Privacy policy

INTRODUCTION

There will be two versions of this policy. The internal document, which includes version control and document approval will be published on our website but will not include document approval. Both documents must be updated in line with any changes.

PURPOSE

Solus is committed to protecting personal information. The purpose of this Privacy Policy is to inform our customers how we use your personal data, who we share it with, our lawful basis to process your personal data and your rights under UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

SCOPE

This Privacy Policy relates to our use of any personal information we collect in relation to individuals (“you”) who use our repair, engineering, claims management and total loss services.

This Privacy Policy applies whether you interact with Solus by email, telephone, SMS, in person or through our online services, including our customer app and website. This Privacy Policy is in addition to and does not affect the Privacy Policy which governs the relationship between you and your insurer or any other third party with whom you have a relationship in connection with the handling of your claim or the repair of your vehicle.

Our Approach to Privacy

The privacy and security of your personal information is very important to us. We want to assure you that your information will be properly managed and protected whilst in our hands.

The information we collect and how we collect it

We may collect information about you through a number of channels whether you approach us directly or are referred to us by your insurer or other third party for repair services, engineering, claims management and management of total loss.

This includes:

  • By email or secure online transfer from your insurance company;
  • By our online contact form, email, telephone and/or face to face from you directly; or
  • By email or telephone from third-party service providers.

The only personal data Solus collects on our website is from the online enquiry forms.

Our web site is hosted by WordPress. WordPress may collect additional personal information about your device in connection with your use of our website. Further details may be found here https://en-gb.wordpress.org/about/privacy/

We will collect the following personal information about you:

  • basic personal details such as your name, address, e-mail address, telephone number and postcode;
  • VIN number and registration number of the vehicle;
  • details about the incident;
  • threatened or actual motor convictions and threatened or actual legal action against you in connection with your use of a courtesy or hire vehicle arranged through Solus;
  • where applicable, insurer policy and claim numbers;
  • bank details;
  • finance and vehicle purchase documents

How we use your personal information and our lawful right to do so

Wherever we collect or use personal information, we will make sure we do this for a valid legal reason. This will be for at least one of the following purposes:

  • to allow us to repair your vehicle and provide ancillary services such as courtesy or hire vehicles for duration of repair – we will use your information to:
    • set up a record of your insurance claim (where applicable);
    • make all necessary arrangements in connection with the repairs to your vehicle and provision of any ancillary services;
    • monitor the progress of your claim;
    • keep you and your insurance company (as applicable) up to date with the progress of your claim;
    • arrange delivery and collection of your vehicle and any hire or courtesy vehicle, and
    • issue invoices to you.
  • to allow us to manage total loss – we will use your information to:
    • make all necessary arrangements in connection with the management of total loss
    • monitor the progress of your claim;
    • keep you up to date with the progress of your claim;
    • to verify vehicle specification and ownership
  • to allow us to provide engineering services – we will use your information to:
    • make all necessary arrangements in connection with the repairs to your vehicle
    • monitor the progress of your claim;
    • keep you and your insurance company (as applicable) up to date with the progress of your claim;
  • to allow us to process claims (claims management) – we will use your information to:
    • make all necessary arrangements in connection with the repairs to your vehicle and provision of any ancillary services;
    • monitor the progress of your claim;
    • keep you and your insurance company (as applicable) up to date with the progress of your claim;
    • arrange delivery of your vehicle and any hire or courtesy vehicle.

If you have signed up to our customer app you will be able to change your booking date, view job updates and your personal details such as address, contact details and vehicle details such as registration and VIN number. You will also be able to communicate with us and send images and videos.

If we are acting on behalf of your insurer, we process this information as a data processor, any contact information you provide will not update your records with your insurer.

If you have instructed us directly in respect of all or part of the work that we are arranging, we will be a data controller for those aspects of work for which we have been instructed directly. As a data controller, we use this information for the performance of the contract entered between you and us for vehicle repair and/or any ancillary services.

  • to make improvements to our operations – we will use your personal information to send you a customer satisfaction survey which we will ask you to complete. We will also use your personal information for research and statistical purposes, including analysis of repair cycle times and hire costs.

We use personal information for the purposes outlined above to support the legitimate interests we have as a business to improve our services.

  • to respond to threatened or actual civil proceedings made against us – we may disclose information to third parties as necessary to release our liability for any civil matters which arise during the period of hire of a courtesy or hire vehicle we have arranged for you, including in connection with any parking fines.

We disclose this information to support our legitimate interests as a business to limit our liability to third parties for incidents or parking fines raised against us but which are not our fault.

  • to respond to any notices of intended prosecution, fixed penalty notices or notification of any other motoring offences – we may pass your details to the relevant authority or third party if we receive a notice of intended prosecution or motoring penalty (including speeding penalties or other traffic violations) arising during the period of hire of a courtesy or hire vehicle we have arranged for you. This will enable them to take any necessary enforcement action against you.

We will disclose this information to meet responsibilities we have to law enforcement and to meet our legal responsibilities.

  • where we have obtained appropriate consents from you – we may need to collect or use your personal information for a particular purpose for which we need consent. This will always be explained to you separately when we ask for your consent.

If you would like to know more about any of the legal reasons or legitimate interests that apply to a particular way in which we use personal information you can contact us at any time.

How we share your information with others

In order to collect and return your vehicle, carry out repairs and provide ancillary services such as a hire or courtesy vehicle, we may have to share your information with a number of third parties including:

  • Recovery contractors;
  • Repair contractors;
  • Third party engineers
  • Parts suppliers;
  • Enterprise Rent a Car or other vehicle rental company;
  • DVLA;
  • Your insurer or other referring party;

Solus will never directly share your information outside of the UK. However, some of our suppliers may have data centres outside of the UK. Where this is in the EU, this will be covered by an adequacy decision and the relevant due diligence carried out.

Security

We are committed to protecting the confidentiality and security of the information that you provide to us and we put in place appropriate technical, physical and organisational security measures to protect against any unauthorised access or damage to, or disclosure or loss of, your information.

You should also be aware that communications over the internet, such as emails, are not secure unless they have been encrypted

Retaining personal information in our systems

We generally only keep personal information for as long as is reasonably required for the reasons explained in this privacy policy. We do keep certain transactional records –

which may include personal information – for more extended periods if we need to do this to meet legal, regulatory, tax or accounting needs. For instance, we’re required to retain an accurate record of your dealings with us, so we can respond to any complaints or challenges you or others might raise later. We’ll also retain files if we reasonably believe there is a prospect of litigation.

We maintain a data retention policy which we apply to the records we hold.

We may also retain personal information where we have identified a legal basis for doing so in an aggregated form which allows us to continue to develop/improve our products and services.

Your rights

You have legal rights under data protection laws in relation to your personal information. Click on the links to learn more about each right you may have.

  • To access personal information
  • To withdraw consent
  • To correct / erase personal information
  • To restrict how we use personal information
  • To object to how we use personal information
  • To ask us to transfer personal information to another organisation
  • To object to automated decisions
  • To find out more about how we use personal information

We may ask you for proof of identity when making a request to exercise any of these rights.

We do this to ensure we only disclose information where we know we’re dealing with the

right individual.

We’ll not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we’ll inform you before proceeding with your request.

We aim to respond to all valid requests within one month. It may however take us longer if the

request is particularly complicated or you have made several requests. We’ll always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.

We may not always be able to do what you have asked, for example if it would impact the duty of confidentiality we owe to others, or if we’re otherwise legally entitled to deal with the request in a different way.

Accessing personal information

You can ask us to:

  • confirm whether or not we have and are using your personal information
  • get a copy of your personal information

Withdrawing consent

Where we’ve asked for your consent to use your personal information, you’ll always have the right to withdraw such consent by contacting us on the details below. If you withdraw your consent, we will not be able to continue to process the information you gave us for the purpose/s we explained when you gave us your consent. This would not affect our use of information where consent is not required.

In some circumstances, once consent is withdrawn, we may not be able to provide certain products and services to you. If this is the case, we’ll tell you at the time you ask to withdraw your consent.

Correcting / erasing personal information

You can ask us to:

  • correct any information about you which is incorrect. We’ll be happy to correct such information but will need to verify the accuracy of it first.
  • erase your personal information if you think we no longer need to use it for the purpose we collected it from you.
  • erase your personal information if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, where we have used it unlawfully or where we’re subject to a legal obligation to erase your personal information.

We may not always be able to comply with your request, for example, if we need to keep using your personal information in order to comply with our legal obligation or where we need to use it to establish, exercise or defend legal claims.

Restricting our use of personal information

You can ask us to restrict our use of your personal information in certain circumstances, for example, where:

  • you think the information is inaccurate and we need to verify it;
  • our use of your personal information is not lawful but you do not want us to erase it;
  • the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your personal information but we still need to verify if we have overriding grounds to use it.

We can continue to use your personal information following a request for restriction if we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.

You can object to any use of your personal information which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal information if we can demonstrate that we have compelling legitimate interests to use the information.

Requesting a transfer of personal information

You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).

You may only exercise this right where we use your personal information in order to perform a contract with you, or where we asked for your consent to use your personal information. This right does not apply to any personal information which we hold or process based on our legitimate interest or which is not held in digital form.

Contesting decisions based on automated decision making

If we made a decision about you based solely by automated means (i.e. with no human intervention), and our decision produces a legal effect concerning you (such as the

rejection of your claim), or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we’re authorised by law to make such decisions and have adopted suitable safeguards in our decision- making processes to protect your rights and freedoms.

Contacting us for more information

If you’re not happy with the level of information provided in this privacy policy, you can ask us

about:

  • To access personal information
  • To withdraw consent
  • To correct / erase personal information
  • To restrict how we use personal information
  • To object to how we use personal information
  • To ask us to transfer personal information to another organisation
  • To object to automated decisions
  • To find out more about how we use personal information

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time for example, to keep it up to date or to comply with legal requirements. You should regularly check this Privacy Policy for updates. If there will be any significant changes made to the use of your personal information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website.

Contact us

If you have any questions about this privacy policy or how to exercise your rights, please contact our Data Protection Team.

Write to: Data Protection Team, Solus London Ltd, 1-2 Shenley Pavillions, Chalkdell Drive, MK5 6LB. Email us: dataprotection@solusarc.co.uk

Your right to complain

If you’re not happy with the way we’re handling your information, you have a right to make a complaint with your local data protection supervisory authority at any time. In the UK this is the Information Commissioners Office. (www.ico.org.uk)

We ask that you please attempt to resolve any issues with us before contacting the ICO.