CONTENTS OF PRIVACY NOTICE
What is LGVAssessment?
Explaining the legal bases we rely on
When do we collect your personal data?
What sort of personal data do we collect?
How and why do we use your personal data?
How we protect your personal data
How long will we keep your personal data?
Who do we share your personal data with?
Where your personal data may be processed
What are your rights over your personal data?
How can you stop the use of your personal data?
Contacting the Regulator
If you live outside the UK
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Pride uses your data; for example we will explain things such as our partnership with operators, your employer or potential employer.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. You’re welcome to come back and check it whenever you wish.
2. What is LGVAssessment?
LGVAssessment is a secure online database and training / assessment platform for the transport industry, managed and owned by Pride Training Uk Ltd.
For simplicity throughout this notice, ‘we’ and ‘us’ means Pride Training UK Ltd.
3. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tick the box to undertake an assessment / training.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you undertake a driving assessment to obtain work / employment with one of our partners.
Legal compliance If the law requires us to, we may need to collect and process your data.
For example, we may need to provide evidence to the HSE that you have been suitably trained and have the appropriate knowledge to undertake the work you have been assigned.
Legitimate interest In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we may send you or make available information you need to maintain the appropriate level of professionalise.
4. When do we collect your personal data?
When you visit any of our websites, and use your login details
When you create an account with us.
When you undertake a training course with us or one of our Consortium Members.
When you contact us by any means with queries, complaints etc.
When you ask us to email you information about a product or service.
When you choose to complete any surveys we send you.
When you comment on or review our products and services.
Any individual may access personal data related to them, including opinions. So if your comment or review includes information about a Consortium Member or Partner who provided that service, it may be passed on to them if requested.
When you fill in any forms. For example, if an accident happens whilst training, a Consortium Member or Partner may collect your personal data.
When you’ve given a third party permission to share with us the information they hold about you.
When you use our premises which usually have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit.
5. What sort of personal data do we collect?
If you have a web account with us: your name, gender, date of birth, Driving Licence Number, Driver’s Card number, DQC number. For your security, we’ll also keep an encrypted record of your login password.
Details of your interactions with us through our online services.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of assessments, training, web pages you visit and how and when you contact us.
Copies of documents you provide to prove your identity where the law requires this. (including your passport and driver’s licence). This will include details of your full name, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
Details of your visits to our websites.
Payment card information.
Your comments and product reviews.
Your image may be recorded on CCTV when you visit our premises or car park.
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit.
6. How and why do we use your personal data?
We want to give you the best possible customer experience. The data privacy law allows this as part of our legitimate interest in providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Here’s how we’ll use your personal data and why:
To process any assessment and training. If we don’t collect your personal data, we won’t be able to process your assessment and training and comply with our legal obligations.
For example, your details may need to be passed to a third party to provide you with employment opportunities and to obtain your Driver CPC Qualification Card DQC.
To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our business and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
To protect our customers, premises, assets, we operate CCTV systems in our premises and car parks which record images for security. We do this on the basis of our legitimate business interests.
To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice.
To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law
To process your booking. Sometimes, we’ll need to share your details with a third party who is providing a service.
7. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
8. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
9. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, operators, employers and Consortium Members, to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
IT companies who support our website and other business systems.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct purposes.
For example, sharing details of your training and assessment within the company.
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
For further information please contact our Data Protection Officer.
10. Where your personal data may be processed
We only share your personal data with third parties and suppliers based in the UK.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
11. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that Pride Training UK Ltd holds at any time, and also to have that information corrected if it is inaccurate.
To ask for your information, please contact Data Protection Officer, Pride Training UK Ltd, Mohan Business Centre, Tamworth Road, Long Eaton, NG10 1BE or email firstname.lastname@example.org.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
12. How can you stop the use of your personal data for direct marketing?
You can stop direct marketing communications from us by:
Clicking the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
Writing to Pride Training UK Ltd, Mohan Business Centre, Tamworth Road, Long Eaton, NG10 1BE.
13. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
17. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you.
This notice was last updated on 16/04/2018