Butlers Vehicle Solutions Ltd
3 Chillington Way, Norton Heights, Stoke on Trent ST6 8GJ
are committed to protecting and respecting any personal information you share with us.
This statement explains what types of information we collect from you, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us.
The contents of this statement may change from time to time so please check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of these changes.
The GDPR applies to ‘controllers’ and ‘processors’ of personal data. A controller determines the purpose and means of processing personal data. A processor is responsible for processing the personal data on behalf of a controller.
Butlers Vehicle Solutions Ltd are the company responsible for the processing of your personal information (data controller). We will ensure that all contracts with third party service providers are compliant with the GDPR and that personal data shared with third parties for the purposes of delivering products and services is treated appropriately.
Should you have any queries regarding the data controller please contact us on 01782 536007 or by email to firstname.lastname@example.org.
The Information we collect
We collect information about you when you engage with us either through our call centre, our website, other digital platforms or our partners. Some of this information does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you). The information we collect includes some or all of the following:
- Your personal details including name, date of birth, address including previous address history, driving licence details, passport number and contact details
- Your employment information including previous employment history
- Your banking and financial information where you may provide it (including income, expenditure and previous credit history)
- Information about your lifestyle and home ownership
- Identifiers assigned to your computer or other devices, including your Internet Protocol (IP) address
- Details of communications between us (for example emails or call recordings)
- Any other information which you may provide to us
We will only process your personal information for marketing purposes where you have provided your consent. You can ask us to stop processing your personal information for marketing purposes at any time either by updating your preference in “GDPR – My Preferences” section on our website or by contacting us by email to email@example.com.
How we use this information and the legal basis for processing
We will only process information that is necessary for the purpose for which it has been collected. The legal basis of processing will vary depending the type of service you have requested and we have listed some examples of our processing activities below;
- We only offer services to customers aged 18 or over
- Administering your vehicle quotes and policies (as is necessary for performance of a contract between you and us and/or as is necessary for our legitimate interests)
- Carrying out anti-fraud and anti-money laundering checks and verifying your identity (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests)
- Assessing financial risks, including by carrying out credit reference checks and credit scoring assessments, (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests)
- Broking your finance agreement and any related services (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests)
- Using your payment details to process payments or refunds relating to a service provided by us (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests)
- Sending you information about your end of contract obligations and how to renew your vehicle hire agreement (as is necessary for compliance with our legal obligations)
- Communicating with you about your quotes and policies including responding to your enquiries (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests)
- Administering debt recoveries, where you owe us money under a contract or otherwise (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests)
- Undertaking market research and statistical analysis, including analysing your use of our website. This allows us to develop new, or improve existing, products and services (as is necessary for our legitimate interests)
- Fulfilling our obligations owed to a relevant regulator or authority (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests)
Our "legitimate interests" as referred to in this document include our legitimate business purposes and commercial interests in operating our business in a customer-focused, efficient and sustainable manner, in accordance with all applicable legal and regulatory requirements.
Automated Decisions and Profiling
We will never make automated decisions when processing your data nor will we use profiling techniques. However when processing your financial application, some of our third party service providers (i.e. financial service providers, etc.) do use semi-automated underwriting processes.
How do we share this information?
We do not sell your information to third parties, but we do work closely with third party suppliers who fulfil business activities for us. In these situations we will only share the information that is necessary for the third party to perform the processing activity it was provided for, such as;
- Third party service providers who support the operation of our business, such as IT and marketing suppliers, financial service providers, delivery companies, dealer groups and debt collection agencies (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests)
- Third party insurance providers (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests)
- Fraud prevention agencies and associations, (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests)
- Regulators and law enforcement agencies, including the police, the Financial Conduct Authority or any other relevant authority who may have jurisdiction (as is necessary for compliance with our legal obligations)
Some of these third parties may also be considered a data controller in respect of holding your personal data. In these cases, we will provide you with the privacy statements of those parties.
How we store your information?
We hold your information by the following methods listed below:-
- Paper format – in a secure location
- Electronic format – in a secure location and with a third party cloud storage providers
Although we use third party cloud storage providers we do not process any data outside of the EU, it is merely for storage purposes only. The third party cloud providers we use are Dropbox (US & EU), Google (US, EU & Asia), BT (EU), Fasthosts (UK), Mailchimp (US) & Calas Automotive Media Systems Ltd (EU).
How we store your information?
We will not hold your personal information for any longer than is necessary. If you are a customer or otherwise have a relationship with us we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship. In any event, the retention period will be the statutory retention period unless there is a further legal or regulatory requirement to do so.
As a customer we will retain your information (paper & electronic) formats for a period of 5 years after your finance agreement expires. This is due to governing bodies (i.e. HMRC, Financial Conduct Authority, etc.) that may require us to provide some of your information for audit purposes
We will destroy all of your information (paper and electronic formats) in a secure manner.
How can you manage the information we hold about you?
Under the data protection act you have certain rights in relation to the data we hold about you. Under GDPR these rights are extended and listed below;
- To obtain access to, and copies of, the personal information that we hold about you
- To require that we cease processing your personal information if the processing is causing you damage or distress
- To require us not to send you marketing communications
- To require us to erase your personal information
- To require us to restrict or object to our data processing activities
- To receive from us the personal information we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal information to another data controller.
- This is commonly known as “your right to data portability”
- To require us to correct the personal information we hold about you if it is incorrect
Please note that these rights may be limited by data protection legislation, and we may be entitled to refuse requests where exceptions apply.
How to erase, restrict or object to our processing of your personal information?
As at data subject you have the right to withdraw consent at any time. In certain circumstances you are entitled to restrict or ‘block’ the processing of your personal data, or to object to the processing of your personal data. From 25th May 2018, in certain circumstances you will also be entitled to have your personal data erased (also known as a “the right to be forgotten”). This will include the personal data that we hold on you and the data that we disclose to our third party providers (see “How do we share this information” above).
The circumstances in which you can exercise these rights include:
- Where you consented to us processing the personal data, and want to withdraw that consent
- Where your personal data is no longer needed for the reason it was collected – i.e. when the contract between us has expired
- Where you contest the accuracy of the personal data that we hold on you, and require us to restrict any further processing until the accuracy of the personal data has been verified Where you object to us processing your personal data and there is no overriding legitimate interest for us to continue processing your personal data Where your personal data is being unlawfully processed and you require us to restrict or erase your data
- Where you need us to restrict the personal data in order to establish, exercise or defend a legal claim
- Where your personal data needs to be deleted in order to comply with a legal obligation
Please bear in mind the below:
- Where you have entered into a contract with us, we need to manage and apply that contract. We also have a legitimate interest to continue processing your personal data. The Financial Conduct Authority also requires us to hold records for a certain period of time. This means that in these instances we will be unable to erase or restrict your data
- We only obtain your consent for our marketing activities, and you can you easily change your preferences at any time either in the “GDPR - My Preferences” section on the website, or by notifying us by email to firstname.lastname@example.org
How to complain about how we process your personal information
If you have a complaint regarding any aspect of how we handle your personal information, please write to us at the above address or email to email@example.com. If you are still not satisfied with the outcome of your complaint, you may write to the Information Commissioner's Office at the following address:
Information Commissioner's Office
You can also contact the Information Commissioner's Office using their online form: https://ico.org.uk/global/contact-us/email/