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Privacy Policy

You can find a copy of our Data Privacy Notice here.

Data Privacy Notice

Data Protection Policy

Introduction

Car4leasing needs to gather and use certain information about individuals.

These can include customers, suppliers, business contracts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the

company’s data protection standards – and to comply with the law. Why this policy exists This data protection policy ensures Car4Leasing:

• Complies with data protection law and follow good practices
• Protects the right staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of data breach
Data Protection Law

The Data Protection Act 2018 describes how organisations – including Car4Leasing must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by five important principles. These say that personal data must:

1. Lawfulness
2. Fairness and Transparency
3. Purpose Limitation
4. Data Minimisation
5. Accuracy
People, risks and responsibilities

Policy Scope

This policy applies to:

• The head office of Car4Leasing
• All branches of Car4Leasing
• All staff and volunteers of Car4Leasing
• All contractors, suppliers and other people working on behalf of Car4Leasing

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• …plus any other information relating to individuals

Data Protection Risks

This policy helps to protect Car4Leasing from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with Car4Leasing has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with its policy and data protection principles.

However, these people have key areas of responsibility:

• The board of directors is ultimately responsible for ensuring that Car4Leasing meets its legal obligations.
• The Data protection officer (Barry Mainstone), is responsible for:

o Keeping the board updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an agreed schedule.
o Arranging data protection training and advice for the people covered by this policy.
o Handling data protection questions from staff and anyone else covered by this policy.
o Dealing with requests from individuals to see the data Car4Leasing holds about them (also called ‘subject access requests’).
o Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
• The IT Manager, Barry Mainstone, is responsible for:
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is functioning properly.
o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
• The Marketing Manager, Barry Mainstone, is responsible for:
o Approving any data protection statements attached to communications such as emails and letters.
o Addressing any data protection queries from journalists or media outlets like newspapers.
o Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General Staff guidelines

Please refer to Data protection responsibilities for Staff.

Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT Manager or Data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to the data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked filing cabinet
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and firewall.

Data UsePersonal data is of no value to Car4Leasing unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data Accuracy

The law requires Car4Leasing to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Car4Leasing should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional sets of data.
• Staff should take every opportunity to ensure data is updated. For instance by confirming a customer’s details when they call. • Car4Leasing will make it easy for data subje
cts to update the information Car4Leasing holds about them. For instance, via the company website,
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject Access Requests

You have the right to request access to a copy of the personal information that we hold about you. This is also known as a ‘Subject Access Request’. This information is provided to you free of charge however, we can refuse to respond or charge a ‘reasonable fee’ of £10 inc. VAT when a request is manifestly unfounded, excessive or repetitive.

We will provide this information in a structured, commonly used and machine readable form such as a CSV file. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.

If you would like to submit a Subject Access Request, please contact our Data Protection Officer in writing or by telephone to:

Data Protection Officer
Car4Leasing
2 Hitchin Road
Henlow,
Bedfordshire,
SG16 6BB

Telephone: 01462 817457

Email: barry@car4leasing.co.uk

We keep our data protection policy under regular review and we will reflect any updates within this notice. This privacy notice was last updated December 2021

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without consent of the data subject.

Under these circumstances, Car4Leasing will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information

Car4Leasing aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used
• How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

(This is available on request. A version of this statement is also available on the company’s website).

Subject Access Requests You have the right to request access to a copy of the personal information that we hold about you. This is also known as a ‘Subject Access Request’. This information is provided to you free of charge however, we can refuse to respond or charge a ‘reasonable fee’ of £10 inc. VAT when a request is manifestly unfounded, excessive or repetitive. We will provide this information in a structured, commonly used and machine readable form such as a CSV file. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. If you would like to submit a Subject Access Request, please contact our Data Protection Officer in writing or by telephone to: Data Protection Officer Car4Leasing 2 Hitchin Road Henlow, Bedfordshire, SG16 6BB Telephone: 01462 817457 Email: barry@car4leasing.co.uk We will response to your request without delay and at the latest, within 28 days of receipt of your request.

Right to be forgotten

An individual has the right to have their personal data erased if: The personal data is no longer necessary for the purpose an organisation originally collected or processed it.

You can make a request to be forgotten and have your data removed as follows

In Writing:
Data Protection Officer
Car4Leasing
2 Hitchin Road
Henlow,
Bedfordshire,
SG16 6BB

Telephone: 01462 817457

Email: admin@car4leasing.co.uk

Once received the information will be looked at and actionable within 1 month (Unless the request is complication in which case we reserve the right to take 2 months). There are scenarios whereby the right to erasure does not apply and we would notify you of that if this is the case.





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