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 2. Privacy Policy


PRIVACY POLICY

Privacy and GDPR compliance


1. WHAT IS THE PRIVACY POLICY?

At TTC Group (UK) Limited we take privacy seriously and we are committed to
protecting it.

This policy explains when and why we collect personal information about
individuals, how this information is used, the conditions under which it may be
disclosed to others and how it is kept secure.

This policy may change from time to time so please check this page occasionally
to ensure that you’re happy with any changes.

This policy was last updated on 1st October 2021.


2. WHO WE ARE?

TTC Group (UK) Limited (company number 06214074) is the data controller in
relation to the processing activities described below. This means that TTC Group
(UK) Limited decides why and how your personal information is processed.

We also carry out processing activities on behalf of our clients as data
processor. Where this is the case our client will be the data controller in
respect of any personal data processing this way, and that client will decide
why and how your personal information is processed.


3. HOW WE COLLECT YOUR PERSONAL INFORMATION?

How we collect personal information from you
We may collect and process the following information about you:

Personal information you give to us

This is information about you that you give to us either by registering on one
of our client management systems, registering an expression of interest or by
entering information via our company website (including via our portals) or on
the site of one of our partners, when completing a quote request on behalf of an
organisation.

It may also come from the completion of a Fair Processing Declaration provided
to you on behalf of an organisation, entering answers into an audit or risk
excellence questionnaire, making a vehicle declaration, providing an insurance
certificate, or by corresponding with us by phone, email or otherwise and is
provided entirely voluntarily. The information you give us may include your
name, home address, email address, telephone number, driving licence details,
vehicle details, employer details, general driving information and health
information.

Personal information we collect about you

We may automatically collect the following information: with regard to each of
your visits to our site we may automatically collect technical information,
including anonymous data collected by the hosting server for statistical
purposes, the Internet protocol (IP) address used to connect your computer or
device to the Internet, browser type and version, time zone setting, browser
plug-in types and versions, operating system and platform, and in addition, if
you make use of our Compliance Management System (“CMS”) we will collect
username details and information regarding your use of the CMS which will be
used for statistical analysis, troubleshooting and compliance auditing.

Personal information we may receive from other sources

We collect the following personal information about you from the following
sources, which we use in the way described in the section below:

Source of personal information:

UKROEd

View Privacy Policy

The categories of personal information we obtain from these sources:

 * Name
 * Address
 * Date of birth
 * Email address
 * Telephone number
 * Driving licence number
 * Driving offence codes
 * Associated reference number

Source of personal information:

UK Police Forces

Please contact your relevant Police Authority to view their Privacy Policy

The categories of personal information we obtain from these sources:

 * Name
 * Address
 * Date of birth
 * Email address
 * Telephone number
 * Driving offence codes
 * Associated reference number

Source of personal information:

Magistrates Courts

Please contact your sentencing Magistrate Court to view their Privacy Policy

The categories of personal information we obtain from these sources:

 * Name
 * Address
 * Date of birth
 * Email address
 * Telephone number
 * Driving offence codes
 * Associated reference number
 * Offence information

Source of personal information:

Driver and Vehicle Licensing Agency (“DVLA”)

View Privacy Policy

The categories of personal information we obtain from these sources:

Driving licence details for DVLA issued Licence plus any convictions held:

 * Name
 * Address
 * Licence categories
 * Licence codes
 * Expiry dates
 * Unspent convictions
 * CPC dates
 * Tachocard dates

N.b. this is information that we process on behalf of our clients. Please see
Where acting as a DATA PROCESSOR for our clients for more details.

Source of personal information:

Driver and Vehicle Agency Northern Ireland (“DVANI”)

View Privacy Policy

The categories of personal information we obtain from these sources:

Driving licence details DVANI Ireland driving licences only:

 * Name
 * Address
 * Licence categories
 * Licence codes
 * Expiry dates
 * Unspent convictions

N.b. this is information that we process on behalf of our clients. Please see
Where acting as a DATA PROCESSOR for our clients for more details.

Source of personal information:

Driver and Vehicle Standards Agency (“DVSA”)

View Privacy Policy

The categories of personal information we obtain from these sources:

Vehicles registered in the UK

 * Vehicle registration details,
 * MOT expiry
 * VED expiry

Source of personal information:

Your organisation

Please contact your organisation to obtain a copy of your Privacy Policy

The categories of personal information we obtain from these sources:

The organisation may provide any of the following:

 * Name
 * Address
 * Email address
 * Employee ref
 * Date of Birth
 * Incident data
 * Courses undertaken

Source of personal information:

Our partners (third parties that act as resellers of our services)

Please contact your organisation to obtain a copy (they will be able to provide
a copy of the partner’s privacy policy)

The categories of personal information we obtain from these sources:

Partner may provide any of the following:

 * Name
 * Address
 * Email address
 * Employee ref
 * Date of Birth
 * Incident data
 * Courses undertaken

Source of personal information:

In-vehicle driver training provider

Please contact your organisation to obtain a copy

The categories of personal information we obtain from these sources:

The In-vehicle provider will supply:

 * Certificate of training completion
 * Report on training performance

Please see How we use your personal information for details of the purposes for
which we use the personal information we obtain from these sources, and the
legal basis on which we rely to process that information. The remaining
provisions of this policy also apply to any personal information we obtain from
these sources.


4. WHAT TYPE OF PERSONAL INFORMATION DO WE PROCESS ABOUT YOU?

We may process a range of personal information about you. To make it easier to
understand the information that we use about you, we have divided this
information into categories in the table below and provided a short explanation
of the type of information each category covers.

We process the following types/categories of personal information about you:

Personal:  Information included in this category
Contact information which can be used to address, send or otherwise communicate
a message to you.

Geo-location:  Information which contains or reveals the location of your
electronic device or your vehicle whilst undertaking our services.

Identification:  Information contained in a formal identification document or
other unique reference relating to you.

Special category:  Any information that allows us to address your special
requirements such as medical conditions or religious beliefs.

Monitoring:  Information relating to the surveillance or monitoring of your
driving activities.

Employment:  Your previous, current or future employment details.

Insurance:  Your insurance applications and any information relating to your
insurance claims, including vehicle details associated with the insurance.

Legal:  Information relating to legal claims made by you or against you or the
claims process.

Correspondence:  Information contained in our correspondence or other
communications with you about our products, services or business.


5. HOW WE USE YOUR PERSONAL INFORMATION?

Where you have provided CONSENT

We may use and process your personal information where you have consented for us
to do so for the following purposes:

 * to contact you via email or text with marketing information about our
   services if you register an account with us online or when you refresh your
   marketing preferences when responding to a request from us to do so; and
 * processing your medical details as part of an audit we are carrying out for a
   client, where we will have sought your explicit consent.

You may withdraw your consent for us to use your information in any of these
ways at any time. Please see Withdrawing your consent for further details.

Where there is a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to
pursue our legitimate interests as a business for the following purposes:

 * performing services to fulfil our contractual services with our clients,
   including (but not limited to):
   
   * preparing risk assessment or audit reports in relation to your driving
     safety/compliance;
   * contacting you to take any actions found in these reports to be required,
     including but not limited to chasing where renewal of motor insurance is
     required;
   * registering and enrolling you in e-learning or training courses;
   * updating your qualification and/or training records;
   * managing your use of your own vehicle for business purposes as part of our
     Grey Fleet management services; and
   * to “de-activate” your record, which is a process for flagging an
     individual’s record as “terminated”, for example, if the employee has left
     our client’s employment, but is still within the retention period for
     keeping such personal information.
 * analysis to inform our business strategy, and to enhance and personalise your
   experience;
 * for product development purposes (for example to improve courses and training
   quality and performance);
 * for market research in order to continually improve the services that we
   deliver to you and our clients;
 * marketing activities (other than where we rely on your consent to contact you
   by email or text with information about our products and services or share
   your details with third parties to do the same);
 * prevention of fraud and other criminal activities;
 * to verify the accuracy of data that we hold about you and create a better
   understanding of you as a user of our site and/or services;
 * to correspond or communicate with you;
 * network and information security in order for us to take steps to protect
   your information against loss or damage, theft or unauthorised access;
 * to comply with a request from you in connection with the exercise of your
   rights (for example where you have asked us not to contact you for marketing
   purposes, we will keep a record of this on our suppression lists in order to
   be able to comply with your request);
 * assess and improve our service to customers through recordings of any calls
   with our contact centres; and
 * management of queries, complaints, or claims.

Where this is a VITAL INTEREST

In exceptional circumstances, we will share your data with Public Health
Authorities when it is in your vital interest to do so – the Public Health
Authorities act as Data Controllers in this capacity.

Where there is a LEGAL REQUIREMENT

We will use your personal information to comply with our legal obligations: (i)
to assist the DVLA and/or DVANI, UKROEd, Police Forces, Magistrates Courts or
any other public authority or criminal investigation body; (ii) to identify you
when you contact us; (iii) to verify the accuracy of data we hold about you;
and/or (iv) to assist any third party with whom we have shared your personal
information in accordance with this policy (please see Others who have receive
or have access to your personal information) where necessary to assist these
third parties to comply with their legal requirements.

Where it is required to complete a CONTRACT

We may use and process your personal information where it is necessary to fulfil
a contract we have with you, your employer, a public authority body or because
you have asked us to take specific steps before entering into a contract. This
will include information that we process in order to enable you to make use of
our site and the services we provide through it, or to complete a contract for
services that we have entered into with you including without limitation:

 * Contact details.
   Course attendance details.

Where acting as a DATA PROCESSOR for our clients

We will often carry out processing activities on behalf of our clients, such as
when we perform driving licence checking services utilising information provided
by our clients’ employees on D906 Fair Processing Declarations. This processing
will be governed by our clients’ privacy policies. If we are carrying out
driving licence checking services with your personal data, please contact your
employer/ the organisation for whom you work to obtain a copy of the relevant
privacy policy.


6. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Our suppliers and service providers

We may disclose your information to our third party service providers, agents,
subcontractors and other organisations for the purposes of providing services to
us or directly to you on our behalf. Such third parties may include; course
trainers and instructors, cloud services providers (such as hosting services),
the DVLA or DVANI, DVSA, address matching service providers, training
organisations, our partners, or other third parties who provide services to us.

When we use third party service providers, we only disclose to them any personal
information that is necessary for them to provide their service and we have a
contract in place that requires them to keep your information secure and not to
use it other than in accordance with our specific instructions.

Your employer

We may disclose personal information to your employer when we have entered into
a contract to provide services to them. This may be when we report on audits
and/or risk assessments carried out in relation to your driving.

Our partners (third parties that act as resellers of our services)

We work with a number of third party partners who act as resellers of our
services. We may disclose personal information to one of our partners if they
have a contract with your employer who has entered into a contract with this
partner to provide our services to them. This may be when we report on audits
and/or risk assessments carried out in relation to your driving.

Other ways we may share your personal information

We may transfer your personal information to a third party as part of a sale of
some or all of our business and assets to any third party or as part of any
business restructuring or re-organisation. We may also transfer your personal
information if we’re under a duty to disclose or share it in order to comply
with any legal obligation, to detect or report a crime, to enforce or apply the
terms of our contracts or to protect the rights, property or safety of our
visitors and customers.
However, we will always take steps with the aim of ensuring that your privacy
rights continue to be protected.


7. WHERE WE STORE YOUR PERSONAL INFORMATION

All information you provide to us is stored on our secure servers which are
located within the UK and European Economic Area (EEA).

If at any time we transfer your personal information to, or store it in,
countries located outside of the UK and EEA (for example, if our hosting
services provider changes) we will ensure that appropriate safeguards are in
place for that transfer and storage as required by applicable law. This is
because some countries outside of the UK and EEA do not have adequate data
protection laws equivalent to those in the UK and EEA.

If you use our services whilst you are outside the UK and EEA, your information
may be transferred outside the UK and EEA in order to provide you with those
services.


8. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

If we collect your personal information, the length of time we retain it is
determined by a number of factors including the purpose for which we use that
information and our obligations under other laws.

We do not retain personal information in an identifiable format for longer than
is necessary.

We will retain your personal information as set out in the table below, except
where:

 * the law requires us to hold your personal information for a longer period, or
   delete it sooner
 * you exercise your right to have the information erased (where it applies) and
   we do not need to hold it in connection with any of the reasons permitted or
   required under the law (see further Erasing your personal information or
   restricting its processing); or
 * in limited cases, the law permits us to keep your personal information
   indefinitely provided we put certain protections in place.

We retain your personal information as follows:

 1.  Data records provided to us for provision of police referred training
     courses: Data retention for 1 year from completion of the associated
     course.
 2.  Data records provided to us for provision of Magistrates Court referred
     training courses:  Data retention for 7 years from the set course
     completion date
 3.  Consent Forms/Fair Processing Declarations for processing of driving
     licence details (hard copy and electronic):  Data retention for 7 years
     from the date the form is received by us, as mandated by the DVLA, in case
     the information is needed to establish, defend or bring legal claims.
 4.  Personal data collected from you in the provision of our services,
     including Audit, vehicle declaration and insurance certificate:  Data
     retention for 3 years. This enables organisations to run a three year cycle
     Health and Safety Programme to establish continued improvement.
 5.  Reports generated as part of the services we provide:  Data retention for 3
     years. This enables organisations to run a three year cycle Health and
     Safety Programme to establish continued improvement.
 6.  Incident management data:  Data retention for 3 years. This enables
     organisations to run a three year cycle Health and Safety Programme to
     establish continued improvement.
 7.  Vehicle data:  Data retention for 3 years. This enables organisations to
     run a three year cycle Health and Safety Programme to establish continued
     improvement.
 8.  Driving licence data:  Data retention for 3 years. This enables
     organisations to run a three year cycle Health and Safety Programme to
     establish continued improvement.
 9.  Cookies data:  As per the Cookies Policy
 10. Contact details:  Data retention for 7 years from the date the data is
     received by us if provided as part of a Consent Form/Fair Processing
     Declaration as mandated by the DVLA, in case the information is needed to
     establish, defend or bring legal claims.


9. YOUR RIGHTS

Your (data subject) rights

You have a number of rights in relation to your personal information under data
protection law. In relation to certain rights, we may ask you for information to
confirm your identity and, where applicable, to help us to search for your
personal information. Except in rare cases, we will respond to you within 30
days after we have received this information or, where not required, after we
have received your request.

Accessing your personal information

You have the right to ask for a copy of the information that we hold about you
by emailing or writing to us at the address at the end of this policy. We may
not provide you with a copy of your personal information if this concerns other
individuals or we have another lawful reason to withhold that information.

Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways
to make it easier for you to review and correct the information that we hold
about you.

In the meantime, if you change your name or address/email address, or you
discover that any of the other information we hold is inaccurate or out of date,
please let us know by contacting us in any of the details described at the end
of this policy.

Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal
information, as set out under How we use your personal information, you may
withdraw your consent at any time by contacting us at the contact details set
out below (Contact us). If you would like to withdraw your consent to receiving
any direct marketing to which you previously opted-in, you can do so using our
Unsubscribe tool. If you withdraw your consent, our use of your personal
information before you withdraw is still lawful.

Objecting to our use of your personal information and automated decisions made
about you

Where we rely on our legitimate business interests as the legal basis for
processing your personal information for any purpose(s), as out under How we use
your personal information, you may object to us using your personal information
for these purposes by emailing or writing to us at the address at the end of
this policy.

Except for the purposes for which we are sure we can continue to process your
personal information, we will temporarily stop processing your personal
information in line with your objection until we have investigated the matter.
If we agree that your objection is justified in accordance with your rights
under data protection laws, we will permanently stop using your data for those
purposes. Otherwise we will provide you with our justification as to why we need
to continue using your data.

You may object to us using your personal information for direct marketing
purposes and we will automatically comply with your request. If you would like
to do so, please use our Unsubscribe tool.

You may also contest a decision made about you based on automated processing by
contacting us at the contact details set out below (Contact us).

Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be
removed from our systems by emailing or writing to us at the address at the end
of this policy. Provided we do not have any continuing lawful reason to continue
processing or holding your personal information, we will make reasonable efforts
to comply with your request.

You may also ask us to restrict processing your personal information where you
believe it is unlawful for us to do so, you have objected to its use and our
investigation is pending or you require us to keep it in connection with legal
proceedings. We may only process your personal information whilst its processing
is restricted if we have your consent or are legally permitted to do so, for
example for storage purposes, to protect the rights of another individual or
company or in connection with legal proceedings.

Transferring your personal information in a structured data file

Where we rely on your consent as the legal basis for processing your personal
information or need to process it in connection with your contract, as set out
under How we use your personal information, you may ask us to provide you with a
copy of that information in a structured data file. We will provide this to you
electronically in a structured, commonly used and machine readable form, such as
a CSV file.

You can ask us to send your personal information directly to another service
provider, and we will do so if this is technically possible. We may not provide
you with a copy of your personal information if this concerns other individuals
or we have another lawful reason to withhold that information.


Complaining to the UK data protection regulator

You have the right to complain to the Information Commissioners Office (ICO) if
you are concerned about the way we have processed your personal information.
Please visit the ICO’s website for further details.


10. SECURITY / COOKIES / LINKS

Security measures we put in place to protect your personal information

Unfortunately, the transmission of information via the internet is not
completely secure. Although we will do our best to protect your personal
information, we cannot guarantee the security of your information transmitted to
our website and any transmission is at your own risk. Once we have received your
personal information, we put in place reasonable and appropriate controls to
ensure that it remains secure against accidental or unlawful destruction, loss,
alteration, or unauthorised access.

Where we collect any sensitive personal information about your ethnic
background, sex life, political opinions, religion, trade union membership or
criminal record, we will apply additional security controls to protect that
data.

Where we have given (or where you have chosen) a password which enables you to
access an account, you are responsible for keeping this password confidential.
We ask you not to share your password with anyone.

Use of 'cookies'

Like many other websites, our websites use cookies. 'Cookies' are small pieces
of information sent to your device and stored on its hard drive to allow our
websites to recognise you when you visit.

It is possible to switch off cookies by setting your browser preferences. For
more information on how we use cookies and how to switch them off on your
device, please visit our Cookies Policy.

Links to other websites

Our website may contain links to other websites run by other organisations. This
policy does not apply to those other websites and Apps‚ so we encourage you to
read their privacy statements. We cannot be responsible for the privacy policies
and practices of other websites and Apps even if you access them using links
that we provide.

In addition, if you linked to our website from a third party website, we cannot
be responsible for the privacy policies and practices of the owners and
operators of that third party website and recommend that you check the policy of
that third party website.


11. MARKETING

We may collect your preferences to receive marketing information directly from
us in the following ways:

 * if you register an account with us online, we will ask you if you would like
   to provide your consent to receive marketing information directly from us; or
 * if you make an enquiry we may contact you with marketing information in the
   ways mentioned in the notices presented to you, except where you indicate you
   would prefer otherwise.

We may contact you with marketing information by post or by telephone or with
targeted advertising delivered online through social media and platforms
operated by other companies, unless you object.

From time to time, we may ask you to refresh your marketing preferences by
asking you to confirm that you consent to continue receiving marketing
information from us.

You have the right to opt-out of our use of your personal information to provide
marketing to you in any of the ways mentioned above. Please see Withdrawing your
Consent and Objecting to our use of your personal information and automated
decisions made about you above for further details on how you can do this.

You have the right to withdraw your consent or request that the data we hold on
you is erased or rectified. For example, if you don’t want us to use your
information for views and comments on the services we provide, you can ask to
have your contact details removed. To submit a request complete our Subject
Access Request form.


12. CONTACT US

Our Data Protection Officer is David Finney. Please direct any queries about
this policy or about the way we process your personal information to our Data
Protection Officer using our contact details below.

The ADRRESS If you wish to write to us:
Attention of The Data Protection Officer,
TTC Group (UK) Limited,
Hadley Park East,
Telford, TF1 6QJ


Our email address for data protection queries is yourdata@ttc-uk.com

If you would prefer to speak to us by phone, please call 0330 024 1805


13.  USEFUL DOCUMENT LINKS

Download Privacy Policy

Download Information Security Policy

Download GDPR Compliance Policy

Download Cookies Policy

 


CONTACT US

TTC Group
Hadley Park East
Telford, TF1 6QJ
Location details


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