Privacy Policy – Drivers

Driver Privacy Policy

 

Last Updated: 1st January 2021

 

Introduction

1.1 Who we are

Argyle Satellite (“Us”, “Our” or “We”), formed of Argyle Satellite Limited (company number 10755797) and Argyle Satellite Contract Services Limited (company number 10755970), is the Wirral’s largest private hire and taxi company.

 

Explained simply, our core product involves us providing a booking service to passengers enabling them to connect with hundreds of self-employed drivers across Wirral, Liverpool and Cheshire. As a self-employed driver, you offer transportation services to these passengers who have booked through Argyle Satellite and we facilitate the connection between the two parties.

 

To enable us to provide this service we process personal and other data about you, passengers, customers, visitors and users of our services and products.

 

We understand how important this information is and are committed to protecting your information and respecting your privacy. Argyle Satellite is a registered ‘data controller’ with the Information Commissioner’s Office (registration number ZA293310), as we are responsible for deciding how and why your data is used; ensuring your data is kept safe and that it is handled securely.

 

1.2 What this policy is about

 

This driver privacy policy (“Privacy Policy”) sets out the basis on which personal data and/or usage information we collect about you, or that you provide to us, by telephone, email, our website www.argylesatellite.com (“Website”), our driver portal, our mobile apps (“Apps”) or in connection with our services will be processed by us. Please read this notice carefully so that you understand your rights in relation the personal data we collect and how we use and process it.

 

In the context of this policy: ‘process’ and ‘processing’ means the collection, storage, transfer, use or action otherwise on information, ‘data subject’ as defined by the General Data Protection Regulation. ‘Personal data’ means any information that could identify, directly or indirectly, a natural person (e.g. name, address, email address), and ‘sensitive personal data’ and ‘special category personal data’ means any information consisting of data revealing health-related data/ disabilities, political opinions, racial or ethnic origin, religious beliefs, or data concerning a person’s sex life or orientation, information regarding children and vulnerable adults, and information regarding criminal records. When we process special category data Argyle Satellite will identify a lawful basis and relevant condition to do so and document it accordingly.

 

It is important that if you do not agree with this policy, in general or any part of it, you should not access the Website, the driver portal, the Apps or use our services.

 

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at drivers@argyletaxis.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 with the Information Commissioner’s Office or the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

 

What information do we collect and where does it come from?

 

2.1 Information that you give us

 

  • Driver Profiles: We collect information when you sign up to use our services or update your driver profile. The data collected includes: name, address, email, contact details, badge no/expiry, driving license no/expiry, national insurance, proof of address, photo ID (e.g. passport), vehicle make/model/colour/registration, plate no/expiry, insurance policy no/expiry, bank sort code and account number.

 

  • User content: We may collect information that you submit when you contact Argyle Satellite to leave feedback or otherwise contact us. This may include through social media, when signing up for our newsletters or marketing initiatives and correspondence (letters, emails, phone calls).

 

2.2 Information created when using our services

 

This may include:

 

  • Location information: When the driver app is running (in the foreground or background of the device), location information is collected from your PDA. This helps assist with booking allocation, tracking and auditing.

 

  • Booking Records: We collect information relating to a service user and driver’s use of our services. This includes the type and frequency of services requested and/or provided, a customer’s booking details, date and time the service was provided, amount charged on the Driver App, result of journey, distance travelled and route tracking.

 

  • Usage information: We collect information on how you interact with us and how you interact with our services. This may include access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or service you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers.

 

  • Device information: We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information. When using one of Argyle Satellite’s PDAs we will also collect the PDA telephone number and PDA pin code you use.

 

  • Communications data: We communicate directly with you and with service users; and enable you and service users to communicate with each other through our systems. To provide this service, we receive and record information regarding the calls or texts, including the date/time of the call/text and the content of the communications. Argyle Satellite may use this information to investigate complaints and resolve disputes (between ourselves and users, or between users), for safety and security purposes, to improve our products and services and for analytics.

 

2.3 Information from other sources

 

  • CCTV recordings: Our offices are fitted with outward and inward-facing CCTV cameras operating 24 hours a day. These cameras do not record audio, but your image or vehicle image may be picked up by them when you pass or enter/exit the offices. Some of the vehicles that are used by drivers who work with us are fitted with internal and external CCTV cameras. These cameras are not operated by Argyle Satellite and any data recorded is under the control of the vehicle owner, not us. The vehicle owner is responsible for the CCTV footage under his or her control.

 

As part of your agreement with us, any driver who makes any use of CCTV is required to ensure that:

 

  • Within the relevant vehicle used, there is a clear sign indicating that CCTV is in operation;
  • Inform any passengers of the presence of CCTV;
  • Ensure that the CCTV hardware is not configured to record any audio.

 

  • Information provided to us by a third-party and/or collected from public records in the case of fraud or suspected fraud.
  • Driver and service user ratings, feedback or complaints
  • Fraud prevention tools.
  • Insurance providers
  • Licensing and regulatory bodies
  • Telematic analytics.
  • Publicly available sources.
  • Marketing service providers.
  • Customers, service users or others in connection with claims or disputes.

 

Argyle Satellite may combine the information collected from these sources with other information in our possession.

 

What do we do with your information?

 

It is important that you understand how and why we use the information we collect about you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose.

 

3.1 Is this the only way?

 

We use your information only after carefully considering:

 

  • Can the same objective be achieved through other means?
  • Might it cause you or another harm by processing your data?

 

If the answer to either of these questions is YES, we do not process the data.

 

  • Would you reasonably expect us to process your data in this way?
  • By not processing your data might it cause you or another harm?
  • By not processing your data might we be in breach of our legal or regulatory obligations?

 

If the answer to any of these questions is NO, we do not process the data.

 

3.2 Why we use your information

 

Primary we use this information to:

 

  • Create, facilitate and manage your driver account.
  • Provide you access to use our services and carry out any obligations arising from this.
  • Create records of bookings, sending booking acknowledgements, confirmation, receipts and invoices (where applicable).
  • Facilitate the communication between you and service users.
  • Create invoices for your driver account and pay owed funds into specified bank accounts.
  • Contact you when necessary (e.g. your compliance documentation needs updating, there are changes to our terms of service).
  • Comply with our accreditation, legal and regulatory obligations.
  • Improve the safety and security for you, service users and the local community as a whole through the detection and prevention of fraud and crime.

 

We may also collect and use this information to:

 

  • Facilitate features to enhance, improve and reduce the number of no-job bookings, including: card payments for services, IVR, CLI, call-back, text-back, call2customer, call2driver and track-my-driver;
  • Ensure that our content and information about our services can be accessed in the most appropriate and effective manner for service users;
  • Monitor, assess and improve the quality of our services;
  • Investigate or address claims or disputes relating to your use of our services;
  • Pass on feedback (ratings, compliments, complaints) about drivers;
  • Pass on feedback (ratings) to drivers about service users;
  • Reduce the likelihood of no-shows where possible;
  • Provide you with information, products or services that you request from us or which we feel may interest you (where you have expressly consented to be contacted for such purposes).
  • Allow you to participate in competitions and to carry out any activities in relation to those competitions, for example contacting you to let you know you have won a prize using your contact telephone number to inform you;
  • Provide third-parties with anonymised statistical information about drivers, service users and customers.
  • Respond to queries, complaints or comments that you have and to make sure that these are appropriately dealt with.
  • Research and development.
  • Measure and understand the effectiveness of the content we serve to you and others
  • Notify you about changes to our services or our terms and conditions.
  • Establish facts in cases of claims or disputes.
  • Notify you about changes to our services and/or the contractor agreement and respond to queries, complaints or comments and establish facts in cases of claims or disputes.
  • Contact you when drivers are needed during busy periods and keep you informed with the latest updates.

 

Whenever possible we use aggregated and/or anonymised data for monitoring and analysis purposes. When used, this data does not enable you or any other individual to be identified.

 

3.3 Who we share your information with

 

Argyle Satellite does not sell, rent, lease or share personal information to third parties for third party direct marketing purposes. However, you should be aware that we may share your information with selected recipients. Categories of the main recipients of data include:

 

  • Customers/Service Users: To provide our service users with journey information at all stages of a journey, your vehicle details (registration, make, model, colour, vehicle plate and driver badge number) may be sent to the customer, as well as a journey receipt. To reduce the number of no-job bookings as service users are aware of the vehicle being dispatched to the customer.
  • IT support providers: To process and secure your data we use external providers who support and maintain our booking platform, network, provide SaaS or have access to our secure servers at our premises.
  • Cloud storage providers: We use both local and cloud-based storage solutions to store the personal data you provide and for disaster recovery purposes.
  • Merchant service providers: We use merchant service providers (such as Judo and Stripe) to securely process and store card and payment details.
  • App service providers: We use app service providers (such as iCabbi, Riide and their contractors) to facilitate the transportation service you request using the App. Information processed by these providers include: your precise location, name, telephone number and email address.
  • Licencing: To fulfil requirements outlined in the licencing legislations, your details will be sent to you licencing when requested.
  • We may also share your App information indirectly to contractors of the App service providers, and the services they offer the App provider, to make certain features and functionality of the App possible. These include: the payment processing services (e.g. merchant service providers), mapping and location services (Google, Waze) and the booking platform service (iCabbi).
  • Communication system providers: We use Mailchimp and other communication systems to contact you about operational changes and/or changes to terms and conditions of service.

 

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

 

  • Comply with a legal obligation, process or request.
  • Enforce our terms and conditions and other agreements, including investigation of any potential violation thereof.
  • Detect, prevent or otherwise address security, fraud or technical issues.
  • Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

 

We will also disclose your information to third parties:

 

  • In the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets.
  • If we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

 

3.4 Where we store your data

 

Your personal data is processed primarily by staff operating inside the United Kingdom (UK) who work for us or for one of our suppliers. It is possible however that your personal data may be processed by staff or systems operating outside the UK to enable the fulfilment of our services to you, the processing of your payment details and the provision of support services. In either case will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.

 

The information we collect from you is primarily stored locally on our secure servers or on UK located cloud-based storage solutions. All payment transactions are encrypted, processed and stored securely by a PCI level 1 compliant facilitator (the most stringent level of security certification available for card payment companies). Where data that we collect may be transferred to, and stored at, destinations outside the UK we have taken and will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.

 

3.5 Security of your information

 

As mentioned earlier, we have taken and will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy and our information security policy. We ensure employees within our company who have access to your data have received training on information security and UK GDPR. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website, Web-booker, App, over email or via our contact centres; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.

 

We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.

 

3.6 How long we store your information for

 

As a rule of thumb, the following records are kept up to:

 

  • 6 years from the last use or activity – User Profiles, Driver/Passenger Assistant Records, Account Records and Complaint Records.
  • 3 months from the last use or activity – CCTV Recordings.
  • 2 years from the last use or activity – Booking Records, Location Information and Communications Data.
  • 1 year from the call made to the company – Call Recordings.
  • 3 years from the completion of course – Learner Records.

 

Except otherwise mentioned in this privacy policy, we keep your personal information only for as long as required by us to:

 

  • Provide you with the services you have requested.
  • Comply with the law and all regulatory requirements.
  • Support a claim or defence in court.

 

3.7 What are your data protection rights?

 

You have rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances, and we have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please contact us at drivers@argyletaxis.com.

 

  • Access: You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with.

 

  • Correction: You also have the right to ask us to correct your personal data where it is inaccurate or incomplete.

 

  • Portability: You have the right to ask us to share (port) this data to another data controller in a structured, commonly used and machine-readable format.

 

  • Erasure: If your contractual agreement has been terminated, you have the right to ask us to delete the personal data we hold about you.

 

  • Restriction: Once your contractual agreement has been terminated, you have the right to ask us to restrict (stop any active) processing of your personal data, save for storage.

 

  • Objection: Once your contractual agreement has been terminated, the right to restrict or object to our processing of your personal information (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 can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.

 

In addition, you have the right to complain to the Information Commissioner’s Office or other applicable data protection supervisory authority.

 

Please note that these rights are sometimes limited, for example, where fulfilling your request would adversely affect other individuals or company trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data.

 

Cookies

 

When using our website, Web-Booker or Apps we may collect information about your computer or device and about your visits. We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer or mobile device. By using our website, Web-Booker or Apps, you accept we may collect and use this information as outlined below.

 

4.1 What is a cookie?

 

A cookie is a small data file which contains information that is transferred to the hard drive of the device from which you access our site. For more comprehensive information about how cookies work, see http://www.allaboutcookies.org. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

 

4.2 Types of cookies and consent

 

In order to comply with legislation, we have reviewed the use of cookies on our site and have implemented measures to ensure that you are aware of these cookies and give your consent for placing of some or all of these cookies, except for those which are necessary for the services you have requested (as explained below).

 

In summary, we use the following types of cookies:

 

  • Cookies which are essential for our site to operate, such as those which identify you so you can log into your Judo Account. These cookies will always be activated.
  • Cookies which are necessary to assist in meeting our regulatory compliance obligations, such as anti-money laundering and anti-fraud obligations, and prevent your user or driver account from being hijacked. These cookies will always be activated.
  • Cookies that help us to improve our site and to deliver a better and more personalised service to you.
  • Some cookies are not related to us or our group companies. When you visit a page with content embedded from, for example, YouTube or Twitter, you may be presented with cookies from these websites. We do not control the dissemination of these cookies: you should check the third party websites for more information about these cookies.

 

4.3 Blocking cookies

 

You can block cookies by activating the setting on your browser and device which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Our system will issue cookies as soon as you visit our site unless you have adjusted your browser setting so that it will refuse cookies.

 

Your Obligations

 

5.1 Data Sharing Obligations

 

By accessing and using our services as a driver you acknowledge that:

 

  • We are the Controller and you are a Processor of any personal data you may receive from us.
  • To facilitate provision of passenger and light good transportation services, personal data may be provided to you as a Processer and that this may include, but is not limited to: names, telephone numbers, email addresses, addresses, access requirements and lifestyle information.
  • You will comply with our documented instructions, subject to compliance with all applicable data protection legislation in relation to processing personal data.
  • You will comply with any further instructions issued by us; with respect to the processing, transferring or storage of personal data provided to you by us.

 

5.2 Processing

 

If you receive personal data from Argyle Satellite you confirm that you will:

 

  • Take all reasonable steps and actions to ensure that access is limited to only individuals who are employed by Argyle Satellite or are subject to legal/statutory obligations of confidentiality (e.g. police, taxi licensing) and who need to know/access personal data to fulfil our data privacy obligations.
  • Make available to us all information necessary to demonstrate that you have complied with your obligations to data privacy and will assist us in completing audits to confirm this.
  • Assist us with our obligation to facilitate Data Subject’s rights (e.g. access requests).
  • Assist us with our data privacy obligations, including but not limited to: the security of processing, notification of Personal Data Breaches to the supervisory authority, communication of Personal Data Breaches to affected Data Subjects, the completion of data protection documentation (e.g. DPIAs, DSAs, IAs).
  • Immediately inform us if, in your opinion, an instruction infringes or conflicts with any applicable data protection legislation and that you will not commence such processing until you have received confirmed instructions from us.
  • Not engage a Sub-Processor without our prior written consent; and where a Sub-Process is approved, you will ensure that the Sub-Processor is capable of providing the same level of protection as you are.

5.3 Transferring

 

If you receive personal data from Argyle Satellite you confirm that you will not share or transfer any personal data without our prior written consent, unless by not doing so you are in breach of any legal or regulatory requirements or your obligations under data protection legislation.

 

5.4 Storage

 

If you receive personal data from Argyle Satellite you confirm that you will:

 

  • Not make unauthorised copies of personal data for any reason.
  • Within 7 working days after (a) you have completed a booking, (b) the end of the use of our services or (c) as directed by us at any time; delete existing copies of any personal data provided to you by us, subject to compliance with all applicable data protection legislation. You will also provide evidence of this to us on request.
  • Make available to us all information necessary to demonstrate that you have and are complying with your obligations.

Other Considerations

 

6.1 Updates

 

We annually review this privacy policy to ensure it remains fit for purpose and to identify any opportunities for improvement.

 

6.2 Contact

 

We welcome questions, comments and requests regarding this policy. Please address any enquires or feedback to drivers@argyletaxis.com. Alternatively, you can also write to our Information Security Team at Argyle Satellite Limited, 15 Park Street, Birkenhead, Wirral CH41 1ET.