Vehicles4work & Car Lease Shop Privacy Policy

Please take a few moments to read our Privacy Statement. Whether you have contacted us for an initial enquiry or a quotation, or if you are proceeding with a finance application and vehicle order – either for yourself or on behalf of your business or employer – this Statement is relevant to you. 

It has been updated considerably to reflect the new GDPR law which came into effect in May 2018 . This new legislation impacts on how companies collect, use, store and share data which might be used to identify a living person. In short, companies must be transparent and have legitimate reasons for using the data, and individuals have greater rights to update or remove data held about them. Thank you for reading. If you have any questions, please do not hesitate to contact us.

1. Introduction

Vehicles4work, Car Lease Shop and Park Street Car Sales are trading names of WRK Solutions Ltd. For the purposes of this document, ‘we’, ‘our’ or ‘us’ refers to WRK Solutions Ltd, our trading names and subsidiaries. We are committed to protecting and respecting any personal information you share with us. 

This notice applies whether you visit our premises or our websites or engage with us via other means of communication such as in person, or by telephone, email, social media or digital applications. 

WRK Solutions Limited is committed to complying with the United Kingdom Data Protection Act 1998 and the General Data Protection Regulation 2016/679. 

This policy may change so please check this page from time to time to ensure that you are happy with any changes. 

This policy was updated on and is effective from 21 May 2018.

2. What Personal Data Do We Collect?

Personal data is information which can be used to identify an individual, for example, a name, address, contact details, or more sensitive information such as employment, marital status, credit history etc. We collect personal data relevant to enable us to carry out the service you have requested or accessed, and to enable us to fulfil our legal and/or regulatory obligations and legitimate interests. Most of this information will be supplied directly from you to us, but we may also collect some data from other sources (see 2.3).

2.1 Personal Data Supplied by You

Most of the Personal Data we collect about you will have been supplied by yourself. It will be necessary to enable us to deliver the service you have asked of us, and you will have given us the data voluntarily. This could be in person when you meet with one of our representatives, or by telephone or text, via our websites, social media pages and online forums, by email, post, by postal services or by any other means of communication. In general, the level of personal data we need from you will be incremental depending on the nature of your enquiry. For example:

• General Enquiry and Quotation Requests: Your title, forename, surname; company name, year established and job title (where applicable); address (street, street number, postal code, town/city, region); email address and telephone (landline and mobile); vehicle preference, finance/contract preference and budget preference, and any special requirements. 
• Finance application, Vehicle ordering and Contract fulfilment: In addition to the above, we may collect whatever personal data is required for your finance application such as your income and expenditure (affordability check); non-detailed credit history indication (i.e. good, mixed, poor); employment history; address history, marital status, number of dependants, date of birth; identification documents (copies of driver license and address confirmation such as recent utility bills), bank account details; contract details including duration, term, payment details, penalties and terms and conditions; company details such as trading history and company directors (where applicable). 
• Vehicle Purchase: Should we purchase your vehicle, we will also require data on the vehicle’s history. 
• Competitions: Should you enter a competition run and operated by WRK Solutions Ltd we will collect your name, email address, postal address and contact telephone numbers and any further details pertinent to the competition. Terms and conditions will be published with each competition and should be referred to in addition to this policy.

2.2 Cookies and Web Data

As well as the information you give us, we may collect further Personal Data from cookies and other website activity.

Cookies 

When you visit our websites, we will ask you to accept the use of Cookies. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Cookies help us provide you with a better website and service, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. .

Other Web Data 

Your web browser may also provide us with information about your device such as your IP address and details about the browser you are using. As with cookies, this information enables us to provide a better service.

2.3 Data from other sources

We may collect Personal Data about you from other sources. This can include data you have made available via social media platforms, data from vehicle suppliers and finance providers, or data we received from third parties who have referred you to us, such as your name and contact details. 

As a finance broker, we may also collect data from Credit Reference Agencies and Companies House. 

Should you have given consent for us to send you marketing communications, we will also collect data on your interaction via our marketing suppliers.

3.How Do We Use Your Personal Data?

We will only use - i.e. process - information that is necessary for the purpose for which it has been collected and where we have a legitimate reason to do so. This will vary depending on how you chose to use our services. For example:

• Administering your information requests, vehicle quotations, finance applications, orders, payment and deliveries and policies (as is necessary for performance of a contract between you and us and/or as is necessary for our legitimate interests); 
• Carrying out anti-fraud and anti-money laundering checks and verifying your identity (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests);
• Assessing financial risks, including by carrying out credit reference checks and credit scoring assessments, (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests);
• Broking your finance agreement and any related services (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests); 
• Using your payment details to process payments or refunds relating to a service provided by us (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests); 
• Sending you information about your end of contract obligations and how to renew your vehicle hire agreement (as is necessary for compliance with our legal obligations); - Communicating with you about your quotes and policies including responding to your enquiries (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests); 
• Administering debt recoveries, where you owe us money under a contract or otherwise (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests); 
• Undertaking market research and statistical analysis, including analysing your use of our website. This allows us to develop new, or improve existing, products and services (as is necessary for our legitimate interests); and 
• Fulfilling our obligations owed to a relevant regulator or authority (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests).

Our "legitimate interests" as referred to in this document include our legitimate business purposes and commercial interests in operating our business in a customer-focused, efficient and sustainable manner, in accordance with all applicable legal and regulatory requirements. This may include:

• General client administration and business efficiency, records accuracy and other improvements to our processes and databases 
• Analysis to inform our business development strategy 
• Analysis to personalise the service we offer to you - Market research to improve our services Website administration, testing and troubleshooting 
• Process administration, testing and troubleshooting 
• Fraud prevention Network and IT security
• Post contract communications with you such as response to mid-term contract enquiries, service enquiries, contract conclusion notices, early termination enquiries, complaints. 
• GDPR compliance including complying with requests from you (e.g. at withdrawal of consent for marketing communications, confirmation that you will no longer receive marketing emails from us) 
• Business restructure, sale or part sale 
• Our legal rights and protections

3.1 When we ask for consent

We may seek your consent to use your Personal Data for other beyond that which is necessary for the performance or a contract between you and us, as is necessary for our legal obligations or as is necessary for our legitimate interests. For example, to receive our marketing emails, you must first give us your consent to do so. 

When we ask for consent it will be for a specific use of your data, and it must be given to us freely and explicitly. If, at any point, you wish to withdraw your consent (see 6.3), we will cease to use your data in that way.

3.2 Protecting You – Lawful Basis: Vital Interest

In the unlikely event that we have the reasonable belief that processing your Personal Data is vital to your life and safety, we may do so on the basis of Vital Interest.

3.3 Automated Decisions and Profiling

We do not make automated decisions when processing your data nor will we use profiling techniques.

4. Sharing Personal Data with Third Parties

We do not sell your data to third parties, but we do work closely with many third-party suppliers who fulfil business activities for us. In these situations, we only share the information as necessary for the third party to perform the processing activity it was provided for, such as:

• third party service providers who support the operation of our business, such as IT and marketing suppliers, financial service providers, delivery companies, dealer groups and debt collection agencies (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests); 
• third party insurance providers (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests). 
• fraud prevention agencies and associations, (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests); 
• regulators and law enforcement agencies, including the police, the Financial Conduct Authority or any other relevant authority who may have jurisdiction (as is necessary for compliance with our legal obligations). Some of these third parties may also be considered a data controller in respect of holding your personal data. In these cases, we will signpost the privacy statements of those parties

5. How Do We Store and Protect Your Personal Data

WRK Solutions Ltd takes the security of your Personal Data very seriously.

5.1 Where we store your Personal Data

Personal data is stored

• Digitally – on our web server, internal IT systems and cloud server service suppliers both within and out with the EEA 
• Print – client administration files held within our offices at 38 Old Street, Kilmarnock KA1 4DX and at our registered office of Bank Chambers, 31 The Square, Cumnock.

Some of our third-party suppliers may store your data out with the EEA. In such circumstances, we will endeavour to work with our suppliers to ensure your privacy rights continue to be protected as far as possible. Please note if you choose to use or access our services whilst you are out with the EEA, your data may be transferred outside the EEA automatically as part of our service delivery to you.

5.2 How long we store it for

WRK Solutions Limited will, where possible, take steps to remove and erase personal data that is no longer necessary to the purposes for which it was collected. To meet our compliance and general legal obligations – and to provide our clients with a comprehensive service - as a rule, we will retain personal data relating to brokerage of vehicles for a minimum of eight years from your most recent meaningful contact with us. Exceptions to the above include when the law requires us to do so for a longer or shorter period; and when you exercise your rights to have information erased (see section 6).

5.3 How we protect your Personal Data

• We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. For example: 
• Digital files and cloud storage password protection - regularly updated and with access strictly limited to necessary personnel 
• Print files – held securely in locked premises with access strictly limited to necessary personnel 
• Malware and Virus protection – regularly updated and installed firewalls on all devices utilised to access personal data •Website security – where possible we have tried to create as safe and secure a website as possible. However, we recognise that your use of the internet and our websites is entirely at your own risk and we have no responsibility or liability for the security of personal information transmitted via the Internet.

Links to other websites 

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

5.4 Breaches

If at any time we become aware of a breach of your Personal Data, we will notify you and the Information Commissioners Office without undue delay.

6. Your Rights

6.1 Accessing your data

GDPR gives you the right to access the data we hold about you, and the right to ‘block’ or request deletion or removal of personal data to prevent further processing when

• The personal data is no longer necessary for the purposes for which it was collected or processed 
• Consent is withdrawn •You object to the processing and there is no legitimate reason for the processing to continue 
• The personal data has been unlawfully processed 
• A legal obligation requires the erasure of the data

To initiate both or either right please contact us in writing at WRK Solutions Ltd, 38 Old Street, Kilmarnock KA1 4DX. We may ask you to verify your identity. 

When you request we provide you with the Personal Data we hold about you, we will provide this in a structured, commonly used and machine-readable format. It will be provided to you free of charge. However, should we deem the request to be manifestly unfounded, excessive or repetitive we can refuse to respond and/or charge a reasonable fee of £10 per request. 

Please note that these rights may be limited by data protection and other legislation, and we may be entitled to refuse requests where exceptions apply.

6.2 Rectifying your data

If you believe the Personal Data we hold on you is incorrect or incomplete, you have the right to rectification. Please let us know of the changes you wish us to make and we will endeavour to make the required amendments within a period of one month (two should the data changes be more complex).

6.3 Withdrawal of consent

Where you have given us consent to collect, process and use Personal Data, you have the right to withdraw that consent. Please do so by writing us at WRK Solutions Ltd, 38 Old Street, Kilmarnock KA1 4DX. 

In the case of email or other digital marketing communications, this you can also click the appropriate ‘unsubscribe’ or ‘preferences’ links included.

6.4 Complaints

If you suspect a data breach or wish to complain about any aspect of our data protection please contact us at WRK Solutions Ltd, 38 Old Street, Kilmarnock KA1 4DX telephone 01563 542820. We will process your complaint in line with our Complaints Policy. Should you be unsatisfied with our final response you have the right to complain to the Information Commissioners Office (ICO) within 3 months of your last meaningful contact with us. You can contact the ICO on 0303 123 1113 or visit their website at www.ico.org.uk.

7. Changes to this Policy

This policy may be updated and any changes will be published here. Please check back from time to time to ensure you are aware of such changes and are happy with them. If you are not happy with this policy, or any changes to it, please do not continue to use our websites or submit personal data to us. If a material change to this policy is made, we will provide a more prominent notice such as an email notification. 

Last Updated: 21 May 2018