Last updated: 14 May 2018
When this policy mentions “Keith Elkington Transport Ltd”, “KET”, “we”, “us” or “our”, it refers to the “Data Controller”, Keith Elkington Transport Ltd.
The GDPR definition of personal information is the following:
‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
The GDPR definition of processing is the following:
‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
There are three categories of information we collect.
We ask for and collect the following personal information about you when providing you the service(s) you have requested. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested service(s).
If you visit our premises based in Milton Keynes, on arrival we record your Name, Company name and your car registration using a Sign-in device at reception.
When you visit our website, phone our office or register interest in one of our services and/or purchase one of our services, we automatically collect information, including personal information. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve our services.
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the services provided by us to create and maintain a trusted and safer environment and comply with our legal obligations.
We process this information given our legitimate interest in improving the services provided by KET, and where it is necessary for the adequate performance of the contract with you.
The Data Controller processes this information given its legitimate interest in improving the payment services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
Keith Elkington Transport Ltd. may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Keith Elkington Transport Ltd., (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms and Conditions, or (v) to protect the rights, property or personal safety of Keith Elkington Transport Ltd., its employees, its customers and suppliers, or members of the public.
Where appropriate, we may notify customers about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Keith Elkington Transport’s property, its customers and our websites. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that customer about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
We will need to share some of your Company’s information with our employees, including personal information to ensure a satisfactory performance of our contract with you.
For example, our drivers will receive names and phone numbers of your employees to be able contact them when booked for a specific job, i.e. engineers helping with installations.
KET uses a variety of third party service providers to help us provide our services. Service providers are located inside of the European Economic Area (“EEA”).
KET will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
Where permissible according to applicable law we may use certain limited personal information about you, such as the name of your business, to hash it and to share it with KET website and social media platforms, such as Facebook or Twitter, to generate leads, drive traffic to our websites or otherwise promote our products and services. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.
The social media platforms with which we may share your personal data are not controlled or supervised by Keith Elkington Transport Ltd. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.
Please note that you may, at any time ask Keith Elkington Transport Ltd. to cease processing your data for these direct marketing purposes by sending an email to GDPR@keithelkingtontranport.co.uk.
We may also share aggregated information (information about our customers/users that we combine so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
We allow limited remote working as some activities we conduct are done on sites or at home. Security controls and strict processes are in place to ensure that the risks of remote working are minimised, this includes device encryption and secure VPN connection. Only approved devices, which have been supplied by KET or our IT Company, are permitted.
We may review, scan, or analyse your communications with KET for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. In some cases, we may also scan, review, or analyse messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyse your communications to send third party marketing messages to you, and we will not sell reviews or analysis of these communications.
These activities are carried out based on Keith Elkington Transport’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
Keith Elkington Transport Ltd. website may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). KET doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, KET, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
You may exercise any of the rights described in this section by sending an email to GDPR@keithelkingtontransport.co.uk. Please note that we may ask you to verify your identity before taking further action on your request.
You may request and update some of your information by contacting us. You are responsible for keeping your personal information up-to-date.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide our services, you can request that we erase your personal information. Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain certain information from that account to prevent that individual from opening a new account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, KET may keep some of your information for tax, legal reporting and auditing obligations.
Because we maintain our platforms to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Where you have provided your consent to the processing of your personal information by KET you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of KET override your own.
In some jurisdictions, applicable law may entitle you to require KET not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing KET will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
You have the right to lodge complaints about the data processing activities carried out by KET before the competent data protection authorities. You have the right to file a complaint with the Information Commissioner’s Office.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us following the instructions in the Contact Us section below.
Keith Elkington Transport Ltd
Unit 17 Garamonde Drive
01908 585 894