PRIVACY POLICY

The Small Print

Welcome to The Driving Skills Agency Limited's privacy policy. The Specialist Driving Skills Agency is a trading name of The Driving Skills Agency Limited. The Drive Skills Agency Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you how The Driving Skills Agency Limited collects and processes your personal data when you visit our website and tell you about your privacy rights and how the law protects you.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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. We keep our privacy policy under regular review. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Who we are and how to contact us

The Driving Skills Agency Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at The Driving Skills Agency Limited 59-61 Charlotte Street, St Paul’s Square, Birmingham B3 1PX [MS1] or by email at info@sdsa.eu.

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.

The data we collect about you

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

Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data including address, email address and telephone numbers.
Technical Data including 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 including your username and password, your preferences, feedback and survey responses.
Usage Data including information about how you use our website.
Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

How is your personal data collected?

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

Direct interactions. You may give us your Identity, Contact, Profile and Marketing and Communications Data by filling in forms on our website or by corresponding with us. This includes personal data you provide when you create an account on our website, purchase or participate in driving activities which we organise, request marketing to be sent to you, enter a competition, promotion or survey, or give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical and Usage Data about your 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 will receive personal data about you from various third parties as set out below:
1. analytics providers [such as Google based outside the EU];
2. advertising networks [such as [NAME] based [inside OR outside] the EU]; and
3. search information providers [such as [NAME] based [inside OR outside] the EU].[MS2]

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 we need to perform the contract we are about to enter into or have entered into with you.
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 obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or by following the opt-out links on any marketing message sent to you.

We have set out below, in a table format, a description of all the 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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a user of our website

(a) Identity

(b) Contact

Performance of a contract with you

To carry out any contract we have entered with you including:

(a) Performing our obligations including providing driving activity courses and/or making driving skill and capability assessments

(b) Managing payments, fees and charges

(b) Collecting and recovering money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you about your use of our products/services

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our website, to develop our website and grow our business)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) 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)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our website, to develop our website, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

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 or permitted by law.

Disclosures of your personal data[MS3]

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

Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
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 policy.

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

We are based in the UK, and we will access and use your personal data from here.

However, we may also send personal data elsewhere in the world, for example, where we use cloud-based technology or a data centre or back up facility overseas. In such instances, people in other countries may also need to access that personal data for purposes such as technical support or system development and testing. Whenever we transfer your personal data outside the UK, we ensure that a similar degree of protection is afforded to it to that applicable in the UK, by ensuring that 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 example, countries within the European Union.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the safeguards used by us when transferring personal data outside the UK.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Your duty to inform us of changes

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.

Third-party links

Our website 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 policy of every website you visit.

Your legal rights

Under certain circumstances, you have the rights under data protection laws in relation to your personal data to:

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.
Withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at The Driving Skills Agency Limited 59-61 Charlotte Street, St Pauls Square, Birmingham B3 1PX or by email at info@sdsa.eu].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

[MS1]Is this still the correct address?

[MS2]This highlighted section will only be required if you receive personal data about your users from third parties? If so, you will need to include details of what personal data you receive and from whom you receive this. If you don’t receive personal data about your users in this way, the highlighted words can be deleted.

[MS3]Are there any other third parties to which you disclose customer personal data? So, for example, do you disclose customer personal data to the bodies commissioning SDSA to undertake assessments?