Privacy policy.
The Motoring Studio is committed to processing personal data about its customers in ways that comply with its legal and regulatory obligations, and to being clear with our customers about what we do with their personal data. We respect and value the privacy of everyone who enquires about or uses our services, and will only collect and use data in ways that are useful to you in arranging and delivering the services you request, and in a manner consistent with your rights and our obligations under the law.
The purpose of this document
The primary purpose of this privacy policy is to ensure The Motoring Studio complies with its information disclosure obligations under data protection legislation. In the UK, that includes the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Failure to comply may lead to civil liability and/or criminal law penalties.
Assistive Solutions Ltd, trading as The Motoring Studio, is referred to as “we”, “us” and “our” unless specified otherwise.
General Data Protection Regulation
In collecting and using data, we must comply with the requirements of the UK GDPR, which governs the processing of personal data. We are the Data Controller under the legislation, and our Data Protection Officer can be contacted at contact@motoring.studio. The personal data you provide to us when you enquire about, book or hire a vehicle is held securely by us and will be treated confidentially and with sensitivity, so that our commitments to you can be fulfilled.
Data protection principles
We are committed to processing data in accordance with our responsibilities under the UK GDPR.
Article 5 of the UK GDPR requires that personal data shall be:
Processed lawfully, fairly and in a transparent manner in relation to individuals;
Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of the appropriate technical and organisational measures required by the UK GDPR in order to safeguard the rights and freedoms of individuals; and
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
General provisions
This policy applies to all personal data processed by us.
The Responsible Person shall take responsibility for our ongoing compliance with this policy.
This policy shall be reviewed at least annually.
We shall remain registered with the Information Commissioner’s Office (ICO) as an organisation that processes personal data.
Lawful, fair and transparent processing
To ensure our processing of data is lawful, fair and transparent, we shall maintain a Register of Systems.
The Register of Systems shall be reviewed at least annually.
Individuals have the right to access their personal data, and any such requests made to us shall be dealt with in a timely manner.
Lawful purposes
All data processed by us must be processed on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
We shall note the appropriate lawful basis in the Register of Systems.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available, and systems will be in place to ensure such revocation is reflected.
Data minimisation
We shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
We will only collect the data required to respond to your enquiry and to arrange and deliver any hire, including driver approval, insurance and identity checks, and to fulfil our obligations for the agreed length of any contract.
Accuracy
We shall take reasonable steps to ensure personal data is accurate.
Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
Individual’s rights
Under the UK GDPR, we acknowledge the following rights of the individual in respect of any personal data that we hold:
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
The right not to be subject to automated decision-making, including profiling
Archiving and removal
To ensure that personal data is kept for no longer than necessary, we shall put in place an archiving policy for each area in which personal data is processed, and review this process annually.
The archiving policy shall consider what data should or must be retained, for how long, and why.
Security
We shall ensure that personal data is stored securely using modern software that is kept up to date.
Access to personal data shall be limited to personnel who need access, and appropriate security shall be in place to avoid unauthorised sharing of information.
When personal data is deleted, this shall be done safely so that the data is irrecoverable.
Appropriate back-up and disaster recovery solutions shall be in place.
Breach
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, we shall promptly assess the risk to people’s rights and freedoms and, if appropriate, report this breach to the ICO (more information on the ICO website).
Contact us
To exercise any of your rights, or to ask about this policy, contact: Assistive Solutions Ltd, trading as The Motoring Studio, 160 Dalston Lane, London, E8 1NG · contact@motoring.studio.