Who are we?
Our registered company name is Commercial Vehicle Contracts Limited and we trade only in the United Kingdom (UK) as Commercial Vehicle Contacts Limited; Commercial Vehicle Contracts; CVC and FleetsourceUK
What is our function?
We are a licensed credit intermediary to the automotive industry and we establish finance agreements for our customers through our business relationships with our portfolio of funding partners which are secured against cars and vans that we source for our customers from our franchised automotive retail partners
How can we be contacted?
You can write to us at our trading address which is The Landmark, 66 Sackville Road, Bexhill on Sea, East Sussex, TN39 3FA or you can telephone us on 01424 863456
Who regulates us for data protection purposes?
The data regulator in the United Kingdom is the Information Commissioner’s Office (ICO) who is responsible for the governance of Data Controllers and Data Processors operating in the UK under the Data Protection Act 2018.
Our ICO registration number is Z3597237
What is personal information?
Personal information that falls under the jurisdiction of Data Protection Act 2018 is any information that can be used to identify a living individual within the UK. This includes expression of opinion and data about you that is collated and stored electronically
Who owns your personal information?
You are the sole owner of your personal information, regardless of who you may give it to at any stage. The Data Protection Act 2018 recognises that the subject of the data is the ‘data holder’
What information do we collect from you?
The amount of information that we collect from you will depend on which of our services we discharge for you
• If you agree to receive a written quotation from us, then we will require the following information; your first name and surname; your personal title; your job title (if you are operating on behalf of an organisation); your e-mail address; your telephone number; your correspondence address
• If you place business with us then in addition to the above information, we will also require the following information; your marital status; your gender; your nationality; your date of birth; your home address where you are registered on the electoral roll; your status at the property (for example: owner with no mortgage; owner with mortgage; renting); the duration that you have resided at your current address and if less than five years, your address history for a five year period; (these details apply to customers who place business as a private consumer; as a registered Director of a limited company; as a registered Partner of a Partnership or Limited Liability Partnership and as a Sole Trader but do not apply to an individual operating on behalf of an organisation who is not in any of these categories); your bank account details; your current annual salary; any other income received by you; your total income and expenditure; your existing financial commitments; number of financial dependents; your occupation; your employer details such as name of organisation and address; your employment history for a five year period; a declaration from you of any likely change of circumstance during the term of the finance agreement that may affect your ability to meet the payment terms of the agreement; proof of identification which includes an approved photographic image of your present likeness (such as a UK driving licence photocard); two proofs of address which clearly display your name at your present address (such as a electric, gas or water bill) which are dated within ninety days of the date of submission for purpose (these details apply only to customers who place business as a private consumer and customers who are operating as a guarantor and are therefore ultimately responsible for meeting the payments terms of an organisation)
Why do we collect your information?
• The information that we collect from you in order to provide you with a written quotation is the minimum amount of information that we require to be able to send a quotation to you in your chosen format, and to be able to identify you as the recipient of the quotation should you wish to liaise with us in a written or verbal communication following receipt
• The information that we collect from you in order to transact business that you have placed with us is the reasonable and proportionate amount of likely information required by our partner finance companies to allow them to assess your circumstances or that of your organisation for credit assessment purposes. This information is then used by the partner funder as the basis of the finance agreement between you and them. We also need to pass an appropriate amount of information (enough information only to be able to identify you and your address) to our automotive retail partner so that delivery of the vehicle can be undertaken as part of our duties towards you
• In the event that we handle a complaint that you have made about us or one of our funding partners, we may need to make your details available to the Financial Conduct Authority as part of our annual regulatory reporting responsibility, so that they are able to investigate the circumstances and nature of the complaint should they decide it is appropriate to do so
• We will use your information to keep in touch with you and deliver important updates and contractual information to you throughout the term of the finance agreement
• We will use your information to deliver contract and fleet management services to you as is deemed necessary by the data controller and by you during the term of the finance agreement
• We will use your information and associated data within our business to monitor market conditions and consumer / customer trends to allow us to develop our understanding of the industry and monitor, amend and enhance our services accordingly
• We will use your information to keep in touch with you to inform you about any change to our services that may affect our duties towards you
How do we collect your information?
• For purposes of receiving a written quotation from us, the information that we collect from you may be in the form of a written statement of request from you to us via our online web portal; e-mail; social media platform or written letter, we may also collect this information from you via spoken word during a telephone conversation between you and us
• For the purposes of transacting business that you have placed with us, we will collect the initial information and any subsequently requested information from you in the form of a written proposal form that we will supply to you and that you must complete in full with accurate information to allow us to discharge our duties towards you on a fair basis. If you give your consent to do so, we are also able to collect any required information from you for this purpose via spoken word during a telephone conversation however in these instances we will always populate the proposal form with the information and submit it to you for authorisation, to ensure that you remain in full awareness of all information you have given
What is our status when we collect your information?
• If we supply a written quotation to you and any subsequent marketing material that we feel may be of interest to you, then we do so acting as a Data Controller under the Data Protection Act 2018 . This means that we decide how we use your information within our business and in a way that we feel will be of benefit to you
• When transacting business for you that you have placed with us, we do so acting as a Data Processor under the Data Protection Act 2018, as we will pass your information in a reasonable and proportionate manner to our funding partners (who will act as the Data Controller) and automotive retail partners as required to discharge our agreed duties to you
Will we sell, trade or give your information to anyone or any other organisation?
• At no time will we sell, trade or give any information that we hold about you to anyone or any other organisation for commercial gain
• At no time will we sell, trade or give any information that we hold about you to anyone or any other organisation in exchange for business services
• At no time will we sell, trade or give any information that we hold about you to anyone or any other organisation in exchange for present or future goodwill
• At no time will we behave in a manner which results in the information we hold about you being made available to anyone or any other organisation who does not possess a legitimate business interest in the information
• We will give your information in a reasonable and proportionate manner to our funding partners and automotive retail partners (which includes the manufacturer of the vehicle and their associated businesses) in the normal course of transacting your business
• We will give your information to another business that is providing marketing services to us to allow them to send information about us to you in your preferred format
• We will give your information to the Financial Conduct Authority in the event that we are required to do so by them, and in which case legal grounds for them to request this information from us will exist
• We will give your information to any legally recognised UK law enforcement agency in the event that we are required to so by them, and in which case legal grounds for them to request this information from us will exist
• In the event that we give your information to another organisation, then it must be the minimum amount of information required to allow them to perform their agreed function, and they must not use the information for any other purpose other than the intended and agreed purpose as defined between the organisation and us
What is our legal basis for processing your information?
• If we provide a written quotation to you at any time and this is the extent of our services discharged then we will process your information only with your consent
• If we supply marketing material to you that we feel may be of interest and therefore of benefit to you, via such communications as e-mail, via social media platforms or via spoken word during a telephone conversation, then we will process your information only with your consent
• In the event that we transact business for you that you have placed with us, then we will process your information having a legitimate business interest for doing so and in line with a contractual duty to be able to identify and contact you which exists between us and the funding partner to whom we have introduced you to
Is any information that we may collect from you treated as special information?
• All of the information that you give to us is important, and we will always keep every detail private and safe
• Our systems, processes and our behaviour will ensure that we meet this requirement at all times
• Some of the information that you give to us might be categorised as special data under the Data Protection Act 2018
• As a general rule we will not ask you for any special data
• We will only ask for this information in a proportionate amount from you where there is a requisite legal reason to do so, or when meeting the regulatory requirement placed on us to be able to establish whether a physical or mental vulnerability exists if base indicators are present or if disclosed directly to us by you
• Special data includes but is not limited to; trade union membership; professional body membership; genetic and bio-metric data; racial heritage; ethnic origin; religious belief; national Identifier; national insurance number; political sympathies; membership of organisations; psychiatric report; shotgun licence; medical report; medical history; offences including penalty charge notifications; criminal convictions
Will any other organisations give your information to us?
• Occasionally and in the normal course of transacting your business, partner organisations may give some of your personal data to us
• This is likely to be in the form of your name, telephone contact number, address and vehicle registration number or vehicle identification number (VIN)
• This information is likely to be given to us so that we are able to discharge our agreed duties to you
• The organisations likely to give your information to us are; funding partners; any business dealing with insurance related activity on your behalf; automotive retail partners; delivery agent partners; UK law enforcement agencies
• These organisations will only give your information to us either with your consent or because they are duty bound to give the information to us due to our legitimate business interests
• If you access our services via a price comparison website or any other web based portal on which we advertise or have a presence, then with your consent they will give your information to us so that we are able to discharge our duties to you as you have requested
Do you have a right of access to the information that we hold about you?
• You have a legal right of access at any time to all of the information that we hold about you • The route of access is called a Subject Access Request (SAR) under the Data Protection Act 2018
• You (or someone who has power of attorney for you) are the only person who can ask for your information held by us via an SAR
• You may in certain instances nominate (by writing to us with the details) another person or group of people (such as a solicitor or accountant) to be able to access your information via an SAR
• If you exercise your right to see your information held by us via an SAR, then we must make all information available to you including any information stored on our electronic business system; any information stored in a manual file; any information written about you in any other durable medium; any information that can be used to identify you held in a recorded telephone conversation
• A SAR can be submitted to us in writing at our office address detailed in this Privacy Notice or verbally by you (in which case we will need to take appropriate measures to confirm your identity which may involve us calling you by return on one of the telephone numbers that we hold for you)
• A written SAR should be signed by you and dated
• A written SAR should display your correspondence address
• A written SAR should display your telephone number so that we are able to call you by return and check the validity of the SAR with you before responding
• We must and in line with our responsibilities towards you under the Data Protection Act 2018, respond to your SAR within one month of receipt of it from you
• This is to allow us time to check all of our records (including recorded telephone conversations) and compile them to send to you
• We will not charge you for compiling this information as a result of the SAR
• If you make a number of SAR’s in a time frame that renders it difficult for us to discharge this duty to you without causing us an undue amount of work, then the ICO has issued guidance that we will be able to charge a fee to you that is proportionate and reasonable for these instances. If this arises then we will charge a fee to you of £25.00 + VAT for each SAR that you make within a three month period of a previous SAR response to you by us
• We will make the information available to you in the form of an e-mail which will include a digital link to any telephone conversation that can be used to identify you
• If you submit a SAR and in meeting our obligation to you, it will result in us making personal information about another individual available to you, we will consult with the ICO to make an informed decision about whether it is possible for us to proceed with your request. In these circumstances we will write to you to advise the outcome and will supply to you any justification for the decision based on the ICO guidance received
How long will we hold your information for?
• When you submit information to us for the purposes of receiving a written quotation and / or to receive marketing material from us, we will hold your information until such time as you withdraw the consent for us to do so
• When you submit information to us for the purposes of transacting business for you, then we will hold the information for a minimum of the term of the finance agreement and up to three years following the termination of the finance agreement to allow us to process any retrospective complaint or enquiry about the agreement that you, the Financial Conduct Authority or a UK law enforcement agency may make
What action can you take if you are not satisfied with how your information is processed?
• In the event that you feel unfairly treated by us in the course of processing your information, you are able to complain to us and we will investigate your complaint formally and on a fair basis. To complain, please write to us at the address denoted on this Privacy Notice and we will respond with an acknowledgement of receipt of your complaint, and we will supply a copy of our formal complaints procedure to you which detail response times
• If you feel that we have not reached the right outcome following your complaint, and it has not been resolved to your satisfaction, or if you feel that we have breached our responsibilities under the Data Protection Act 2018, then you can lodge a complaint with the ICO (telephone number 0303 1231113) who will investigate the complaint and will arrive at an adjudication
Are you able to ask for incorrect information to be amended?
• If any element of the information that we hold about you is either inaccurate, out of date or incomplete, then as the data holder you have a right under the Data Protection Act 2018 to request that this is updated and / or completed so that the information is accurate and complete
• In order to update or amend information, please contact us at the address denoted on this Privacy Notice and supply to us the accurate or updated information
• We will need to verify the validity of the request in these instances and so we will contact you on a telephone number that we hold for you
• We must update or amend your information without delay and within one month of receipt of receiving the information from you in line with our obligations under the Data Protection Act 2018
• We will not charge you for carrying out an information update / amendment
What happens to your information if our business is sold or transferred to a new owner?
• A business may expand by organic growth and also through merger or acquisition
• If we merge with another business or if we are bought by another business, one of the business assets that will be transferred is the information / data that we hold under the Data Protection Act 2018
• In all cases of merger or acquisition, a condition of the agreement will be that the new entity or parent entity will abide by this Privacy Notice at all times for our existing customers for the duration of the existing term of finance
• Any future agreement between you and the new entity or parent entity will be subject to the prevailing Privacy Notice in place at the organisation
Will the details in this privacy notice change at any time?
• By constructing and abiding by a thorough and robust privacy notice, we are confident that future amendments and changes to the document will be minimal
• We must however amend this privacy notice with updated information as required under the Data Protection Act 2018
• We will also amend or update this privacy notice with information applicable to you if we change or update our data controller or data processor procedures at any time
• In the event that we amend or update this privacy notice for any reason, we will write to you to inform you of the update or amendment, and we will include a copy of the updated document in the communication
How is your information stored?
Your information can be stored by us using one of four possible formats
• The first is a digital recording of a telephone conversation between you and us. The telecommunications system that we use meets the requisite UK security and privacy regulation for such systems and digital recorded files are only available to authorised staff within our business via a password protected online portal, and the system operator for maintenance and legal purposes
• The second is an e-mail thread between you and us. The e-mail operating system that we use conforms with the necessary UK legislation for security and privacy for such systems. All operators of the system within our business have a unique user login and password to access the system and are only able to access e-mail threads which they have been party to. The system operator has access to our e-mail directory for system maintenance and legal purposes
• The third is a written letter from either you or us. As a business we recognise that the most secure way to store information is to protect it to the greatest degree possible. Therefore if you request written correspondence from us in the form of a letter, or if you send a letter to us, we will scan the letter in its entirety along with any other associated information and will store it as a PDF file in your personal or your organisation’s secure data file on our secure, password protected and encrypted business system. After being scanned, the original letter will be posted to you if we produce it, and if you produce the letter it will along with any associated information be destroyed immediately by category DIN 5 shredder
• The fourth is a data entry in your unique customer file on our purpose designed and built business system. Data entry includes word, numeric and electronic data file entries and uploads. Your information is stored against your customer file only, so that it can be identified easily and will not become compromised with another data holder’s information. Our business system is password protected and each user has their own personal login details so that we can monitor access to the system and the files that are accessed. In addition to this the business system benefits from encrypted coding to ensure that security integrity is practically impossible to compromise. The system is officially certified as secure by Sectigo
• The data held on our business system is backed-up for security purposes by a daily data download to an independent server at an approved global data centre location in London, UK, where the data is held for a two week period
How do I withdraw consent for you to control my information for marketing purposes?
• You can write to us at the address denoted in this Privacy Notice to request that we remove your information for marketing purposes
• If we receive such communication from you, then we will action your request within seven calendar days of receipt of your request
• If you withdraw consent for us to control your information for marketing purposes, please be aware that this will result in us being able to communicate with you about products and services that may be of interest to you in the future
• You may also unsubscribe from receiving any marketing information from us by accessing the ‘unsubscribe’ link that is displayed on all of our digital marketing communication
• If we receive such communication from you, then we will action your request within seven calendar days of receipt of your request
• In order to make our website work properly, we sometimes place small data files called cookies on your device
• Most websites operate in this way
• A cookie is a small text file that a website saves on your computer or mobile device when you visit the website
• It enables the website to remember your actions and preferences such as login, language, font size and other display preferences over a period of time, so that you do not have to keep re-entering them whenever you come back to the site or browse from one page to another
• Cookie related information is not used to identify you personally and the pattern data is fully under our control
• You can control and / or delete cookies if you wish
• For details please see aboutcookies.org
• You can delete all cookies that are already on your device and you can set most browsers to prevent them from being placed
• If you do this you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work as they require cookies to do so
• There is a facility on our website to enable or disable all non essential cookies created by this site
• Please click on the cookie options link at the bottom of each page to access the settings
• This website uses Google Analytics to help analyse how users use the site
• The tool uses “cookies,” which are text files placed on your computer, to collect standard Internet log information and visitor behaviour information in an anonymous form
• The information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity
• We will never (and will not allow any third party to) use the statistical analytics tool to track or to collect any Personally Identifiable Information (PII) of visitors to our site
• Google will not associate your IP address with any other data held by Google
• Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user
• We will not associate any data gathered from this site with any Personally Identifiable Information from any source, unless you explicitly submit that information via a fill-in form on our website
• We use Hotjar to improve the user experience on our websites
• Hotjar collects anonymous usage information from our website, including the pages you visit
• Hotjar does not collect form submissions or any personal information