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Effective URL: https://www.zenith.co.uk/privacy-notice/?dm_i=26PO,8INLC,3RSLU0,Z8E3O,1
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Text Content

 * Who we are
   
   
   Who we are
   
   Zenith is the UK’s leading independent leasing, fleet management and vehicle
   outsourcing business, with capabilities across all vehicle asset types,
   supporting business fleets, salary sacrifice and consumer cars.
   
   View all
   
    * About us
    * Our strategy
    * Our People Promise
    * Technology and transformation
    * Sustainability
   
   
   
   SMARTER SALARY SACRIFICE
   
   Find out more
   
 * Personal
   
   
   Personal Car Solutions
   
   All the joy of driving a new car, none of the hassle. Just the car you want
   on your terms. That’s personal contract hire.
   
   View all personal
   
    * 
      Personal contract hire
      * View all Personal contract hire
      * How PCH works
      * Personal contract hire FAQs
   
   
   
   how does salary sacrifice work?
   
   Find out more
   
 * Business
   
   
   Business
   
   Business leasing solutions for all – from bikes to cars, vans, trucks and
   trailers, we have vehicles to meet all needs and fleet sizes.
   
   View all business
   
    * 
      Corporate fleets
      * View all Corporate fleets
      * Fleet management
      * Funding
      * Electric
      * Fleet services
      * Salary sacrifice
    * 
      Commercial Vehicles
      * View all Commercial Vehicles
      * Commercial Fleet Solutions
      * Trailer rentals
   
   
   
   E-LCV transition strategy
   
   Navigate your journey to electric
   
 * News & Insights
   
   
   News and Insights
   
   The future of intelligent solutions, first. Stay connected to the latest news
   and information from Zenith.
   
   View all
   
    * News
    * Case studies
    * Blogs
    * Guides
    * Webinars
    * Events
    * Insights
    * Drivers
   
   
   
   Santander Consumer Finance extends its partnership with Zenith
   
   Read more
   
 * Life at Zenith
   
   
   Life at Zenith
   
   We strive to be the best employer that we can be and our people are central
   to our success. Find out more about our culture.
   
   View all Life at Zenith
   
    * Careers
    * Our values
    * Caring for each other
    * Academy
    * Apprenticeships
    * Agile working
    * Diversity & Inclusion
   
   
   
   Accelerate your career at Zenith
   
   Where to next?
   
 * Investors
   
   
   Investors
   
   With turnover of £688.1m and EBITDA of £79.4m in the year ended March 2023,
   this has been a year of record performance for Zenith.
   
   Take a look at our financial results, reports and presentations.
   
   View all
   
    * Reports
    * Presentations
    * Announcements
    * Green Financing Framework
   
   
   
   Zenith Q2 & H1 FY24 financial results
   
   Read more
   


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HOW DOES SALARY SACRIFICE WORK?

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HOW THE TRANSPORT INDUSTRY CAN SUPPORT YORKSHIRE

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INDUSTRY INSIGHTS - NOVEMBER 2023

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PRIVACY NOTICE

Zenith respects your privacy and is committed to protecting your personal data.


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GO TO SECTION

 * Overview
 * The data we collect
 * How we collect data
 * How we use data
 * Job applicants
 * Disclosures
 * International transfers
 * Data security
 * Data retention
 * Your legal rights
 * Glossary

Welcome to Zenith’s Privacy Notice

This privacy notice will inform you as to how we look after your personal data
when you visit our websites and driver portals or contact us directly, and tells
you about your privacy rights and how the law protects you.

Click on the links to the left to view the applicable section of this notice.
Please also use the glossary to understand the meaning of some of the terms we
have used.




IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice provides information on how Zenith collects and processes
your personal data via your use of our websites and portals, including any data
you may provide when you register or login to a driver portal, sign up to a
newsletter or take part in a prize draw or survey, order a new vehicle, or
access and request certain services from us.

It is important that you read this privacy notice together with any other
privacy notice or fair processing notice we may provide on specific occasions
when we are collecting or processing personal data about you so that you are
fully aware of how and why we are using your data. This privacy notice
supplements the other notices and is not intended to override them.

Controller

Zenith is made up of different legal entities, details of which can be
found here. This privacy notice is issued on behalf of the whole Zenith Group so
when we mention “Zenith”, “we”, “us” or “our” in this privacy notice, we are
referring to the relevant company in the Zenith Group responsible for processing
your data.

We will let you know which entity will be the controller for your data when you
visit the applicable driver portal.

Zenith Vehicle Contracts Limited is the controller for www.zenith.co.uk

Zenith Vehicle Contracts Limited or Leasedrive Limited will be the controller of
the driver portals depending on your employer’s scheme. Further information can
be found on the applicable portal.

If you are visiting the ZenAuto website then that privacy notice will apply
which can be found here.

We have appointed a data protection officer (DPO) who is responsible for
overseeing this privacy notice and answering any questions you may have. If you
would like to discuss any aspect of this privacy notice, including any requests
to exercise your legal rights, please contact the DPO using the details set out
below.



Contact details


Our full details are: Zenith Vehicle Contracts Limited and Leasedrive Limited
DPO: Andrew Morton
Email: data.protection@zenith.co.uk
Post: Number One, Great Exhibition Way, Kirkstall Forge, Leeds, LS5 3BF
Telephone: 0344 417 6015

You have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data protection
issues (www.ico.org.uk). We would, however, appreciate the chance to deal with
your concerns before you approach the ICO so please contact us in the first
instance and we’d be happy to help.

Changes to the privacy notice and your duty to inform us of changes

This version 5.0 was last updated on 5th October 2023 and historic versions can
be obtained by contacting us via the methods set out above.

It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us – for example if you change your name, address or telephone
number.

Third-party links

This website and our driver portals may include links to third-party websites,
plug-ins and applications. Clicking on those links or enabling those connections
may allow third parties to collect or share data about you. We do not control
these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every
website you visit.




THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an
individual from which that person can be identified. It does not include data
where the identity has been removed for example anonymous data.

We may collect, use, store and transfer different kinds of personal data about
you which we have grouped together as follows:

 * “Identity Data” includes your first name, maiden name, last name, username or
   similar identifier such as an employee number, marital status, title, date of
   birth and gender – and, as applicable, such Identity Data in relation to
   additional named drivers. We may also receive or ask you to provide your
   National Insurance number and driving licence number, or dash-cam footage and
   vehicle location if we provide related services to you.
 * “Contact Data” includes your home address, email address and telephone
   numbers. We may also ask for details about your employer such as which office
   you work at or which division, and the office address. We may also need this
   information in relation to additional named drivers as applicable.
 * “Financial Data” includes your bank account and payment card details if we
   are providing certain services to you.
 * “Transaction Data” includes details about payments to and from you and other
   details of products and services you have ordered from us or that you are
   receiving.
 * “Technical Data” includes internet protocol (IP) address, your login data,
   browser type and version, time zone setting and location, browser plug-in
   types and versions, operating system and platform and other technology on the
   devices you use to access this website.
 * “Profile Data” includes your username and password, quotes or orders made by
   you, your interests, preferences, feedback and survey responses.
 * “Usage Data” includes information about how you use our website, products and
   services.
 * “Marketing and Communications Data” includes your preferences in receiving
   marketing from us and whether you have ‘unsubscribed’ to marketing.

We also collect, use and share “Aggregated Data” such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data
does not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data so that we can see how users are accessing our portals
and to ensure the user journey works the way it is intended to. However, if we
combine or connect Aggregated Data with your personal data so that it can
directly or indirectly identify you, we treat the combined data as personal data
which will be used in accordance with this privacy notice.

Special Categories of Personal Data require higher levels of protection. We need
to have further justification for collecting, storing and using this type of
personal information. We have in place an appropriate policy document and
safeguards which we are required by law to maintain when processing such data.

Depending on the type of services to be provided to you, we may collect a
limited amount of health information should you be involved in a vehicle
incident. We call this the ‘first notification of loss’ and is where (if you are
receiving these kind of services) our representatives will record information
from you about the incident. If you wish to make a personal injury claim we can,
always at your request, refer your details to our preferred specialist law
firms, who will then contact you directly and handle the claim on your behalf.
We will ensure that any information obtained is limited to what is necessary in
order to, for example, administer an insurance or injury claim.

We may also collect driving related convictions and offences when we receive
your driving licence information and administer fines and traffic offences on
behalf of you and your employer.

You may also tell us about certain health information and we will use that
information to ensure that we are treating you fairly and adapting our approach.
For example, if you have particular vulnerabilities we will use that knowledge
so that we can support you to the best of our ability and act fairly and
responsibly. We will seek your consent prior to logging any such information. We
will remove this data once it is no longer necessary, for example once your
vulnerability ends.

We do not collect any other Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health other than referenced above and
genetic and biometric data). Nor do we collect any information about non-driving
related criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data and you fail to provide that data when
requested, we may not be able to provide a quote for your vehicle, deliver it or
provide other services to you that you have requested. In this case, we may have
to cancel a product or service you have with us but we will notify you if this
is the case at the time.




HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may for example give us your Identity, Contact and
Profile Data by filling in forms on our sites or by corresponding with us by
post, phone, email, live chat or otherwise. This includes personal data you
provide when you:

 * apply for or request our products and services;
 * create an account on our website or visit it from your employer’s intranet;
 * subscribe to our service or publications;
 * enter a competition, promotion or survey; or
 * give us some feedback.

IMPORTANT TO KNOW

Where you provide information relating to additional drivers, you must obtain
their authority for it to be used and disclosed in the ways described in this
Privacy Notice.

Your Employer. Your employer may give us certain Identity Data about you so that
we can pre-register you on our sites and ensure that you have access to the
correct products and services. We call this an ‘Eligibility File’ and is limited
to such Identity Data that we need to ensure that you have access to the right
products and services when you access the portal.

Automated technologies or interactions. As you interact with our website, we may
automatically collect Technical Data about your computer equipment, browsing
actions and patterns. We collect this personal data by using cookies, and other
similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about
you from various third parties as set out below:

 * Technical Data from analytics providers.
 * Identity, Contact, Financial and Transaction Data from providers of
   technical, payment and ‘in-life’ services such as:
   * our vehicle dealerships and agents when they deliver your new vehicle or
     collect your old one;
   * verification of your driving licence from the DVLA and our processing
     agents;
   * our approved network of repairers and garages;
   * confirmation of vehicle insurance from an insurance broker or provider.




HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:

 * Where it is necessary for our legitimate interests (or those of a third
   party) and your interests and fundamental rights do not override those
   interests.
 * Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on
to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your
personal data.

We have set out below a description of the main ways we plan to use your
personal data, and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate. We’re unable to
name all of the partners here, due to commercial confidentiality and the large
number that we work with. Instead, we’ve provided the categories of partner that
we use, and the services that they will provide as applicable. To support our
services, we also use a variety of approved third party tools and services.

Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data.
Please contact us if you would like to discuss this further.

In addition to the below we may transfer information about your arrangements
with us to our third party funders and financiers (Funders), including in
connection with transferring our interest, financial or otherwise, in our
arrangements to those Funders. We will not transfer personal data to the Funders
unless it is absolutely necessary for us to do so however if you are a Director
of our corporate customer then we may send your Identity and Contact Data to
Funders so that they may complete a credit and fraud check as applicable. In the
event of our insolvency, then we may transfer your personal data to those
Funders so that they may collect any remaining payments from you and to continue
to manage any existing arrangements. Those Funders will provide you with their
relevant Privacy Notice at that time and following receipt of your data from us.



Vehicle scheme is live

Purpose/Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
Examples of transfers to third parties
To advise you that your employer vehicle scheme is live and to provide
instructions to you on how to access our driver portals
 * Identity
 * Contact
 * Marketing and Communications

Necessary for our legitimate interests (so that you can order your new vehicle
and access our portals and obtain services)
None

Accessing our driver portals, browsing and selecting products and services and
ordering a vehicle

Purpose/Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
Examples of transfers to third parties
To register you as a new customer
Identity
Contact
Necessary for our legitimate interests (to verify and provide you with access to
our driver portals)
None
To arrange a demonstrator vehicle
Identity
Contact
Necessary for our legitimate interests (to arrange a vehicle to be delivered to
you based upon your instructions)
Necessary to comply with a legal obligation (to arrange insurance)
To vehicle dealerships and providers
To insurance brokers and providers
To obtain a vehicle and/or insurance quote
Identity
Contact
Necessary for our legitimate interests (to arrange a unique quote based on your
requirements)
Necessary to comply with a legal obligation
To vehicle dealerships and providers
To insurance brokers and providers
To process and deliver your order including:
Ordering your vehicle
Delivering your vehicle
Identity
Contact
Finance (if applicable)
Transaction
Marketing and Communictions
Profile
Necessary for our legitimate interests (to complete your vehicle order)
Necessary to comply with a legal obligation
To vehicle dealerships and providers
To insurance brokers and providers
To our delivery agents
To our funders and banking institutions (if applicable)
To your employer (if applicable)

Vehicle "in-life" services

Purpose/Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
Examples of transfers to third parties
To arrange vehicle services including:
MOT and service
Tyres
Other maintenance and repairs
Breakdown recovery
Collection
Identity
Contact
Financial
(if applicable)
Transaction
Profile
Necessary for our legitimate interests (to undertake and complete services)
To vehicle dealerships and providers
To our approved network of repairers, service providers and fitters
To our breakdown recovery provider
To your employer (if applicable)
To administer notices of intended prosecutions, penalty charge notices and
private parking charge notices
Identity
Contact
Financial
(if applicable)
Transaction
Necessary for our legitimate interests (to transfer liability to the driver)
Necessary to comply with a legal obligation
To the issuing authority
To the police (if applicable)
To your employer (if applicable)
To provate parking companies
To third party notice processing companies
To administer insurance related services and credit checking (if applicable)
Identity
Contact
Financial
(if applicable)
Transaction
Necessary for our legitimate interests (to ensure the vehicle is insured)
Necessary to comply with a legal obligation
To insurance brokers and providers
To the Motor Insurance Database (if applicable)
To your employer (if applicable)
To arrange a hire or temporary vehicle
Identity
Contact
Finance (if applicable)
Transaction
Profile
Necessary for our legitimate interests (to ensure the vehicle is insured and to
manage a pool car, if applicable))
Necessary to comply with a legal obligation
To vehicle dealerships or hire car providers
To insurance brokers and providers (if applicable)
To the Motor Insurance Database (if applicable)
To your employer (if applicable)
To our car pool mobile app provider (if applicable)
To administer vehicle incident claims
Identity
Contact
Finance (if applicable)
Transaction
Profile
Health information (if applicable) and relating to the vehicle incident only
Necessary for our legitimate interests (to provide accident management services,
insurance related claims and recovery as applicable)
Consent
Necessary to comply with a legal obligation
To insurance brokers and providers
To your employer (if applicable)
To independent professional advisers (if applicable)
To our approved network of repairs and service providers and fitters
To uninsured loss recovery agents (if applicable)
To provide other services to you such as ‘MyMiles’, ‘CAMS’ and Driving Licence
Checking
Identity
Contact
Finance (if applicable)
Transaction
Profile
Health information (if applicable) and relating to any DVLA declared medical
conditions
Necessary for our legitimate interests (to provide accident management services,
insurance related claims and recovery as applicable)
Necessary to comply with a legal obligation
To insurance brokers and providers
To your employer (if applicable)
To the DVLA and third party driving licence checking partners
To provide operational processing such as travel abroad requests, cherished
plates, vehicle schedules, MOT reminders, authorisation letters, demo requests,
fuel cards

Identity
Contact
Finance (if applicable)
Necessary for our legitimate interests (in order to manage the vehicle and to
respond driver requests)
Necessary to comply with a legal obligation
 * To printing solutions provider
 * DVLA
 * BVRLA
 * To your employer (if applicable)

To provide end of life / end of contract services such as vehicle collections,
vehicle disposables
Identity
Contact
Necessary for our legitimate interests (in order to manage the vehicle and to
respond to driver requests)
To collection agents
To auction partners
To vehicle disposal partners

Our relationship with you

Purpose/Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
Examples of transfers to third parties
To manage our relationship with you which will include:
Notifying you about changes to our terms or privacy notice
Asking you to leave a review or take a survey
Advising you of a vehicle renewal and/or special offers
Identity
Contact
Profile
Marketing and Communications
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study
how customers use our products/services)
To independent survey providers To your employer (if applicable) and their
benefit providers
To enable you to partake in a prize draw, competition or complete a survey
Identity
Contact
Profile
Usage
Markeing and Communications
Necessary for our legitimate interests (to study how customers use our
products/services, to develop them and grow our business)
To independent survey providers To your employer (if applicable) and their
benefit providers
To administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support, reporting
and hosting of data)
Identity
Contact
Technical
Usage
Necessary for our legitimate interests (for running our business, provision of
administration and IT services, network security, to prevent fraud and in the
context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
None
To deliver relevant website content and advertisements to you and measure or
understand the effectiveness of the advertising we serve to you
Identity
Contact
Profile
Usage
Marketing and Communications
Technical
Necessary for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to inform our
marketing strategy)
None
To use data analytics to improve our website, products/services, marketing,
customer relationships and experiences
Technical
Usage
Necessary for our legitimate interests (to define types of customers for our
products and services, to keep our website updated and relevant, to develop our
business and to inform our marketing strategy)
None
To make suggestions and recommendations to you about goods or services that may
be of interest to you
Identity
Contact
Technical
Usage
Profile
Necessary for our legitimate interests (to develop our products/services and
grow our business)
None
To send you marketing and offers from other Zenith Group Companies
Identity
Contact
Technical
Profile
Marketing and Communications
Consent
Zenith Group Companies
To log a vulnerability to support you to the best of our ability, act fairly,
deliver positive outcomes and act responsibly
Health
Consent
None

Other sales activity

Purpose/Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
Examples of transfers to third parties
To host and share content with sales prospects
Contact
Profile
Consent
To our sales content platform provider
To sell our products and services and manage ongoing interactions
Contact
Necessary for our legitimate interests (to develop our products/services and
grow our business)
Consent
To our customer relationship management provider

Marketing


We may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
This is how we decide which products, services and offers may be relevant for
you (we call this marketing).

We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising. We have established the following
personal data control mechanisms.

Invitation to participate in your employer’s chosen scheme or access to services


You will receive communications from us and in certain cases your employer to
advise you that the vehicle scheme and benefit service portal is open. These
communications will be sent to you if you are eligible for the vehicle benefit
or certain services as determined by your employer from time-to-time and with
their collaboration. For example, if you are a company car driver then we’ll
email you to let you know how you can order a new vehicle.

We won’t spam you with emails and if you aren’t interested in the scheme you can
stop receiving such emails by clicking the unsubscribe link any time.

If you don’t receive a vehicle from us, your employer may still determine that
it is necessary for you to receive certain services – for example logging your
business mileage or personal vehicle details on our CAMS site. We’ll still email
you about how you can register and access these services.

Promotional offers from us

You will receive marketing communications from us and via your employer (if
applicable) if you have requested information from us, have obtained a vehicle
or services from us or if you provided us with your details when you entered a
competition or registered for a promotion and, in each case, you have not
unsubscribed to receiving that type of marketing.

If you currently have a vehicle from us then we will advise you when it’s
getting close to the end of its term and let you know about special offers on
replacement vehicles and services.

Opt-In Marketing

With your consent, given at the time you supply your personal data, we may pass
that data to a Zenith Group company for their direct marketing purposes. You can
stop these communications at any time by following the instructions below.

Third-Party marketing

We will get your express opt-in consent before we share your personal data with
any company outside the Zenith group of companies for marketing purposes.

Unsubscribing

You can ask us or third parties to stop sending you marketing messages at any
time by following the unsubscribe links on any marketing message sent to you or
by contacting us.

Where you unsubscribe to receiving these marketing messages, this will not apply
to personal data provided to us as a result of a product or service experience
or other transactions and services required to be fulfilled such as delivering
your vehicle or arranging ‘in-life’ services for that vehicle.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website and our portals may become inaccessible or
not function properly. For more information about the cookies we use,
please click here.

Automated Decisions 

We may sometimes use systems to make automated decisions based on personal data
we have about you. This helps us to make sure are decisions are quick, fair,
efficient and correct based on what we know. These automated decisions can
affect the products and services we may offer you or the price that we charge.
We may for example place you in groups with similar individuals to learn about
our customer’s needs and to make decisions on what we learn.

You have rights over automated decisions. You can ask us at any time not to make
our decision based on an automation, and you can object to an automated decision
and ask that a person reviews it.

If you want to know more about these rights please contact us.

Change of purpose

We will only use your personal data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and that
reason is compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify
you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required and
permitted by law.




JOB APPLICANTS

If you apply for a job with us, we will collect and use the information you
provide to us in the course of your application to assess your suitability for
the position you have applied for and for other roles in future, and to monitor
diversity and equal opportunities within our recruitment process.

What information does the company collect?

We collect a range of information in relation to a job application. This
includes:

 * your name, address, date of birth, National Insurance number, HMRC new
   starter checklist details, contact details, including email address,
   telephone number and an emergency contact;
 * details of your qualifications, skills, experience, employment history and
   any gaps in your employment;
 * information from interviews and phone-screenings you may have;
 * bank account information;
 * information about your current level of remuneration, including benefit
   entitlements;
 * information about all spent and unspent convictions, cautions, reprimands,
   and final warnings held on central police records (apart from protected
   convictions and cautions) and information about your address history and
   electoral roll registration, County Court Judgements (CCJs), bankruptcies,
   voluntary arrangements, decrees and administration orders;
 * information about your entitlement to work in the UK;
 * equal opportunities monitoring information, including information about your
   ethnic origin, sexual orientation, physical health or mental conditions,
   religion or belief, gender identity and nationality;
 * Dietary requirements (for induction purposes only);
 * Vehicle registration/s;
 * Uniform requirements (for applicable Commercial employees only).

How is this data collected?

This data may be obtained from:

 * Our background checking partner
 * Directly from you, including:
   * your CV and job application form
   * other documents provided by you to confirm your identity and support your
     job application
   * information provided by you through our applicant tracking portal.
 * Your previous employers
 * Educational and professional organisations
 * Internet searches and other publicly available information sources

We will seek information from third parties only once a job offer has been made
to you.

Data will be stored in a range of different places, including on your
application record, in our HR management systems and our email system.

How do we use this personal data?

We collect and process your data for a number of purposes and where we have a
legal basis to do so, as follows.

We have a legitimate interest in processing personal data during the recruitment
process and for keeping records of the process. Processing data from job
applicants allows us to:

 * manage the recruitment process,
 * make a well-informed hiring decision,
 * protect our business, and employees, from potential risk,
 * assess the honesty, character, safety, and qualifications of our applicants,
 * confirm a candidate’s suitability for employment,
 * decide what form of employment to offer,
 * set successful applicants up as employees in our HR systems,
 * respond to and defend against legal claims,
 * to ensure that individuals in privileged roles remain trusted and do not pose
   any risk to our business on an ongoing basis (for select employees only).

In some cases, we need to process data to ensure that we are complying with our
legal obligations. For example, we are required to check a successful
applicant’s eligibility to work in the UK before employment starts.

We may process information about whether or not applicants are disabled so we
can make reasonable adjustments for candidates who have a disability. Where we
process other special categories of data, such as information about ethnic
origin, sexual orientation, health or religion or belief, this is for equal
opportunities monitoring purposes. Our processing of these types of data will be
carried out to ensure you or us can meet our obligations or exercise our rights
under law related to employment or (only where applicable) to enable us to
establish, exercise or defend legal claims.

We will not use your data for any purpose other than the recruitment process of
which you are a part.

Who will we share this data with?

Your information may be shared internally within our group for the purposes of
the recruitment process. This includes members of the HR team, interviewers
involved in the recruitment process, and managers in the business area with a
vacancy. In limited circumstances, your application data may also be shared with
members of the legal and compliance team and with senior managers.

We will not share your data with third parties, unless your application for
employment is successful and an offer of employment is made. We will then share
your data with former employers in order to obtain references. We may also share
your data with our group companies, for business performance and other types of
monitoring and management purposes and, if the role requires certain levels of
screening we may share limited data with our screening providers. To process
successful applicant’s data, we will also share data with our payroll and
benefits providers.

In addition, we may need to share your personal information with relevant
regulators, or otherwise to comply with the law.

How long do we keep this data?

If your application for employment is unsuccessful (including when you have
speculatively applied to us in respect of a role which is not available), we
will hold your data on file for 6 months. At the end of that period, your data
is deleted or destroyed (unless we need to retain it for longer to exercise or
defend any legal claims).

If your application for employment is successful, personal data gathered during
the recruitment process will be transferred to your personnel file and retained
during your employment. The periods for which employee data is held will be
provided to you in a separate employee privacy notice.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to us
during the recruitment process. However, if you do not provide the information,
we may not be able to process your application.




DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 4 above.

 * Internal Third Parties as set out in the Glossary
 * External Third Parties as set out in the Glossary
 * Specific categories of third parties listed in the table in paragraph 4
   above.
 * Third parties to whom we may choose to sell, transfer, or merge parts of our
   business or our assets. Alternatively, we may seek to acquire other
   businesses or merge with them. If a change happens to our business, then the
   new owners may use your personal data in the same way as set out in this
   privacy notice.

We require all third parties to respect the security of your personal data and
to treat it in accordance with the law. We do not allow our third-party service
providers to use your personal data for their own purposes and only permit them
to process your personal data for specified purposes and in accordance with our
instructions.




INTERNATIONAL TRANSFERS

In the majority of cases it will not be necessary for us to transfer your
personal data outside the European Economic Area.

If we do need to share your personal data outside of the European Economic Area,
we ensure a similar degree of protection is afforded to it by ensuring at least
one of the following safeguards is implemented:

 * We will only transfer your personal data to countries that have been deemed
   to provide an adequate level of protection for personal data by the European
   Commission.
 * Where we use certain service providers, we may use specific contracts
   approved by the European Commission which give personal data the same
   protection it has in Europe.
 * Where we use providers based in the US, we may transfer data to them if we
   have carried out appropriate transfer risk assessments to ensure data is
   transferred securely and put in place appropriate contractual clauses and/or
   wording (which may include using UK specific contractual clauses and/or
   wording).

Please contact us if you want further information on the specific mechanism used
by us when transferring your personal data out of the EEA as applicable.




DATA SECURITY AND GDPR ACCOUNTABILITY


Information security

We have put in place appropriate technological and organisational measures to
prevent your personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. We operate an Information Security
Management System (ISMS) which is accredited to ISO/IEC 27001:2013. We use
industry-recognised tools and partnerships to secure our network, systems, and
software – including web-filtering and data loss prevention tooling, co-location
data centres, network intrusion monitoring and a 24/7/365 SOC / SIEM solution,
database patching, penetration testing and vulnerability scanning, anti-virus
and firewall software, PCI DSS compliant payment software, encryption and
anonymisation tooling – where it is appropriate to do so.

In addition, we operate internal policies and procedures which cover access
controls and privileged access management, IT acceptable usage, mobile devices,
data breach and cyber-attack response plans, business continuity management and
physical office controls. We also operate several delegated groups who are
responsible for ensuring that systems are stable, secure, available and
performant (covering vulnerabilities, patches, business change, project
management and development).

UK Data Protection / UK GDPR

Our privacy management framework ensures compliance with UK data protection
legislation and provides evidence of our compliance with the ‘accountability’
principle. This framework is maintained by our Data Protection Officer, who is
accredited to CIPP/E & CIPM (IAPP). We utilise a lifecycle model to continuously
measure and improve our privacy program.

In addition to our privacy policies and procedures, our governance structures
ensure the confidentiality, integrity, and availability of data. Directors are
accountable for managing the data in their business areas (referred to
internally as ‘Information Risk Owners’). They are supported by ‘Data
Guardians’, who are operational managers responsible for delivering mandatory
and risk-based activities regarding information security (e.g., access control
reviews) and data protection (e.g., DPIAs). In addition, Data Guardians act as
advocates for managing data responsibly and fielding queries from their
operational teams. Data Guardians and Information Risk Owners are supported with
subject matter expertise by our Information Security team and our DPO.




DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the
amount, nature and sensitivity of the personal data, the potential risk of harm
from unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes
through other means, and the applicable legal requirements.

We generally keep personal data about our customers and drivers for six years
after they cease being customers. This is for insurance, accident management,
tax purposes – or to defend ourselves against legal action. In some
circumstances we may retain personal data for a shorter time-frame, and we have
programmes in place to ensure this is deleted or put beyond use at the relevant
time.

In some circumstances you can ask us to delete your data: see Request
erasure below for further information.

In some circumstances we may anonymise or pseudonymise your personal data (so
that it can no longer be associated with you) for research or statistical
purposes and we may also put your personal data beyond use. In these instances
we may use or hold this information indefinitely without further notice to you.




YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in
relation to your personal data. Please click on the links below to find out more
about these rights:

 * Request access to your personal data
 * Request correction of your personal data.
 * Request erasure of your personal data.
 * Object to processing of your personal data.
 * Request restriction of processing your personal data.
 * Request transfer of your personal data.

If you wish to exercise any of the rights set out above, please email us.

No fee required

You will not have to pay a fee to access your personal data (or to exercise any
of the other rights) but see further below.

Refusal

We may refuse to comply with your request if it is clearly unfounded, repetitive
or excessive. In these circumstances we will confirm your right to complain to
the Information Commissioner’s Office (ICO), and to a judicial remedy, as
quickly as we can – but at the latest within one month. We may charge a
reasonable fee if your request is clearly unfounded, repetitive or excessive.

What we need from you

We may need to confirm your identity before we can action any request. This is a
security measure to ensure that your personal data is protected from
inappropriate use. You will need to provide a copy of your photo driving licence
or passport, plus a copy of a utility bill or bank statement within the last 3
months.  We may also contact you to ask you for further information in relation
to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it
may take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you
updated.




GLOSSARY



Lawful basis

Legitimate Interest means the interest of Zenith in conducting and managing our
business to enable us to give you the best service/product and the best and most
secure experience. We make sure we consider and balance any potential impact on
you (both positive and negative) and your rights before we process your personal
data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we
have your consent or are otherwise required or permitted to by law). You can
obtain further information about how we assess our legitimate interests against
any potential impact on you in respect of specific activities by contacting us.

Comply with a legal or regulatory obligation means processing your personal data
where it is necessary for compliance with a legal or regulatory obligation that
we are subject to.

Third Parties

Internal Third Parties

Other companies in the Zenith Group acting as joint controllers or processors
and who are based in the United Kingdom and provide IT and system administration
services and other services.

External Third Parties

 * Service providers acting as processors based in the United Kingdom who
   provide IT and system administration services.
 * Professional advisers acting as processors or joint controllers including
   lawyers, bankers, auditors and insurers based in the United Kingdom who
   provide consultancy, banking, legal, insurance and accounting services.
 * HM Revenue & Customs, DVLA, regulators and other authorities acting as
   processors or joint controllers based in the United Kingdom who require
   reporting of processing activities in certain circumstances.
 * Other third parties acting as processors or joint controllers based in the
   United Kingdom to whom we subcontract certain services to.

Your legal rights

You have the right to:



Request access: You have the right to be aware of the personal data that we or
our partners hold about you, and to verify the lawfulness of the processing.
This is formally known as a “Subject Access Request”. When submitting your
request, it would assist us if you could specify what information or processing
activities you’d like to see.



Request correction: You have the right to have your personal data corrected if
it is inaccurate or incomplete. This includes the data that we and our partners
hold on you. In many instances you can simply call or email our customer teams,
who can make most changes immediately, however you can also send us a formal
written request.



Request erasure: In certain circumstances you are entitled to have your personal
data erased (also known as “the right to be forgotten”). This includes the
personal data that we hold on you and also the data which our partners process
(see Third Parties above). Please note that where you are using a vehicle under
our fleet management services we have a legitimate interest to continue
processing your personal data and we will be unable to erase your data.



Object to processing: You have the right to object where we are processing your
personal data for direct marketing purposes. We will remove you from our mailing
list.



Request restriction of processing: You have the right to restrict or ‘block’ the
processing of your personal data. This might be where you contest the accuracy
of the personal data that we hold on you, and require us to restrict any further
processing until the personal data has been verified.



Request the transfer: You have the right to receive your personal data in a
format that can be easily transferred to, and used by, an alternative service
provider. This is formally known as “Data Portability”. We will provide you with
a CSV or Excel format file.


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