Dynamic Car Leasing will hold information about yourself or your company. You agree that we may use the information held to;
- Update our records about you or your company
- Provide you with services
- Provide you with information and relevant offers
In order to improve our service to our current or prospective clients we may use your information for research purposes. You can at any time request a copy of the information that we hold for a small fee of £10. Any information that we hold about you is confidential and we will not disclose it unless;
- Your consent has been given
- In order to gain professional advice
- Prevention of Crime – we or others need the information in order to investigate a crime (Crime prevention agencies)
- It is required or permitted by law
- A duty to the public requires it
- A governmental or regulatory body requests or requires it
GDPR
GDPR will apply to all EU states from the 25th May 2018 and has two main elements:
1.The EU wants to give people more control on how their personal data is being used.
2.The EU wants to give businesses a simpler, clearer legal environment in which to operate, making data protection law identical throughout the single market.
Dynamic Car Leasing Ltd has always complied with data protection laws and regulations surrounding the use of personal data. However, GDPR means we are having to change a number of our processes and policies. This document outlines what we have done at Dynamic Car Leasing to ensure we are fully compliant with the new regulation as from 25th May 2018.
What does GDPR change?
In summary, two things:
1.Transparency – Customers must be given far more information about what is done with their personal data, why, and what rights they have.
2.Control – Customers are given much more control in terms of obtaining a copy of their personal data, have it corrected, having it deleted, being told what legal ground is relied on to process the data, how long it will be kept for, objecting to processing (especially automated processing) and being told about security breaches and loss of data.
Data Controllers and Data Processors at Dynamic Car Leasing
A Data Controller states how and why personal data is processed. Robert Frost is the Data Controller at Dynamic Car Leasing and he can be contacted via helps@dynamic-car-leasing.co.uk should you need any assistance.
A Data Processor is the individual at Dynamic Car Leasing who is processing the data. All of our team who are in a sales, operations, finance and marketing roles can process data at Dynamic Car Leasing.
The duty of our Data Controller is to ensure that our processors abide by the law and our processors must abide by these rules and maintain records of their processing activates.
Our Data Controller must ensure that data is processed lawfully (see below “What is Lawful?”), is transparent and used for a set purpose.
Once this purpose has been fulfilled and the data is no longer required, it then needs to be deleted from our systems.
Who we are and our details?
All our company details on our website, www.dynamic-car-leasing.co.uk. At the footer of the home page, there is a section called “Contact Us” where all our details are available
What is Lawful?
Firstly, a person has consented for us to have their personal data and to process it.
Secondly, collecting the data is in our legitimate interest, such as preventing fraud.
How do we get consent from you?
We ask you to submit your name and email address when requesting a quotation via our website and we then retain your name and email address for a reasonable time whilst we are processing your quotation and if necessary your finance application and delivery of your new vehicle.
To comply with GDPR, Dynamic Car Leasing need to answer the following questions?
When did you give us consent?
The date you have clicked and submitted your quotation request
What did you give consent for?
Dynamic Car Leasing Ltd works with finance companies and dealerships in the UK. You may be a prospect that is looking for finance, an end user customer of ours where we have arranged a finance facility for a vehicle.
You are giving us consent to market to you no more than once per month and also to communicate about business opportunities we may be working on.
Why do Dynamic Car Leasing require consent?
We require consent for our own “Know Your Customer” (KYC) requirements, to reduce fraud and malpractice in our sector. We also need to maintain a commercial relationship over time with all our stakeholders to ensure that we can supply appropriate services and products to you.
How did you give consent?
By submitting a request for a quotation via this website or via an opt-in form that you may have completed
How can I withdraw my consent for you to hold my data?
You have the right to withdraw your consent for us to hold your data at any time. You do not have to offer a reason for this.
Once we have received notice from you to withdraw consent to hold your data, your details will be removed from our system and marketing lists within seven working days.
To remove your consent for us to hold your data, please email help@dynamic-car-leasing.co.uk
Do we have this history by individual person?
Yes, our records will provide history by the individual, not the company or organisation they represent.
When will the consent expire?
We expire consent seven years after it has been given. This period of time is due to companies undertaking lease contracts that can be five years in duration. We have allocated a year prior to a contract potentially being completed and one year after the agreement end.
What is classified as personal data?
Personal data could relate to economic, cultural and mental health information on yourself. We do not hold any of this data.
What data we hold and why?
At Dynamic Car Leasing, at time we collect information on:
- People’s interests – this is used for our account managers to speak about subjects an individual is interested in, thus building up a stronger relationship with them.
- Health – we will only ever record information on an individual’s health to ask how they are at a later date, or not to embarrass ourselves speaking about a subject matter that would clearly cause offence or harm.
- Location – we use location information, such as where you live, should there be a need to meet up in the future and / or take a general interest in business or local events that may be of interest to you.
- Age – we collect information on peoples age. Often, when we underwrite a finance agreement this data will be needed. With regards to the suppliers we work with, again, we have to carry out basic KYC checks and wish to communicate with you on a social level about things that interest you.
- Gender – we collect information on your gender for the purposes of writing to you.
- Spouse and Children – in some instances, we will hold the names and year of birth of immediate family members. This is done to build a closer working relationship with you over a period of time. This information is not used for any other form of profiling.
- Contact data – mobile phone number and email address.
Who do we share our data with, selling or offering of your data to third parties?
Dynamic Car Leasing will not sell your personal data to any third parties* without your written consent.
We will use your personal data for undertaking credit approvals and certain data will be stored for:
- The prevention of fraud.
- Contacting you in the event of a default (for end user customers).
- Resolving a problem relating to the supply of equipment if you are a supplier to a customer of ours.
* The only third party companies we share data with are:
Finance companies that offer leasing and finance facilities. Even then, this will only be done at a time when we are looking at a specific business opportunity or when we have been requested this information due to a dispute, default or problem in general.
Motor dealership because when arranging a vehicle delivery we will need to provide a name, address and contact number
Holding of “Special Personal Data” also known as “Sensitive personal Data.”
This relates to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and health or sex life.
Dynamic Car Leasing does not hold or collect any of this data.
Passports, driving Licences or utility bills do not form part of sensitive data.
Where information on the data subject/customer is obtained from a source other than the data subject/customer, what is that source?
There will be instances where we obtain data from a third party. Often, this is where a supplier we deal with passes up information on a prospect they are working with. We will data load and keep this information to help in obtaining a credit acceptance as long as the information is appropriate to our needs. Should you request it, we will be more than happy to disclose what information we hold and the third party we received it from.
What is soft Opt-in?
Soft opt-in is a term used to allow us to communicate with an individual even though they have not actually opted in as from the 25th May 2018. An individual could be a prospect, customer or supplier with whom we have spoken to about leasing. Under the soft opt-in rules, we are allowed to communicate with this individual via email as long as the subject matter is related to leasing and asset finance.
The soft opt-in ruling can be deemed to be ambiguous. We have interpreted this section under the new GDPR rules that we can communicate with individuals via their personal email account or mobile phone if we can clearly demonstrate we have communicated with them in the past about a relevant subject matter.
What have we done to comply with the new GDPR ruling?
Board of Directors – The directors have been fully briefed on GDPR and have appointed Data Controllers internally.
Training – All our existing staff – and new recruits – are fully trained on data protection issues and are made aware of their responsibilities through our own internal programmes.
Company mobile phones – All company mobile phones are password protected.
Company laptops – All laptops are password protected. They are hidden when in a vehicle and locked away if ever stored overnight at an office. Employees are aware on the need to keep them safe in a home environment.
Personal Data – Our CRM system, Word, Excel, Outlook are encrypted on our Server
Downloading of data – The bulk downloading of data from our CRM system has been changed so that only Data Controllers can undertake this process. Excel spreadsheets are then deleted when not needed.
Printed material – Any printed personal information is only kept for as long as that information is required for the process that it was initially requested for. Once that use has expired the data is secure shredded. Any data retained is done so in locked steel filing cabinets.
Your rights as an individual
The GDPR includes the following rights for individuals:
- 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.
You can remove consent, for any reason at any time by emailing help@dynamic-car-leasing.co.uk
Should you have any questions regarding GDPR and your data at Dynamic Car Leasing, again, please email help@dynamic-car-leasing.co.uk and our Data Controller will get back to you within two working days.
We hope that you will not find it necessary to file a complaint against our company with reference to Data Protection. Should you feel it appropriate, you will need to contact:
The Information Commissioner’s Office
Website address www.ico.org.uk
Telephone 0303 123 1113
Who are the ICO?
The ICO are the UK’s independent authority set up to uphold information rights in the public interest promoting openness by public bodies and data privacy for individuals.
Use of Cookies
Our website uses Cookies to collect the following information;
- The use of the website by the user
- The connection speed of the user
- The operating system of the user
- What time the user accessed our website
- The length of the users visit
- The users IP Address
Cookies are widely used and do not identify the individual, only the computer being used. Cookies will also serve a purpose of making it easier for you to visit our website in the future. No attempt will be made to personally identify the individual from the used IP address unless a matter of law or regulation requires it. The majority of browsers accept cookies automatically. If you wish, you can configure your browser options to refuse cookies and delete existing cookies. By doing this you may find that some areas of our website do not function correctly.
The information collected by cookies helps us to understand the usage of our website;
- Amount of visitors our website has
- Details about particular pages
- Length of time pages are viewed for
This helps us to adjust our website and tailor it to the information that is required, hopefully making the website better and easier for its users.
Telephone/Email Monitoring
For training and development purposes we may monitor, record, store or use any email, telephone or electronic communications. This helps make sure that all information given to our clients is clear and correct.
Your Privacy – Protecting it
Appropriate security measures are taken by us to ensure that sensitive personal data processed about you is kept as safe as possible. We are not liable and do not accept any responsibility for the security of any personal data transmitted via the internet. You agree that your use of the internet and our site is totally at your own risk. On occasion our website may provide banners or links to third party websites by way or advertising. We will not take any responsibility or have any control over the information that is submitted or collected by these third parties. We do not control such websites and therefore you as the user are responsible for viewing and abiding by the privacy policies that these websites provide. Some information about you may be supplied to certain third parties for services supplied to you, transport companies, manufacturers etc.
If for any reason you believe that your privacy has been breached by us, please contact us:
Compliance Manager
Dynamic Vehicle Solutions Ltd
Dynamic House
Turners Hill Rd
Crawley Down
West Sussex
RH10 4EY
Security
It is not acceptable for you to use any information, services or products supplied by us for illegal purposes including accessing, transmitting or receiving any illegally deemed material, offensive, indecent or otherwise unacceptable under UK law. You must not use any false information when communicating with us in email, telephone or any other communication. Any usernames or passwords given to you must remain secret and must never be disclosed unless our prior written authorisation is obtained first. You must not attempt unauthorised entry to access another individual’s account. You must not use our network systems or services or any other part for fraudulent activities, cross-network hacking or breach of another organisations. Any kind of illegal act in this manner will result in criminal prosecution.
Credit or Hire Applications
Upon application for a credit or hire agreement, we or the finance / leasing company will search your record via a credit reference agency. Details of this search will be added to your record and will be visible to other organisations conducting searches. Director and Partners of firms applying for credit or hire will also be searched. Any financial association you may have with other people will be viewable via the credit reference agency. In this situation you may be treated as linked and assessed with any associated records.
If you are a joint applicant, or a director of a company, you must confirm that;
- You have permission to disclose the relevant information about a joint applicant or any fellow director / partners
- You are giving us authorisation to search, record and link any information submitted to us about a joint applicant, director, partner or anyone else referred to by you
A credit scoring system will be used when assessing your application.
When an agreement has been taken, the leasing / finance company will add details of the agreement, the payments you make under the agreement and any default or failure to keep to its terms and conditions to your credit record. They will also record a failure to tell us of a change of address where a payment is overdue. The records will be shared with other organisations and will be used by both them and us in order to make future decisions about credit and/or credit related services like insurance. It will also be used to trace debtors, recover debt and manage your credit account. For the above purposes, the leasing/finance company may make further searches; these will be added to your account but will not be shared with others. If we identify fraud via false or inaccurate information, fraud prevention agencies will be informed and further action may be taken.
The following information will be shared with other organisations in order to prevent fraud and money laundering;
- Credit related accounts and facilities
- Application details for credit and credit related activities
- Debt recovery
- Applications and claims for all types of insurance
- Job applicants and Employees
Law enforcement agencies may also access this information. Fraud Prevention Agencies from other companies will also be used by us and other organisations. If you wish for us to supply you with the details of any credit reference and fraud prevention agencies from whom we obtain information, please email us at help@dynamic-car-leasing.co.uk
Sharing Your Information
Information about you and your agreement will be kept on our database. We will pass any information about you or your agreement to an administrator that you have appointed, to your insurer for claims handling, fraud prevention and administration, to insurance companies or for recovering any amounts owing or to whom we transfer an agreement to. For a small fee we can supply you with a copy of any information we hold about you. Please contact in writing at help@dynamic-car-leasing.co.uk
Using your information – Marketing
We will use your information to tell you about any products or services that we deem to be of interest to you. We may also use your information to inform you of any products or services available that we can introduce from other selected businesses. We also have the right to pass your information to agencies conducting and market research and to selected insurers who may use it for marketing purposes. At any point, you have the right to request that we do not contact you or pass your details to others for these purposes. Please email us agencies from whom we obtain information, please email us at help@dynamic-car-leasing.co.uk to request this.
