Privacy Policy  – Users of TMC services

The policy below relates to users of TMC services.  For the privacy policy for website users, please click here.

This policy (together with our Acceptable Use Policy, Terms of Website Use, Cookies Policy and any other documents referred to in them) sets out the basis on which we process your data on behalf of your employer.  Your employer has engaged us to provide products and services which requires us to process your personal data.  In this context, your employer is the data controller of your personal data and we are a data processor only.  We can only act with regards your personal data, on instruction of your employer.

The Miles Consultancy Limited is registered in England and Wales under company number 04679336 and has its registered office and main trading address at Spring Farm Business Park, Moss Lane, Minshull Vernon, Cheshire, CW1 4RJ. It is a limited company.

This policy covers:

• Information we collect from you
• IP addresses
• Uses made of the information we collect
• How we store your information
• Our retention of your information
• Disclosure of your information
• Your rights in relation to your information
• Other websites
• Changes to this privacy policy
• Contact

Information we collect from you

We may collect and process the following data about you depending upon which services your employer has requested we provide in order for us to provide such services to your employer:

• Where we are providing mileage capture and audit services, we will process the following information where requested by your employer:
  • Employee ID
  • Vehicle registration
  • First and last name
  • Work email address
  • Line manager email address
  • Contact phone number
  • Home postcode
  • Work postcode
  • Vehicle details
  • The car scheme of your employer which applies to you and details of any related car/cash allowances and benefits in kind
  • Odometer readings
  • Business trip detail and commute mileage (trip mileage, purpose, date, to and from locations, whether a passenger was taken on the trip)

• • Only where our Mileage Track mobile app is used to record trips, GPS co-ordinates/locations and only where enabled at Customer’s request, Google polyline
  • Where required by your employer, data from telematics providers which if required by your employer, may include driver behaviour data including accelerometer readings, gyroscopic and GPS data

• Where we are providing fuel management and audit services, we will process the following information:

• Your fuel card number and associated administrative details
• Where we are providing fuel card administration services to your employer, we will require additional details required to order a fuel card from the relevant fuel card provider (which may include date of birth, nationality, gender, requirement for a chip-only card due to disability)

• • Data from your employer’s fuel card provider or other corporate card provider relating to the spend held on the card(s) used by you, products purchased, transaction location and vehicle odometer readings

• Where we are providing our EV charging cost calculation service, we will process the following information:
  • Home energy supplier, tariff type, day rate and night rate and start and end date of rate, bill type and payment type
  • Image of energy supplier statement

• Where we are providing our V2D driving licence checking services, we will process the following information:

• Driving licence details (full name, licence number, country of issue of licence, date of birth, home address and any other relevant addresses, driving entitlements, licence endorsements, disqualifications and convictions, Digital Tachograph Card details, photo images, CPC details)
• Image of non-GB driving licence (where non-GB checks provided)

• Where we are providing our V2D Toolkit, we will process the following information:

• Image of motor insurance certificate and insurance policy number
• Image of MOT certificate
• Eyesight test results and date of test (where requested by your employer)

• Where we are providing our work-related road risk assessment services, we will process the following information:
  • Work related road risk assessment and results
  • Details of driver training including date of training, results and comments from instructor

Note that the work-related road risk assessment services comprise profiling activities under Article 4(4) of the GDPR. However, it does not involve solely automated decision making and does not have a legal or similarly significant effect on the individual. The data you input yourself into the work-related road risk assessments and associated training is used for the profiling.  The data controller (your employer) must have a lawful basis for carrying out this profiling.  Where the lawful basis relied upon is legitimate interests, you have the right to object to such profiling.

• Where we are providing our Data+ or Transition + services, we will process the following information :

• • Details of hire vehicles or other temporary vehicles
  • Data from any vehicle leasing companies used by your employer including leasing start and end date and details of any fines incurred

• Where we are providing our EV consultancy services, we will process the following information:
  • Current living situation snd type of property you live in
  • Where your vehicle is stored overnight
  • Your current electricity supplier
  • Electricity rate in kilowatt/hour
  • Whether you have a home car charger

• Where we are providing our Mobility iQ services, we will process the following information:
  • Employee name
  • Employee ID
  • Work email address
  • Contact phone number
  • Trip detail (date, start and end location, distance, duration and mode of travel)
  • Fleet category
  • Vehicle registration

• Where we are providing our Fleet+ services, we will process the following information:

• • Employee name
  • Employee title
  • Employee ID
  • Work email address
  • Vehicle registration number
  • Use of pool car and late returns
  • Fuel card transaction data
  • Fines and damages to vehicles
  • Telematics data

• Where we are providing any of our services to your employer, other data we may process includes:

• • Any information submitted by you through our mileage capture system or by calling our call centre
  • Data from any other third party engaged by your employer that your employer requests we process as part of our service provision (such as fleet management companies)

IP addresses

Where you access our Mileage Capture system via our desktop system, we may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to interested parties. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Uses made of the information we collect

We use information held about you in the following ways:

• To provide our products and services to your employer
• To provide customer service support to you and your employer
• To carry out our obligations arising from any contracts entered into between us and your employer
• To continually improve our products and services, including adding functionality to our mileage capture system and mobile app

How we store your information

The data that we collect from you is stored on cloud servers in the UK. We maintain storage and processing practices that are designed to promote the integrity and confidentiality of personal data.  We update and test our security measures on an ongoing basis and have ISO 27001 and PCI DSS accreditation.  We use commercially acceptable means to protect your data but we cannot guarantee its absolute security as the transmission of data via the internet is never completely secure.

Our retention of your information

We retain your data for as long as necessary to enable us to: (i) provide the relevant products and services and fulfil our contractual obligations to your employer; (ii) assist your employer should it be subject to an inspection by tax authorities; (iii) comply with our legal and other contractual obligations; and (iv) resolve disputes and enforce our agreements. Specific retention periods apply for different categories of data and may be overridden by a request from your employer to delete personal data.

Disclosure of your information

We may disclose your personal information to any member of our group and to the following third parties:

• To your employer in order for us to provide our products and services to them
• To any suppliers or sub-contractors engaged by us to enable us to provide our products and services to your employer. Such suppliers or sub-contractors must comply with our data protection and security requirements.

• • Where we provide work related road risk assessment services and online and on the road driver training, these services are provided by Applied Driving Techniques (Global Solutions) Ltd.
  • Where we provide Fleet+ services, these services are provided using GAC Technology’s platform and their privacy policy is available here Privacy Policy – GAC Technology (gac-technology.com)

• To other suppliers providing services to TMC provided such suppliers comply with our data protection and security requirements
• Any potential purchaser of, or investor in, The Miles Consultancy Limited or its business and assets
• Any party to whom we are under a duty to disclose your personal data in order to comply with any legal obligation, enforce our terms of use and other agreements; or to protect the rights, property, or safety of The Miles Consultancy Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may provide third parties who work with and/or advise the government on tax issues and policies relating to our business with aggregate information from data collected about users of our products and services but such information does not identify any individual.

Your rights in relation to your information

The Miles Consultancy Limited adheres to data protection laws which are applicable to us and our services.  Where we are acting as a data processor, we have statutory and contractual duties to assist the data controller (your employer) with providing you with the below rights.  Please note in this situation, we can only act upon the instructions of the data controller (your employer) and so any requests to enforce the below rights are the responsibility of your employer as the data controller:

• If the processing of personal data is based on your consent, you have a right to withdraw consent at any time for future processing
• You have a right to request access to and rectification of your personal data. You can view, edit or delete certain of your personal information via our mileage capture system, or you may ask us to correct, update or remove information you think is inaccurate by contacting our customer service team
• You have a right to object to the processing of your personal data
• You have a right to lodge a complaint with a data protection authority
• You have the right to request a copy of the information we hold about you

Changes to our privacy policy

Any changes we may make to our privacy policy will be posted on this page and, where appropriate, notified to you by email.

Contact

Any questions, comments, requests and complaints regarding this privacy policy or your personal information should be addressed to [email protected]

EU GDPR Representative

Pursuant to Article 27 of the EU GDPR, TMC is a processor which does not have an establishment in the EU and processes personal data about data subjects in the EU.  In some cases, our customer, the data controller, may not be established in the EU.  As such we have appointed an EU GDPR representative who can be contacted by data subjects in the EU in matters relating to compliance with data protection laws, where the data controller is also not established in the EU.  Details of how to contact our representative by email or post can be found below.