GVL Management Ltd (the Supplier) is committed to protecting the privacy and security of your personal information.
The purpose of this privacy notice is to outline how we collect and use personal information about you during and after your working relationship with the Supplier. This notice applies to all potential and existing clients.
The Supplier is a “data controller”. This means that the Supplier is responsible for deciding how we hold and use personal information about you. The Supplier is required under the data protection legislation to notify you of the information contained within this privacy notice.
The Supplier reserves the right to update this notice at any time. You should read this notice so that you aware of how and why the Supplier is using such information.
1. What are the principles of Data Protection?
1.1. The Supplier will at all times comply with data protection law. The law states that any personal information that the Supplier holds about you must be:
1.1.1. Used lawfully, fairly and in a transparent way;
1.1.2. Collected only for valid purposes that the Supplier has clearly explained to you and not used in any way that is incompatible with those purposes;
1.1.3. Relevant to the purposes that the Supplier has told you about and limited to those purposes only;
1.1.4. Accurate and kept up to date;
1.1.5. Kept only for as long as necessary for the purposes that the Supplier has told you about and is kept securely.
2. What type of information does the Supplier hold about me?
2.1. The Supplier will hold personal information about you which could identify you. This does not include data where your identity has been removed (anonymous data).
2.2. The Supplier will collect, store, and use the following categories of personal data about you, including but not limited to:
2.2.1. Personal details such as your name, title, addresses, telephone numbers and email addresses;
2.2.2. Date and place of birth;
2.2.4. Marital status;
2.2.5. Any references obtained during engagement with the Supplier;
2.2.6. Company, directors and/or partners details;
2.2.7. Operator’s Licence history;
2.2.8. Financial details;
2.2.9. Details of third party suppliers providing services to you;
2.2.10. Details of convictions;
2.2.11. Copies of training or qualification records;
2.2.12. Any correspondence or information you have shared with the Supplier;
3. How will my personal information be collected?
3.1. We will typically collect personal information about you through the enquiry and during the time of fulfilling the contract, either direct from you, or sometimes from a partner, director or any other authorized by you person.
3.2. We may sometimes collect additional information from third parties including Transport Managers, credit reference agencies or other background check agencies.
3.3. We will collect additional personal information during contract related activities throughout the period of providing services to you.
4. How will the Supplier use information about me?
4.1. The Supplier will only use your personal information when the law allows it to do so.
4.2. We will most commonly use your personal information where the Supplier needs to:
4.2.1. perform the contract which it has entered in to with you;
4.2.2. comply with a legal obligation and where it is necessary for the Supplier’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.3. We may also use your personal information in the following situations, which are likely to be rare, where
4.3.1. the Supplier needs to protect your interests (or someone else’s interests); and/or
4.3.2. it is needed in the public interest or for official purposes.
5. In what situations will the Supplier use my personal information?
5.1. The Supplier needs all the categories of information listed above at clause 2, primarily to allow the Supplier to perform its contract with you and to enable the Supplier to comply with its legal obligations.
5.2. We may in some cases use your personal information to pursue legitimate interests of our own or those of third parties, provided that your interests and fundamental rights do not override those interests.
5.3. The situations in which we will process your personal information are when we are:
5.3.1. Making a decision about services to be provided by the Supplier;
5.3.2. Determining the terms between you and the Supplier;
5.3.3. Liaising with your other providers;
5.3.4. Administering the contract which the Supplier has entered in to with you;
5.3.5. Business management and planning, including accounting and auditing;
5.3.6. Ensuring compliance with Supplier policies and procedures;
5.3.7. Education, training and development requirements;
5.3.8. Dealing with legal disputes involving you, employees, workers and contractors;
5.3.9. Complying with health and safety obligations;
5.3.10. To prevent fraud;
5.3.11. To conduct data analytics studies to review and better understand the market.
5.4. Some of the above grounds for processing will overlap and there may be several grounds which justifies the use of your personal information.
6. What happens if I fail to provide personal information?
6.1. If you fail to provide certain information when requested, the Supplier may not be able to perform the contract it entered in to with you (such as fully and correctly complete application documents).
7. Can the Supplier change the purpose for which it is using my personal data?
7.1. We will only use your personal information for the purposes for which it collected it, unless we reasonably considers we need to use it for another reason, and that the reason is compatible with the original purpose.
7.2. If the Supplier needs to use your personal information for an unrelated purpose, the Supplier will notify you and explain the legal basis for this.
7.3. The Supplier may process your personal information with your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
8. What is data sharing and how will this affect me?
8.1. The Supplier may have to share your data with third parties, including third-party service providers.
8.2. The Supplier may require third parties to respect the security of your data and to treat it in accordance with the law.
8.3. The Supplier does not transfer your personal information outside the EU.
9. Why might you share my personal information with third parties?
9.1. “Third parties” includes third-party service providers (including contractors and designated agents).
9.2. The Supplier may share personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where it has another legitimate interest in doing so, for example, organising your Public Notice.
10. How secure is my information with third-party service providers and other entities in our group?
10.1. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
10.2. To ensure the Supplier’s third-party service providers are complying with their obligations under data protection regulations and safeguarding your personal data, the Supplier may conduct audits on third party service providers from time to time as well as seeking contractual commitment for compliance with data protection obligations.
11. What about other third parties?
11.1. The Supplier may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
12. What is data security and how does this affect me?
12.1. The Supplier has put in place measures to protect the security of your information.
12.2. Third parties will only be entitled to process your personal information on the Supplier’s instructions and where we have agreed to treat the information confidentially and to keep it secure.
12.3. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.
12.4. The Supplier has put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where it is legally required to do so.
13. How long will you use my information for?
13.1. We will only retain your personal information 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.
13.2. To determine the appropriate retention period for personal data, the Supplier considers 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. In most cases this will be 7 years.
14. Do I have a duty to inform the Supplier of changes?
14.1. Yes, it is important that the personal information the Supplier holds about you is accurate and current to allow the Supplier to fulfil the contract. Please keep us informed if your personal information changes during your working relationship with us.
15. What rights do I have in connection to my personal information?
15.1. Under certain circumstances, by law you have the right to:
15.1.1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
15.1.2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
15.1.3. Object to processing of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
15.1.4. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
15.1.5. Request the transfer of your personal information to another party.
15.2. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that the Supplier transfers a copy of your personal information to another party, please contact the Operations Manager in writing.
16. Are fees usually required?
16.1. Not usually, you will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, the Supplier may charge a reasonable fee if your request for access is deemed unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
17. Will the Supplier require anything from me?
17.1. The Supplier may need to request specific information from you to help it confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive.
18. Am I able to withdraw my consent?
18.1. In the limited circumstances where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent please contact the Operations Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purposes or purposes originally agreed to, unless we have another legitimate basis for doing so in law.
19. Can this notice be amended?
19.1. Yes, the Supplier reserves the right to update this privacy notice at any time, and it will provide you with a new privacy notice when it makes any substantial updates. The Supplier may also notify you in other ways from time to time about the processing of your personal information.
19.2. If you have any questions about this notice, please contact the Operations Manager