Notice and give my consent for the purposes and processes as detailed below:
☐ I agree ☐ I do not agree
☐ I agree ☐ I do not agree