Cogent Hire Limited Privacy Notice (General)

Your privacy on www.cogenthire.co.uk

Last updated on: 15th March 2021

 

Introduction

Welcome to the Cogent Hire Limited (‘Cogent Hire’) Privacy Notice. Cogent Hire is the data controller and is responsible for your personal data.

Cogent Hire takes data protection seriously and is committed to respecting and protecting your personal data. Your personal data is data which by itself or with other data available to us can be used to identify you.

This Privacy Notice explains how we will collect, store and use any personal data you provide via our website, email or telephone calls and when you otherwise communicate with us (including in the course of the services we provide or the running of our business or which we otherwise obtain in the course of the services we provide).

If you have any questions you can contact our Data Protection Officer at:

E-mail – Kirsty.mckno@cogenthire.co.uk

Post – Speed Medical House, Matrix Park, Chorley, Lancashire, PR7 7NA

Registration Number: 12868934, ICO Registration Number: ZB011262

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.

This Privacy Notice may change from time to time and, if it does, the up-to-date version will be available on our website and becomes effective immediately.

Please take the time to read this Privacy Notice, which contains important information about the way in which Cogent Hire processes personal data.

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 opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

For the purposes of this Privacy Notice, "Data Protection Legislation" is defined as the UK retained parts of the General Data Protection Regulation (Regulation (EU) 2016/670) (“UK GDPR”), the Data Protection Act 2018 (“DPA 2018”) or any equivalent legislation amending, supplementing or replacing the UK GDPR or DPA 2018.

 

The data we may collect about you

We may collect, or be provided with, and process information about you through various means, including:

  • from your insurer when you make a claim or report an accident which you have been involved in;
  • via our website (for example, on our ‘Contact Us’ page);
  • by email or other electronic correspondence;
  • by telephone;
  • from various third parties as set out below;
  • otherwise through providing our services or operating our business.

We collect personal data from the following parties:

  • search information providers including Verius Risk Solutions Limited and the VBASE database and Heads Up Technologies Limited;
  • public bodies including local authorities, the police and the Highways Agency;
  • other parties involved in your claim, or other related claims of yours, including solicitors and medical experts;
  • financial institutions and accountants;
  • private car parking providers; and
  • individuals who may have witnessed the incident relating to your claim.

The personal data you give to us, or which we obtain in relation to you, may include:

  • your name and title;
  • contact information, including telephone number, postal address and email address;
  • driving licence details;
  • your car registration number;
  • information related to your financial status and financial data including payment card details, bank statements and company accounts;
  • information relating to your location, preferences and/or interests;
  • photographic identification;
  • CCTV footage and other information obtained through electronic means such as swipe card records;
  • in limited circumstances, special categories of personal data;
  • the content of any enquiry submitted over our website;
  • any other personal data we collect (such as the customer reference number which may be assigned to you) in the context of providing our services or in the course of operating our business.

Each time you visit our website, we may automatically collect the following information:

  • Web usage information (e.g. IP address);
  • Information about your visit, including the full uniform resource locators (URLs) clickstream to, through and from our website.
  • We may ask you for information when you report a problem with our website.
  • If you contact us, we may keep a record of that correspondence or conversation.

We may also receive personal data from third parties which contains information regarding criminal data, including arrests, cautions, prosecutions and convictions which you have received.

The personal data described above may relate to any of the following categories of person:

  • our customers;
  • our prospective customers;
  • those who submit enquiries through our website or whose details are otherwise entered into our marketing management system.

 

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How we use your information and legal grounds for processing your information

We will rely on the following legal bases under Data Protection Legislation for processing your personal data:

 

Purpose/Activity

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

 

Performance of a contract with you

To undertake searches on you and your vehicle which may include third parties conducting checks against external databases and your social media profiles  

 

Necessary for our legitimate interests (fraud detection and prevent, to assess the validity of your data)

To process your application for a replacement vehicle and arrange for delivery of the vehicle

 

Necessary for our legitimate interests (running of our business)

 

Performance of a contract with you

 

To arrange for the recovery and repair of your vehicle

 

Necessary for our legitimate interests (running of our business)

 

Performance of a contract with you

 

To investigate and gather evidence in support of your claim

Necessary for our legitimate interests (fraud detection and prevention, to assess the validity of your claim)

 

Performance of a contract with you

 

To recover from the at fault party’s insurer sums owed for the repair of your vehicle, the hire of a replacement vehicle and any other sums relating to the processing of your claim

 

Necessary for our legitimate interests (running of our business)

 

Performance of a contract with you

 

To engage with you and contact you during the vehicle hire period

Performance of a contract with you

 

 

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

Necessary for our legitimate interests (to keep our website update and relevant and to develop our business)

 

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

Necessary for our legitimate interests (for running our business, provision of administration and IT services and network security)

 

Necessary to comply with a legal obligation

 

Sharing your information

We may share your details with third parties who are involved in processing your claim or recovery of the sums relating to your claim.

We will only share your personal data in compliance with Data Protection Legislation.

We may disclose your information to third parties for the reasons set out in the table above. We share personal data with the following parties:

  • search information providers including Verius Risk Solutions Limited and the VBASE database and Heads Up Technologies Limited;
  • public bodies including local authorities, the police and the Highways Agency;
  • other parties involved in your claim, or related claims, including solicitors and medical experts;
  • financial institutions and accountants; and
  • private car parking providers

We require all third parties to respect the security of your personal data and treat it in accordance with the law. Some of the third parties that we share your data with may process the data for their own purposes and may allow other organisations to access and process your data to prevent fraud and money laundering.

We will not sell your information.

Storage and retention of your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will procure that any third parties we engage to provide services in satisfaction of any contract between us will keep your data and that of your clients stored on their systems for as long as is necessary to provide the services to you, and to comply with applicable legal requirements.

We will not store your information for longer than is reasonably necessary or required by law, and/or as needed for the duration of our contractual relationship.

Following the completion of any contract between us, we may also need to retain your personal data for legal and regulatory purposes, including

  • pursuing any outstanding payments, and
  • for HMRC audit purposes following payment of an invoice.

Sending your information outside of the UK

We do not transfer your personal data outside of the UK.

 

Your information rights

Data Protection Legislation gives you the right to access information held about you.

We will aim to respond to any requests relating to your rights without undue delay and in any case within one month of receipt of your request.

We may ask you to confirm your identity so that we can validate a request. If you would like to make a request, please email or write to the DPO using the contact details provided above.

You have the right to:

  • Request access to your personal data and check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you if you consider that it is inaccurate.
  • Request the transfer of your personal data to you or to a third party.
  • Request erasure of your personal data. This includes where you have been successful in exercising your right to object to processing (see below). However we may not be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Request restriction of processing of your personal data. This may be the case if you want us to establish the data’s accuracy or where our use of the personal data is unlawful but you do not want us to erase it.
  • Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms.

Where you exercise your rights to request erasure, or request a restriction in the processing of your personal data or to object to processing of your personal data, we may still need to keep basic contact information about you if you are already or will shortly be an active customer as we will require this for contractual purposes.

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