CUSTOMER PRIVACY NOTICE/POLICY
Ryder Limited (“Ryder”) (“we”) respects the privacy of all individuals with whom we deal and/or whose data is provided to us in the course of our business.
This privacy notice/policy applies to customers who are individuals, and also to the employees, contractors, service providers, agents and other workers of our customers whether those customers are corporate businesses or individual customers. We will refer to this information in this privacy notice as “your personal data”. We are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data whenever that information is provided to us. This includes when you, or your business, request information from us, contact us (or we contact you), it is proposed you or they become a customer of ours, we provide vehicles and/or other goods and services to you/your business, you use our website(s), connect with us via social media, link to or from our website(s), or any other engagement we have with you (regardless of where you are based). It also tells you about your privacy rights and how the law protects you.
1 IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and process your personal data in our dealings with you, including in providing goods and services to you, and including any data you may provide through our website.
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. This privacy notice supplements the other notices and is not intended to override them.
Ryder Limited (“Ryder”) is the controller of your personal data and responsible for our website. It is part of the Ryder System Group.
Ryder has appointed a Data Protection Co-Ordinator (DPC) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPC using the details set out below.
Our full details are:
Full name of legal entity: Ryder Limited
Title: The Data Protection Co-Ordinator
Email address: DPC@ryder.com
Postal address: Ryder Ltd, Building 2610, The Crescent, Birmingham Business Park, Solihull Parkway, Birmingham, B37 7YE
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 chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This privacy notice was last updated on 08/05/18. We reserve the right to update this privacy notice at any time. We will post any amendments on our website, and will provide you with an updated privacy notice when we make any substantial changes.
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.
Our website may include links to third-party websites, plug ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2 THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes billing address, home address, email address and telephone numbers].
- Financial Data includes payment card details and, where you or your business have or apply for an account with us, bank account details and information held by credit reference and fraud prevention agencies.
- Mandatory Data includes data that we are required to obtain before conducting business with you and/or before providing a vehicle or service to you, including information to prevent money laundering (e.g. passport/driving licence details) or a driving licence evidencing your entitlement to drive the relevant vehicle.
- Transaction Data includes details about you/your business trading history, including payments from you/your business.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Profile Data includes your username and password, products/services provided to you/your business, feedback and customer satisfaction questionnaire responses.
- Usage Data includes information as to how you use our website.
- Marketing and Communications Data includes your preferences as to whether you are happy to receive marketing from us and, if so, your communication preferences.
- Monitoring Data includes footage captured on CCTV at our sites, and recording of telephone calls with us.
- Vehicle Monitoring Data. Details relating to this are set out in Section 10.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Special Category Data and Criminal Data. We may also collect, store and use the following “special categories” of more sensitive personal data, namely health and medical information, where necessary, to process insurance claims and for regulatory or legal investigations.
We may also obtain information about criminal convictions and offences (e.g. obtained in the course of credit-referencing or fraud prevention checks).
We may also obtain information about County Court or High Court judgments, though these are not considered “special category” data
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a contract you have with us but we will notify you if this is the case at the time.
3 HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial Data and Mandatory Data by filling in forms or by corresponding with us by post, phone, email, via our website, apps or on social media, or otherwise. This includes personal data you provide when you or your business:
- subscribe to our knowledge centre membership or any publications we produce;
- request promotional or marketing materials to be sent to you/your business;
- apply to become a customer;
- contract with us for the provision of contract hire or rental, dedicated delivery services, vehicle maintenance or any other product or service;
- purchase a used vehicle from us; or
- enter a competition, or respond to our customer satisfaction questionnaire.
- Third parties and publicly available sources. We may receive personal data about you from various third parties and public sources.
- Credit reference agencies and fraud prevention organisations such as Experian. When you or your business in which you are a partner or a director applies to become a customer, we will or may make searches about you with credit reference agencies and fraud prevention organisations (“CRAs”). The relevant agencies/organisations will provide information about you, such as your financial history, will keep a record of that search, and will share information from their records with us and with other business assessing applications for credit and to prevent fraud. We will record information as to your/your business’ trading history with us on any ongoing basis, and share this information with CRAs, including your settled accounts any payments not fully made on time. CRAs will share this information with other organisations. Should it become necessary to review an account, a further check with CRAs may be made, and a record kept by them of the search. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html.
- Debt collection and debtor tracing organisations,. Where your/your business’ debts are unpaid, we may share your personal information with relevant debt collection and/or debtor tracing agencies.
- Technical Data from analytics providers such as Google based outside the EU
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services inside OR outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
- HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Ordinary personal data
- Where we need it to perform a contract with you, or to take steps at your request prior to entering into a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
“Special category” data
- Where it is necessary for reasons of substantial public interest, such as the prevention of fraud.
- Where it is necessary for the establishment, exercise or defence of legal claims.
- Where it is necessary to protect your or another individual’s vital interests.
Generally we do not rely on consent as a legal basis for processing your personal data. Where we do so, we will clearly request, obtain and evidence your consent.
You have the right to withdraw consent at any time by email firstname.lastname@example.org
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To respond to an enquiry from you.||(a) Identity
|Necessary to take steps at your request prior to entering into a contract with you.
Necessary for our legitimate interests in operating our business.
|To undertake anti money-laundering, credit-referencing and anti-fraud checks in connection with applications to become a customer and in the course of conducting our business with you||(a) Identity
|Necessary to take steps at your request prior to entering into a contract with you.
Necessary for our legitimate interests in protecting our business from insolvent customers and fraud.
Necessary for reasons of substantial public interest (preventing fraud).
Necessary to comply with a legal obligation.
|To provide goods and/or services to you, and to collect and recover money owned to us||(a) Identity
|Performance of a contract with you
Necessary for our legitimate interests (to operate our business and recover debts due to us).
|To manage our business and relationship with you which will include:
(a) Day to day management activities
(b) Business management and planning, including accounting and auditing
(d) Providing and reviewing responses to our customer satisfaction questionnaire
(e) administering knowledge centre membership and download records
(d) Marketing and Communications
(f) Monitoring (call recording)
|Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to understand customer satisfaction with our services)
|To facilitate the provision of asset funding in connection with our products/services||(a) Identity
|Necessary for our legitimate interests and those of the asset funders with whom we work – to enable mandatory checks to be made before a funding decision can be made|
|To deter and prevent crime and to facilitate the detection of offenders||(a) Monitoring (CCTV)||Necessary for reasons of substantial public interest (deterrence and detection of crime)|
|To administer and protect our business including our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
|To deliver relevant website content to you [and measure or understand the effectiveness/usability of our website||(a) Identity
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing and customer relationships||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To deal with issues, complaints or disputes arising out of our relationship with you/your business, and to prevent or detect crime, including fraud||(a) Identity
|To establish, exercise or defend legal claims|
When we refer to legitimate interests we mean the interest of our business in conducting and managing our business to enable us to give you the best service/product. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
We do not undertake automated decision making using your personal data
We strive to provide you with choices regarding our use of certain personal data for marketing purposes.
Where you have agreed to receive it, we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what other products or services may be of interest to you.
We will only share your personal data for marketing purposes in accordance with your consent.
You can ask us to stop sending you marketing messages at any time by emailing UKmarketing@ryder.com at any time].
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, 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 where this is required or permitted by law.
5 DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the categories of parties set out below for the purposes set out in the table in paragraph 4 above.
- Other companies in the Ryder Group including Ryder System, Inc. as part of our regular reporting activities on company performance and for providing underlying infrastructure services.
- External third parties, including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; including the provision of hosting or other IT services, insurance claims administration, vehicle servicing, maintenance and damage repair, vehicle breakdown and recovery services, tyre fitting, CCTV and other monitoring, call recording, telematics, in-vehicle monitoring and remote vehicle diagnostics];
- analytics and search engine providers that assist us in the improvement and optimisation of our website;
- professional advisers, including lawyers, banks, auditors and insurers;
- HM Revenue and Customs, regulators and other authorities;
- entities involved in credit checking and anti-fraud activities, crime prevention/detection, risk assessment and management and dispute resolution. More detail is set out in paragraph 3 above;
- asset funding providers.
- Third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
Where these third parties are our processors, we require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Some of the third parties mentioned above, for example many professional advisers and HM Revenue and Customs, are controllers who, like us, are subject to specific obligations under data protection law, and who will have their own privacy notices setting out how they deal with personal data. Asset funding providers will be controllers. We usually only provide contact details to asset funders. Where the funder requires us to comply with money-laundering requirements on their behalf, we make the requisite enquiries and confirm we have done so, but do not provide results of our enquiries.
6 INTERNATIONAL TRANSFERS
As described in paragraph 5 above, we may share your personal data within the Ryder Group including Ryder System, Inc.
Though we do not seek actively to transfer personal data outside the European Economic Area (“EEA”), some of the external third parties we deal with [are based outside the EEA or process personal data outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.
- Whenever we transfer your personal data out of the EEA, we look to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented Transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe
7 DATA SECURITY
We have put in place appropriate security measures 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. Processors we appoint 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.
8 DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial, Mandatory and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9 YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please email email@example.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 enable us to deal with your request or to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or we have received a number of requests. In this case, we will notify you and keep you updated.
YOUR LEGAL RIGHTS
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 for 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 our legitimate interest (or that 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 situations: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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.
10 IN-VEHICLE MONITORING
To comply with legal requirements, all Contract Hire and Rental trucks, and the vehicles used to provide the Direct Delivery Service are fitted with tachographs, which record driver information including driver identifier (which may include driver name), details of driving periods and rest breaks taken.
In order to promote driver safety and that of other road users, and to provide assistance in establishing facts when an accident occurs, those vehicles are also fitted with telematics devices (Contract Hire at your request), which record various elements of information as to the manner of driving, and events such as hard braking and cornering and vehicle location. In relation to the operation of Contract Hire and Rental vehicles, our customer is the controller and, insofar as we and any contractors have access to any personal data, we are their processors. It is the responsibility of our customers to ensure that they have complied in full with their obligations under data protection law in relation to the operation of these devices, including minimising the amount of data processed and provided to us, having a lawful justification for their use and providing privacy notices in relation to them.
11 CCTV AND OTHER MONITORING
We may monitor and/or record:
(a) telephone calls;
(b) transactions and activities at all points of contact including CCTV;
(c) web traffic and activities
These are to ensure that we carry out your instructions accurately, for training purposes and to improve our services, and to ensure security and prevent fraud. For the greater security of our customers and staff, and to prevent and detect crime, we use CCTV in and around our sites and other premises.