1. PURPOSE
1.1 This Policy details the personal data Addison Lee Limited, a company incorporated in England under registered number 01205530 with registered address The Point, 37 North Wharf Road, London, England, W2 1AF, (“Addison Lee”, “we”, “us” or “our”) receives about you, how we process it and your rights and obligations in relation to your personal data while you provide services to Addison Lee.
2. DATA CONTROLLER CONTACT DETAILS
2.1 Addison Lee is the data controller for the purposes of the General Data Protection Regulation and any relevant local legislation (“Data Protection Laws”). For all data privacy inquiries and any questions or concerns you have about this Policy, please contact DriverData@addisonlee.com.
3. WHAT INFORMATION DOES ADDISON LEE COLLECT ABOUT DRIVERS?
3.1 Addison Lee holds personal data about you. If this information changes, please let us know at the earliest opportunity so that our records can be updated (see Section 7 (Your Obligations in Relation to Personal Data) below for more details).
Addison Lee will collect the following personal data about you while you provide services to us:
(a) identity information such as title, full name, date of birth, photograph, private hire licence with Transport for London (for drivers in London) or such other relevant regulator or authority (the “Transport Regulator”), drivers licence details, or proof of eligibility to enter into the driver contract;
(b) contact details such as home and work address, phone number(s), email address(es), emergency contacts and next of kin;
(c) data with respect to the driver contract, including commencement date, participation in driver training programmes, background checks (including criminal records, directorship and credit checks), membership of professional bodies and data relating to complaints;
(d) data regarding the location of the vehicle, rate of travel and other similar information transmitted from GPS trackers, telematics devices, Wi-Fi routers, forward-facing cameras, the Addison Lee-provided communications device, and similar devices which are fitted to the vehicle, whether the vehicle is being used for the provision of passenger services or for personal use;
(e) financial data, including payments for bookings, your bank or building society account details and tax numbers;
(f) information about your physical or mental health or condition;
(g) your racial or ethnic origin or religious or similar beliefs in order to monitor compliance with equal opportunities legislation; and
(h) information relating to any background check, any criminal proceedings in which you have been involved or the commission of any potential criminal or civil offence for insurance or trust purposes, or when we have been notified of any relevant potential vehicle or driving offences or where there is an allegation of parking, speeding, toll or other traffic-related incidents, and for the purposes of monitoring safety and assessing training needs, and in order to comply with legal requirements and obligations to third parties.
We receive information about you directly from you, as well as from other sources including from the relevant Transport Regulator, local authorities, law enforcement, government bodies and certain private companies (such as those responsible for managing parking, speeding, toll or other traffic-related incidents).
3.2 Some drivers choose to rent a vehicle from Eventech. If this is the case, some information will be sent to Eventech Limited, and this will be shared with Addison Lee. This information includes any information received from a vehicle video camera (when it is turned on) as well as telematics data about how the vehicle is used, including data on location of the vehicle, acceleration, breaking, mileage and fuel efficiency.
4. HOW DOES Addison Lee USE YOUR PERSONAL DATA?
4.1 Addison Lee will use your personal data for the purposes set out in the table in Appendix I. This table also sets out the legal basis for processing relied upon by Addison Lee to process your personal data.
4.2 Personal data relating to your family members or friends will be processed by Addison Lee as a contact in emergency situations. It is your responsibility to inform your family and friends members about the processing of their personal data for the described purposes and to confirm that they have given their permission.
4.3 Your personal data (excluding name and PL number) will be retained by Addison Lee for 1 year after your contract ends. Your name and PL number will be retained by Addison Lee 6 years after your contract ends.
4.4 In the following circumstances, your personal data will be retained for longer than the specified periods:
(i) as required by law or court order;
(ii) as needed to defend or pursue legal claims; and
(iii) in line with requirements from the Transport Regulator.
4.5 If you choose to rent a vehicle from Eventech, we will use the vehicle data set out at 3.2 above to provide the relevant motor insurer with relevant fleet data from time to time.
5. DISCLOSURE OF YOUR PERSONAL DATA AND TRANSFERS OVERSEAS
5.1 Disclosures and transfers to third parties
(a) Your personal data will, in certain circumstances, be disclosed to third parties for the purposes described in Appendix I. These third parties include:
(i) Insurance providers, brokers and their advisory teams: Marsh, Hill Dickinson, MSL;
(ii) Credit hire and repair providers: Cab-Aid;
(iii) Fleet management and service facilitation providers: Fleetwave, Essendex, ALK, GeoMe, CommonTime;
(iv) Cloud storage providers: AWS;
(v) IT support: Mulesoft;
(vi) Insurers and trust administrators;
(vii) the relevant Transport Regulator;
(viii) government bodies, the Police, Local Authorities and private third party entities responsible for parking, speeding, toll or other traffic-related incidents; and
(ix) third party marketing service providers, which assist us with driver recruitment by creating “lookalikes” of similar audiences to our driver community, which is then used for targeting.
Where Addison Lee is under an obligation to do so by law, or where we have a good faith belief that it is necessary to do so, we will disclose your personal data to regulators (including the relevant Transport Regulator), courts, the police or tax authorities, or in the course of litigation. In some cases, in accordance with applicable law, it may not be possible to notify you in advance about the details of such disclosures. Addison Lee will use all reasonable efforts to disclose the minimum personal data necessary in such cases.
5.2 Addison Lee will ensure that such suppliers protect your personal data with appropriate security measures and prohibit them from using your data other than as instructed by Addison Lee. The following such suppliers are located outside the EEA: Mulesoft and ALK. All suppliers that process personal data outside of the EEA are required to execute the Standard Contractual Clauses for the transfer of personal data. Please contact DriverData@addisonlee.com should you wish to examine a copy of the Standard Contractual Clauses or the privacy shield certification.
6. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA HELD BY THE COMPANY
6.1 You have certain rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please contact us at DriverData@addisonlee.com.
(a) You have the following rights in relation to your personal data:
(i) Access: to access the personal data held by Addison Lee about you and certain information about how we use it and who we share it with;
(ii) Portability: in certain circumstances, you have the right to receive or ask us to provide your personal data to a third party in a structured, commonly used and machine-readable format, although we will not provide you with certain personal data if to so would interfere with another’s individual’s rights (e.g. where providing the personal data we hold about you would reveal information about another person) or where another exemption applies (we can only do so where it is technically feasible; we are not responsible for the security of the personal data or its processing once received by the third party);
(iii) Correction: to correct any personal data held about you that is inaccurate and have incomplete data completed (including by the provision of a supplementary statement). Where you request correction, please explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal data we hold about you is inaccurate or incomplete, you can exercise your right to restrict our processing of the applicable data as described below. Where we agree that the personal data is inaccurate or incomplete, we will try to tell any third party to whom we have disclosed the relevant data so that they can rectify the data, as well;
(iv) Erasure. that we erase the personal data we hold about you:
(A) you believe that it is no longer necessary for us to hold the personal data we hold about you;
(B) we are processing the personal data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such personal data; or
(C) you believe the personal data we hold about you is being unlawfully processed by us;
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. We will retain the personal data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims) but we will let you know if that is the case.
(v) Restriction of Processing to Storage Only: to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds under Data Protection Law for us to do so (e.g. for the defence of legal claims or for another’s protection. You may request that we stop processing and just store the personal data we hold about you where:
(A) you believe the personal data is not accurate for the period it takes for us to verify whether the data is accurate;
(B) we wish to erase the personal data as the processing we are doing is unlawful but you want us to simply restrict the use of that data;
(C) we no longer need the personal data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defence of legal claims; or
(D) you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.
(vi) Objection: in certain circumstances, the right to restrict or object to our processing of your personal data (e.g. where you request correction or erasure, you also have a right to restrict processing of your applicable data while your request is considered). You also have the right to opt out of certain driver community communications that we send you.
(b) You may exercise the rights set out at items (i) through (vi) above by contacting the Data Protection Contact by emailing DriverData@addisonlee.com. If you want more detail on when the rights apply, please contact the Data Protection Contact.
(c) In the event that you wish to raise a query about how we process your personal data, please contact DriverData@addisonlee.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim the Information Commissioner’s Officer, the UK’s data protection authority.
7. YOUR OBLIGATIONS IN RELATION TO PERSONAL DATA
(a) Changes to your personal data must be updated as soon as possible by either making the changes by contacting DriverData@addisonlee.com.
(b) These include changes to the following:
(i) name;
(ii) contact details (home address, phone number(s), email address(es));
(iii) emergency contacts and next of kin;
(iv) bank details for salary payment; and
(v) License status with the relevant Transport Regulator.
(c) You may have access to personal data about other people and use this data in the course of performing the services for us under the driver contract. Under applicable Data Protection Laws, Addison Lee must ensure that the personal data it holds about its customers, passengers or other third parties is held securely and used only for appropriate purposes. You must take all reasonable steps to maintain the security of all personal data held by the Addison Lee to which you have access and you will use such personal data appropriately at all times.
8. CHANGES TO THIS POLICY
This Policy may be amended from time to time at Addison Lee’s discretion. You will be notified of any changes to these terms.
APPENDIX 1
Purposes for Processing DRIVER Data
| Purpose of Use | Categories of Personal Data processed for each purpose | Legal Basis for Processing |
| Verifying eligibility to work and carrying out background checks (where permitted under applicable law). | Identity Information such as title, full name, previous names, gender, citizenship, date of birth and proof of eligibility to work.
References, details of professional history including date of hire, driver license, full time or part-time status, qualifications, references and curriculum vitae information. Details of criminal convictions (where permitted under applicable law). |
· Necessary for entry into driver contract.
· Necessary for Addison Lee’s legal and regulatory obligations vis-à-vis the relevant Transport Regulator. · Necessary for Addison Lee’s legitimate interests (to comply with its responsibilities and help Addison Lee to prevent fraud). |
| Compliance with all relevant legal, regulatory and administrative obligation. | Transport Regulator required data (license data, customer complaints, etc.), as well as racial or ethnic origin, physical or mental health and criminal convictions data. | · Necessary for Addison Lee’s performance of the driver contract.
· Necessary for Addison Lee’s legal and regulatory obligations vis-à-vis the relevant Transport Regulator. |
| Administration of driver contract. | Data with respect to the execution of the driver contract. Compensation and other financial data, including payments and remuneration details. | · Necessary for Addison Lee’s performance of the driver contract.
· Necessary for Addison Lee’s legitimate interests (to comply with its responsibilities and to run a successful and efficient business). |
| Maintaining and ensuring business communications between Addison Lee and driver.
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Data relating to internal correspondence and the use of the driver portal and communications device. | · Necessary for Addison Lee’s performance of the driver contract.
· Necessary for Addison Lee’s legitimate interests (to comply with its responsibilities and to run a successful and efficient business). |
| Maintaining and ensuring driver community communications between Addison Lee and driver, including communications around ad hoc campaigns and driver recruitment incentives. | Identity information and contact details. | · Consent (which can be withdrawn at any time by emailing DriverData@addisonlee.com). |
| Monitoring driver compliance with Addison Lee’s policies and driver and passenger safety. | Identity information, compensation and other use data. Telematics and vehicle monitoring data.
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· Necessary for Addison Lee’s legitimate interests (to protect Addison Lee’s finances and help prevent fraud).
· Necessary for a legal obligation. |
| Maintaining the security of Addison Lee’s network and customer information. | Monitoring data relating to communications data. | · Necessary for Addison Lee’s legitimate interests (to run a successful and efficient business). |
| Contract administration including maintaining contact information (and emergency contact information). | Contact details such as home and work address, phone numbers, email addresses, emergency contacts and next of kin information (name, contact number). | · Necessary for Addison Lee’s legitimate interests (to comply with its responsibilities under the driver contract and to run a successful and efficient business).
· To protect the vital interests of the data subject. |
| Managing and reporting on queries and customer complaints or comments. | Data with respect to the execution and termination of the contract including notes regarding discussions with Addison Lee and customer complaints or comments. | · Necessary for Addison Lee’s performance of the contract.
· Necessary for Addison Lee’s legal obligations vis-à-vis the relevant Transport Regulator. |
| Responding to potential parking, speeding, toll or other traffic-related incidents. | Identity Information such as title, full name, previous names, gender, citizenship, date of birth.
Contact details such as home and work address, phone numbers, email addresses. Data with respect to the execution and termination of the contract. |
· Necessary for Addison Lee’s legal obligations.
· Necessary for Addison Lee’s legitimate interests (to comply with its responsibilities under the vehicle hire contract and to run a successful and efficient business). |
| Driver recruitment through creating lookalike profiles | Identity Information such as gender and age. | · Necessary for Addison Lee’s legitimate interests (to recruit new drivers). |
