Customer Privacy Notice
1.0 - Consent
1.1 - For the details which we hold on a customer we will provide the customer with a consent form for them to sign giving us their permission to hold this data.
1.2 - When a customer phones in to book a test drive a consent form does not need to be signed. The customer’s details, only their name and a contact number, should be put in the Outlook diary for the day of the appointment. The customer is not to be contacted for anything other than the test drive which they are booked in for.
1.3 - Sales customers will have to provide consent when taking a test drive as at this stage we take a copy of their driving licence.
1.4 - A second consent form will be signed if a vehicle is purchased. This will be to allow us to contact you in respect of servicing your vehicle and manufacturer recalls.
1.5 - For service customers a consent form is signed when the customer comes into the dealership. An appointment will be made where the customer provides their name, phone number and registration as well as notifying us of the reason for the booking. These details are not stored and are only entered into an excel spreadsheet for our service management system.
1.6 - At any time after consent has been given the customer has the right to revoke this consent. In order to do this please contact either Ben on email@example.com or Sharon on firstname.lastname@example.org. These requests are to be in writing and are to include your name and a contact number as well as the details which you would like for us to remove from the database.
2.0 - Emails
2.1 - All emails received, including any attachments, are monitored by Microsoft. Please note views of the author may not necessarily reflect those of Brook & Churches Bros Ltd T/A Gatwick Group or its Directors.
2.2 - If we take an email address to send over requested quotes the email address will only be used for this purpose and will not be saved to the database.
2.3 - All emails sent from a Gatwick Group account are saved in the ‘sent items archive’.
3.0 - Telephone
3.1 - For payments being made over the phone the card number is put directly into the card machine at the time of the phone call, the details are not recorded.
3.2 - Any telephone conversations made to or from us are not recorded
3.3 When a booking for a test drive is made a contact number will be taken so we can contact if there are any changes. The number is only used for this purpose and will not be put towards marketing. It will not be stored but will be attached to the appointment in the calendar.
3.4 When a service booking is made we will take the customers telephone number where it is stored in Access. This is so we can contact you regarding your appointment.
4.0 Data Processors
4.1 - In order to hold data on customers we use databases. These are run by external third parties.
4.2 - Sales customers information is held on Reef, the data held is their name, address, contact information and the details of the vehicle they enquire about from us. The date of birth of a customer who orders a vehicle is also in here for registering the vehicle. If a vehicle is being part exchanged its details are also held here. We also log anything of importance here, such as any correspondence with the customer.
4.3 - Vital Software provide us with service reminders, in order for them to do this we need to provide them with the details of the vehicle and previous servicing as this allows them to notify the customer of any works due to their vehicle and ensure it gets to them at the correct intervals.
4.4 - The service department use Access as their main database, this holds a customer’s name, address, email, contact number and vehicle details as well as noting who the salesman was if purchased from us and whether they part exchanged a vehicle. Under the vehicle details is information on any work which we have done on the vehicle.
4.5 - The parts and accounts department also use Access as their database, however the only information which they store are the customers details contact information. No payment information or bank details are stored on any database.
5.0 - License details
5.1 - Due to our insurance policy when a customer has a test drive we need to take a copy of their licence. This copy is kept in a secure file in the Sales Managers office. This is kept on record for one year before it is shredded.
5.2 - If a customer purchases a vehicle a copy of the driving licence is kept in their sales file for 7 years.
6.0 - Finance
6.1 - Finance companies need to know what vehicle they are providing finance for as this is how they decide the residual value they are happy to set against a vehicle.
6.2 - When applying for finance the finance provider will ask for your current address as well as the previous 3 years. This information is then submitted to the finance company and kept in the Sales Administration office. Once the vehicle has been delivered this is then moved into archives where it is kept for 7 years.
6.3 - When taking out finance the customers contact details are given to the finance company so they can make contact with the customer regarding the finance.
6.4 - When applying for finance the customer needs to provide their bank details. This is then submitted to the finance company and until the vehicle has been sold is kept in the Sales Administration office. Once the vehicle has been delivered this is then moved into archives where it is kept for 7 years
6.5 - When a vehicle is ordered on finance a copy of the customers licence is sent to the relevant finance company so they can run background checks and confirm the finance is being taken out by the correct person.
6.6 - When applying for finance the customer must complete questions on their level of affordability for monthly payments. This information is then submitted to the finance company and kept in the Sales Administration office. Once the vehicle has been delivered this is then moved into archives where it is kept for 7 years before it is professionally added.
6.7 - When applying for finance the customer must complete certain questions for the finance company, one of these sections is their employment history covering the previous 3 years employment. This information is then submitted to the finance company and kept in the Sales Administration office. Once the vehicle has been delivered this is then moved into archives where it is kept for 7 years before it is professionally shredded.
7.0 - Insurance
7.1 - GAP insurance needs to be registered to the vehicle, therefore where the insurance is taken out we share the required details.
7.2 - When purchasing any vehicle from Gatwick Group there is the option to take out free 7 day insurance, where this is taken out we need to provide the vehicle details in order for the insurance to be valid.
8.0 - G3 Glasscoat
8.1 When registering a vehicle for G3 Glasscoat we provide the company with customer contact details, address as well as the details of the vehicle.
8.2 This allows for the protection to be registered to the vehicle which validates the guarantee.
9.0 - Automotive Compliance
9.1 When a vehicle is purchased we must put customer and vehicle information into Automotive Compliance which ensures we are complying with legal procedures, governed by the FCA, and that the customer is receiving the correct information.
10.0 - Vehicle details
10.1 When a customer buys a new plug-in vehicle they are able to get a free wall mounted home charging unit provided by Charge Master, we provide them with the vehicle details so they are able to arrange the installation for customers.
10.2 A Hire Purchase Inspection (HPI) shows if a vehicle is on the finance register, meaning it has finance outstanding. It also tells us whether the vehicle has ever been a write off. These are essential for us to know as they can affect the price at which a part exchange occurs.
10.3 - Automotive Compliance take vehicle details so they are able to advise whether a service plan is needed for the vehicle.
10.4 - Automated First Registration and Licensing (AFRL) is where we register a vehicle. Any new vehicle needs to be put into this system, with the details of the vehicle and the owner being supplied in order to register the vehicle.
10.5 - In order to claim a vehicle with low emissions the details need to be submitted to the Office for Low Emission Vehicles (OLEV), they then return a grant confirming the low emission vehicle.
10.6 Electronic Vehicle Health Check (EVHC) are carried out on every vehicle which comes into the garage, this is able to provide a condition report and make us aware of any defects to the vehicle, which in turn we pass back to the customer.
11.0 - Sharing of Contact details
11.1 - Customers with a hybrid vehicle have their contact details are shared with Charge Master so they are able to get in touch with them to book them in for a fitting of charging units.
11.2 Where alternative transport is provided by a hire company the contact details of the customer are provided to them for insurance purposes.
12.0 - Customer address
12.1 - When registering a vehicle with the DVLA we provide them with the customer’s details so they can send the customer any relevant information, such as notices for any speeding violations.
13.0 - Date of birth
13.2 - When a vehicle is registered with the DVLA in order to register the keeper we must provide them with the customers date of birth.
13.2 - If a customer purchases a vehicle through finance the finance company require their date of birth, which is kept in the vehicles sale folder and is kept for 7 years.
14.0 - Card Details
14.1 - When a purchase of a vehicle is made we take a deposit to secure and order the vehicle. This can be done with a credit or debit card as well as with cash. For those who use cards a copy of our receipt is kept in the file for the vehicle.
14.2 - When a customer pays the service department for work done to their vehicle by card payment our copy of the receipt is kept.
14.3 - Any purchases made from the parts department using a card also follow this same policy.
14.4 - A merchant copy has the card number and expiry date on it, however there are no details of the customers pin or of the security code on the back of the card.
14.5 - These receipts are compiled through the day and at the end of the day is taken to the accounts department where they are stored in a locked cupboard. It is then used to match against transactions which we receive so we can confirm payments are received.
14.6 - These receipts are stored securely in the Accounting department for 7 years.
14.7 - Copies of receipts of payments are kept in the file for a vehicle sale, and once the vehicle has been handed over to the customer is then archived securely for 7 years.
15.0 - Bank details
15.1 - We take a customer’s bank details when they apply for a service plan so that a direct debit request form can be sent to the customer’s bank.
15.2 - When taking out GAP insurance with monthly payments bank details are taken so we can send of a direct debit request which can be sent to the customer’s bank.
15.3 - When a refundable deposit is taken for a vehicle a member of the sales team can refund up to £250, anything larger than this will be done by the sales manager. We ask you bring the card you made the payment on and proof of identity.
15.4 - Where finance is taken out the customers bank details have to be provided, these are kept in the sales file for 7 years.
15.5 - We hold bank details for accounts payments on Sage for our monthly accounts.
16.0 - Tax information on vehicle
16.1 - This is provided to us by the manufacturer which we then pass on to the customer so they can tax their vehicle
17.0 - Motability
17.1 - Motability customers must provide their national insurance number, this is so checks can be carried out on their eligibility. These details are only shared with the Department for Working Pensions.
17.2 - When submitting an order form to Motability we have to notify them of the customers details as well as the vehicle which they are ordering.
17.3 - When we take an order for a Motability vehicle we take a copy of a letter of conformity from the Department of Working Pensions to show we are complying with the Motability programme. This copy is kept in the Sales file for the vehicle for 7 years.
17.4 - A copy of the customers driving licence needs to be submitted for identity and eligibility checks, we also take a copy of the second party going onto the insurance.
17.5 - Two proofs of address must also be taken to back up the letter of conformity.
17.6 - Motability provide the information we give them to their partners which allows for the deals to go through, they need to have the vehicle details in order to arrange the insurance of the vehicle and the taxing. We provide this information to them and they distribute it as necessary.
18.0 - Service history
18.1 - When a vehicle is brought in part exchange if it has a service history with it this will be passed on with the vehicle. Where possible details which have remained behind from previous customers are censored.
18.2 - Service customer’s service history is recorded on our internal database which is not shared. This is for our own use so we have a record of any previous reports or faults with a vehicle.
18.3 - Service history is provided to Vital Software who carry out our service reminders, this is to ensure a customer is not sent reminders relevant to their vehicle and so we know what the vehicle is due at its next service.
19.0 - Number plates
19.1 - When a new number plate needs to be printed for a new vehicle a copy of the vehicles registration form needs to be taken for the DVLA records.
19.2 - When a service customer needs a new or additional plate printing a copy of the driver’s license, the V5 form for the vehicle and a utility bill as proof of the registered owner is also taken for security purposes. This is kept in a file in the Human Resources department for 3 years.
20.0 - Body Shops
20.1 - When a vehicle needs to go to the body shop we provide them with a vehicles description and registration number so they are able to identify the vehicle which we are sending them.
20.2 - We also provide them with the customers contact details as these details can be needed for any warranty claims.
21.0 - MOT
21.1 - The MOT’s we carry out are done by a third party. In order for them to carry these out we need to provide them with a vehicle description and registration number.
21.2 - We also have to provide them with the contact details of the customer and their address as is their standard procedure.
22.0 - Stapleton Tyre Services
22.1 - In order to get the correct tyres for a vehicle we provide the registration to STS so they can check the requirements and provide us with a list of suitable options.
23.1 - We share vehicle details with the Manufacturer of the vehicle as this means they are able to link the chassis with the new registration of the vehicle. This also allows for them to tell dealerships what service requirement a vehicle has.
23.2 - When a customer purchases a vehicle we give their details to the manufacturer so they are able to send the customer information on safety recalls and campaigns
23.3 - The customer contact and vehicle details are used by the manufacturer to perform a Customer Satisfaction Inspection (CSI) to ensure a high level of service is constantly being adhered to.
24.0 - Warranty
24.1 - Every vehicle comes with a warranty, however to validate this warranty we need to provide the manufacturer with the vehicles registration and the details of the owner.
24.2 - Vehicles have the ability to have their warranty extended, in order for the customer to receive this offer we provide their contact details to the Manufacturers Extended Warranty department.
24.3 - In order to ensure the offer made to the customer is relevant to their vehicle we also provide the Extended Warranty the vehicles registration number.
25.0 - Service Plans
25.1 - In order to set up an internal service plan we have the customer fill out a form which provides their bank details. This is then sent to our bank in order to set up standing orders.
25.2 - For manufacturer service plans we provide customer and vehicle details to the manufacturer and they then provide this to the external companies which run their service plans.
26.0 - Complaints
26.1 - We always aim to meet high standards and any complaints are taken seriously. When a complaint is made we create a file containing the details of the complaint. Personal information will be used in this file and the name of the complainant will be disclosed to the subject of the complaint.
26.2 - The complaint file will be kept in line with our data retention and shall be kept for 7 Years. This means the information from the complaint will be available for this period of time after the complaint has been settled. The file will be kept in a secure environment with access being restricted to the Human Resources department and Management.
27.0 - Access to Information
27.1 - We attempt to be as open as possible in terms of giving customers access to their personal information. An individual can discover if we hold any personal data on them through a Subject Access Request.
27.2 - To request for any personal data please put a request in writing to either Ben Brookbank on email@example.com or Sharon Brook on firstname.lastname@example.org. Alternatively post can be sent to BCL House, Gatwick Road, Crawley, West Sussex, RH10 9AX.
28.0 - Individuals Rights
28.1 - Right to be Informed
28.1.1 We operate a transparent policy which allows you, our customer, to see how we use personal data
28.2 - Right of Access
28.2.1 Individuals have the right to access personal data and any supplementary information we hold on them. This access allows customers to be aware of processing and to verify the lawfulness of any processes
28.3 Right to Rectification
28.3.1 Customers have the right to have any data we hold on them rectified if it is inaccurate or incorrect
28.4 - Right to Erasure
28.4.1 Individuals have the right to request personal data be deleted where there is no compelling reason for the processing of the data
28.5 - Right to Restrict Processing
28.5.1 An individual can ‘block’ the processing of their data, which permits the storing of the data but not the processing.
28.6 - Right to Data Portability
28.6.1 Allows individuals to obtain and reuse their personal data for their own purposes. It allows the customer to move, copy or transfer personal data from one It source to another without hindrance or usability.
28.7 - Right to Object
28.7.1 Individuals have the right to object to the processing of data for direct marketing and for the purpose of scientific research and statistics
28.8 - Rights relating to Automated Decision Making including Profiling
28.8.1 - Customer have the right to be safeguarded against the risk of a potentially damaging decision being made without human intervention
If you wish to speak to a member of staff about these rights please contact Sharon Brook in Human Resources. We ask that any contact is made in writing, either through post to Gatwick Group, BCL House, Gatwick Road, Crawley, West Sussex, RH10 9AX or via email to email@example.com
29.0 - Legitimate Interest
29.1 - For customers who have purchased a vehicle with us we have a ‘legitimate interest’. This means we will contact you regarding the servicing, MOT and recalls regarding your vehicle. This can also mean we need to disclose your details to a third party in regard to our legitimate interest, such as contacting the DVLA with your details to register the vehicle for you.
29.2 - Upon visiting the dealership customers are given a consent form where they can opt-in and opt-out of receiving communications from us.