ACC – Privacy Statement
Accident Courtesy Car(“ACC”) privacy notice.
ACC respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
Please note that certain terms in this privacy notice are defined at the end of this notice under Definitions.
Before moving on to the content of our privacy policy, please see below a transcript of the recording that our customers hear during their initial call with us:
Initial Call Recorded Message Transcript
Thank you for choosing ACC to manage to arrange a courtesy Courtesy car.
ACC will supply you with a replacement vehicle under a rental agreement which you should read carefully. ACC or our partner company will claim your Courtesy charges and other losses (if any) from the fault insurer. Please note that under the terms of the rental agreement, you are required to provide co-operation throughout your claim. This may include using your motor insurance policy if the fault insurer is unable to deal with your claim within a time appropriate time frame (usually 1 month).
If we have informed you that you can drive under Courtesy providers insurance, you will be provided with a document, which we recommend you read, setting out the terms on which you are authorised to drive on our insurance.
Please ensure the vehicle is returned at the end of the Courtesy period with the same amount of fuel with which it was delivered to avoid incurring a refuel charge and in the same general condition
In accordance with data protection legislation, we will ensure that your personal data will be held securely by us, used only for the purposes of dealing with your vehicle Courtesy claim and shared with parties directly involved in your vehicle claim. These may include vehicle repairers, engineers, insurers, vehicle suppliers, legal advisers, claims investigators and, if applicable, the party that referred your claim to us. Your information is deleted once Courtesy is completed and settled or upon cancelation or rejection of enquiry.
We would also like to use your data for the following purposes:
for your protection and to assist with the detection and prevention of fraudulent claims, searching industry-backed fraud prevention registers
If you have any questions in relation to this message or how we use your data, please notify us.
- Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how ACC collects and processes your personal data.
Neither our website nor any of our services are intended for children and we do not knowingly collect data relating to children.
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.
Controller
Accident Courtesy data controller and responsible for your personal data (referred to as “ACC”, “we”, “us” or “our” in this privacy notice).
ACC is made up of a number of different legal entities who may provide specific services relating to your vehicle claim or courtesy Courtesy vehicle: S&G,Compass,Progress,ACC,vehicle telematic tracker services, Appointed Vehicle Engineer Inspection Service Provider (TBC upon instruction)
This privacy notice is issued on behalf of ACC so when we mention “ACC”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Accident Exchange Group responsible for processing your data. We will let you know which entity is the controller for your data when you conclude any transaction with us. ACC is the controller and responsible for our website.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Company Secretary using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Accident Courtesy Car (ACC)
For the attention of: The Company Secretary
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.
Your duty to inform us of 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 until vehicle claims and loss recovery is settled.
Third-party links
At some point, 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
- 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 follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, driving licence status and data relating to proof of identity.
Contact Data includes residential address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about any agreements you sign with us and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) addressperating system and platform and other technology on the devices you use to access our website.
Usage Data includes information about how you use products and services.
We may 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.
With the exception of information relating to road traffic offences (required for motor insurance purposes) and details of a claim for any injury suffered in a road traffic accident, we do not collect any Special Categories of Personal Data about you.
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 your Courtesy car insurance cover services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
- 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 and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Contact us or are contacted by us in relation to our products or services;
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from analytics providers such as Google, who may be based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Experian, DVLA etc.
Contact and Transaction Data from parties that are involved in your motor accident claim. For example, the party that referred your enquiry to us and our partners.
Identity and Contact Data from publicly available 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:
Where we need to perform the contract we are about to enter into or have entered into with you.
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.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver our services and our partners including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Communications
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(a) 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)
(b) Necessary to comply with a legal obligation
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Opting out
We do not send any marketing material of any form to customer. Once our interaction is complete your data in deleted.
Cookies
A Cookie is a text file that is placed on your computer by a website that you visit. They are used to make websites work, or work more efficiently, as well as to provide information to the owners or operators of the website.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
Our website makes use of cookies to monitor visitor sessions. No personal information is stored in the cookie that is issued by the site. The value stored in the cookie is an anonymous identifier, which is not linked to any other personal information you may give us during your visit. If you do not wish to receive these cookies you can disable them in your browser but this may affect the functionality of our website.
Most web browser settings allow some control of cookies. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. We do not enter into cookie tracking.
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 you wish to get an explanation as to how the processing for the new purpose 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, in compliance with the above rules, where this is required or permitted by law.
- Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Parties involved in the administration of your vehicle claim or Courtesy vehicle provision. These include vehicle repairers, engineers, insurers, vehicle suppliers, legal advisers, claims investigators and, if applicable, the party that referred your enquiry to us if applicable.
If your vehicle repair is funded by a third party on a credit basis we will disclose Identity and Contact Data to third party to enable them to offer you repair funding services. We may also disclose Identity and Contact Data to a third party sub-contractor
Internal Third Parties as set out in the Definitions.
External Third Parties as set out in the Definitions.
Third parties to 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.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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 and limited to our instructions.
- International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
- 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. They 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
- 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.
For details of retention periods for different aspects of your personal data, please us.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers. We adopt a long-stop period of seven years. After this time all date is deleted.
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.
- Your legal rights
Under certain circumstances, you the following rights under data protection laws in relation to your personal data:
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 contact the Company Secretary
No fee usually required
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.
What we may need from you
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 speed up our response.
Time limit to respond
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 you have made a number of requests. In this case, we will notify you and keep you updated.
- Definitions
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other partner companies to ACC (acting as processors) and who are based in the UK and provide certain services in relation to the services we provide and the administration of your claim.
External Third Parties
Service providers acting as processors who provide IT and system infrastructure and administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide their respective services to us.
HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who may require reporting of processing activities in certain circumstances.
Organisations involved in the prevention and detection of insurance fraud.
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 of 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 a legitimate interest
Request restriction of processing of your personal data.
Request the transfer of your personal data to you or to a third party
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.