Privacy Statement and Privacy Notice
Our Privacy Statement
The Grampian Motor Training Trust (GMTT) will keep you informed of how we collect, store and process your personal data with security being a primary factor in everything we do.
As you know we have to keep a little bit of your personal data, such as your name, email address and payment details and driving licence details to enable us to make our decision to support your training and pay our contribution to you.
Finally, we will always give you the option not to receive marketing communications from us and you can always update your marketing preferences be emailing us at the address stated below.
The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your personal data with us. Where possible we will also contact you directly to notify you of any changes.
Below is our detailed Privacy Notice which is live from 17th May 2018
GMTT ("we, “us” or “our”) are committed to protecting and respecting any personal data that our current, former and potential customers (jointly referred to as “customers” or “you”) share with us.
This statement describes what types of personal data we collect from you, or that you provide to us, how it is used and processed by us, how we share it with others, how you can manage the personal data we hold and how you can contact us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
When visiting http://www.gmttrust.co.uk (and any sub-domains unless expressly excluded), you will be asked whether you accept and consent to the practices described in this notice.
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 and what your rights are.
For the purpose of the Data Protection Act 1998 (the Act) and the new General Data Protection Regulation (GDPR), the Data Controller is Grampian Motor Training Trust
PO Box 10482, Aberdeen, AB12 9BQ
What personal data do we collect from you and from where?
We will collect personal data about you and your vehicle when you use the GMTT website, complete forms on our social media pages, correspond with us over the phone, email or otherwise contact us. We will collect some or all of the following data about you:
- Name (Including Title)
- Phone Number
- Date of Birth
- Email Address
- The date and time you used our services
- Your IP Address
- The internet browser and devices you are using
- Cookie Information (please see section on Cookies for further information)
- The website address from which you accessed our site
- Marketing and communications data which includes your communication preferences in receiving marketing from us.
- If you no longer have a relationship with us attached we will hold your record for 5 years from the date our relationship ends. We hold your personal data for this period to establish, bring or defend legal claims.
- You exercise the right to have the personal data erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law.
How Do We Use This Personal Data?
GMTT will only process personal data for the purposes for which it has been collected. We use personal data held about you in the following ways and on the following legal bases:
- Consent we will only send you (as a consumer) marketing communications about goods and services we think may be of interest to you by email if we have your consent to do so. You can withdraw your consent at any time by clicking on “unsubscribe” with any communication
- Contractual - to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us. We may also rely on this basis to legitimise any processing of your personal data that is necessary to take steps at your request to enter into a contract with you e.g. discuss payment plans.
- Legitimate Interests – we may use and process your personal data as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.
Processing is necessary for us to support customers with sales and other enquiries:
- To respond to correspondence you send to us and fulfil the requests you make to us
Processing necessary for us to understand customers’ needs with a view to continually improving services:
- To analyse, evaluate and improve our products and services .
- To undertake market analysis to help us understand you better as a customer and tailor our marketing information to be more relevant to you as an individual;
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively:
- To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
- For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
- To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes we will keep a record of this on our suppression lists in order to be able to comply with your request).
- To inform you of updates to our terms and conditions and policies.
- We may process your personal data to comply with our legal obligations (for example to register your training with VOSA).
- On occasions we will need to process your personal data to contact you if there is an urgent safety or product recall notice and we need to inform you about it.
a. holding personal data for marketing purposes;
b. obtaining your marketing preferences and/or marketing choices that you have provided to any of our dealerships for the purposes of sending you e-marketing communications. Please note that we will only actually send you e-marketing communications if we have your consent and you will not receive marketing from any dealership you have not requested send you such information;
c. contacting you with marketing information by phone or post from time to time. We will only contact you with information about our own products and services and you can ask us to stop at any time. We will not contact you in this manner if you are registered on the Telephone Preference Service or Mail Preference Services (as applicable) or have asked us not to;
d. To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business or where we have obtained your business contact details. You can ask us to stop at any time. In relation to any such information we send by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing;
e. To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more please refer to the information provided on the help pages of the platforms on which you receive advertising from us;
g. To administer competitions and promotions that you enter with us from time to time and to distribute prizes.
How Do We Share This Personal Data
We will not sell your personal data to third parties.
Change Of Purpose
We will only use your personal data for the purposes for which we collected it as explained above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 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.
Where Will We Store Your Personal Data?
We hold your personal data in the UK and we ensure that adequate safeguards are put in place to protect your personal data or we otherwise meet the requirements of GDPR.
How do we keep your data secure?
Once we have received your personal data, we will use strict procedures and security features to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your computer or browser and therefore when your data is transmitted to our site; any transmission is at your own risk.
How Long Do We Keep Your Personal Data For?
We will not hold your personal data in an identifiable format for any longer than is necessary. If you are a customer or otherwise have a relationship with us we will hold personal data about you for a longer period than if we have obtained your details in connection with a prospective relationship.
You have certain rights as an individual under data protection law. These are set out below. In relation to most rights, we will ask you for personal data to confirm your identity and, where applicable, to help us search your personal data. Except in rare cases we will respond to you within one month after we have received any request (including any identification documents requested).
You have the right to:
- If we are relying on your consent, you can withdraw your consent at any time, at which point we shall stop processing your personal data in that way. Please note this does not affect the legality of our processing up to the date of your withdrawal of consent.
- You can seek to restrict our processing of your personal data or ask us to rectify any personal data we hold about you.
- You can object to us processing your personal data where we are relying on legitimate interest and we will cease processing for the purpose you object to. An exception to this would be where we have compelling legitimate grounds for processing which override your interests, rights and freedoms or where it is necessary for the establishment, exercise or defence of legal claims. You can also object to our processing your personal data for direct marketing, after which we will stop immediately
- You have the right to lodge a complaint with the Information Commissioners Office (ICO) if you think that we have infringed your rights. You can find more information about reporting a matter to the ICO at the following link: https://ico.org.uk/
- You have the right to access personal data held by us about you.
- In certain circumstances you have the right to ask us to provide you with your personal data in a structured, commonly used and machine-readable format to allow you (or us on your behalf) to transmit this information to another party. More information can be found at https://ico.org.uk
- In certain circumstances you have the right to ask us to erase the personal data we hold about you. Such circumstances include (a) where we no longer need your personal data for the purposes set out above; (b) if you withdraw your consent to our processing; (c) if you object to our processing based on our legitimate interest and we have no overriding legitimate grounds to continue processing your personal data; (d) if we process the data unlawfully; or (e) where the personal data has to be erased to comply with legal obligation to which we are subject. We will consider any such request in line with GDPR. Please note this is not an absolute right and there may be circumstances where we choose not to delete all of the personal data we hold about you. More information about your right of erasure can be found at https://ico.org.uk
You can exercise the above rights and/or manage your personal data by contacting us as below:
Grampian Motor Training Trust
PO Box 10482
0800 023 2078
What We May Need From You
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.
Your Duty To Inform Us Of Changes
It is important that the personal data we hold about you is accurate and current. Please help us by keeping us informed if your personal data changes during your relationship with us.
What are cookies?
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Cookies are used to measure which parts of the website people visit and to customer your experience. Cookies also provide information that helps us monitor and improve the website’s performance.
This version was last updated on 17th May 2018 and historic versions can be obtained by contacting us.