COGENT HIRE LIMITED PRIVACY NOTICE (GENERAL)

 

Last updated on: 26^th September 2024

 

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 – Ackhurst Business Park, Conway House, Foxhole Road, Chorley, PR7 1NY

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 (https://cogenthire.co.uk/privacy) 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.

 

If you wish to raise a complaint about how we’ve handled your personal data then please contact The Data Protection Officer using the contact details above and we’ll investigate your concerns.

 

If you’re unhappy with or response, or you believe that we are processing data unfairly or unlawfully, then 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, broker, repairer, accident management company or any other party you may make contact with 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 telematics devices in vehicles we may hire to you;
• 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 Heads Up Technologies Limited;
• Financial information providers including Bridgetech Automotive Ltd who receive information from a variety of sources including Percayso Inform Limited, HM Land Registry, and Equifax;
• public bodies including local authorities, the police and the Highways Agency;
• executive agencies such as the DVLA;
• 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 searches undertaken by Heads Up Technologies Limited and Bridgetech Automotive Ltd are classed as soft credit checks. Soft credit checks do not affect your credit score and are not visible to third parties on your credit report.

 

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 held about you by HM Land Registry;
• 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.
• Telephone call recordings

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.

 

Cookies

 

View our cookies policy on our website: https://cogenthire.co.uk/cookies

 

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 publicly available social media profiles	Necessary for our legitimate interests (fraud detection and prevention, to assess the validity of your data).   Consent or via provisions of the Data Protection Act 2018 to process special category data
To process your application for a replacement vehicle and arrange for delivery and collection of the vehicle	Necessary for our legitimate interests i.e. the running of our business to ensure vehicles and any vehicle related services are provided appropriately   Performance of a contract with you
To arrange for the recovery, engineering, repair and/or salvage  of your vehicle	Necessary for our legitimate interests i.e. running of our business to deliver the repair services.   Performance of a contract with you   Consent or via provisions of the Data Protection Act 2018 to process special category data
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   Consent or via provisions of the Data Protection Act 2018 to process special category data
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 to ensure we can recover costs)   Performance of a contract with you
To engage with you and contact you before, during and after 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 up to date and relevant and to develop our business)   Performance of a contract with you
The use of telematics to monitor the use of vehicles	Necessary for our legitimate interests (to monitor the use of vehicles)   Performance of a contract with you
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
Instruction of solicitors to recover outstanding costs from the at fault insurer, other bodies or you	Necessary for our legitimate interests i.e. recovery of deferred costs   Performance of contract with you

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Sharing your information

 

We may share your details with third parties who are involved in processing your claim (both your claim as managed by us and your claim with your insurer or any other relevant party) 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 Heads Up Technologies Limited;
• Financial information providers including Bridgetech Automotive Ltd;
• the telematics providers used by our vehicle suppliers from time to time;
• 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.

 

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 need to retain your personal data for legal and regulatory purposes such as the limitation period for bringing court proceedings, pursuing any outstanding payments, and HMRC audit purposes following payment of an invoice.

 

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. Using the limitation period for issuing court proceedings as a guide, the maximum length of time we will retain your data is 6 years from the date your claim is closed.

 

Sending your information outside of the UK

 

We do not transfer your personal data outside of the UK or the EU without your permission.

 

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 (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  1. if you want us to establish the data's accuracy;
  2. where our use of the data is unlawful but you do not want us to erase it;
  3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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.