7. RETENTION, UPDATING AND REMOVAL OF YOUR PERSONAL INFORMATION
• Our ethos is “for you, for life” and, whether you are contacting us for the first time or have been a customer for a while, we hope that we will be able to continue to be of service to you in future. With this in mind, where you provide us with personal information we may retain this information for future use, including:
- providing important follow-up information on your purchase, such as letting you know when your next vehicle service is due;
- undertaking surveys or market research regarding your purchase or regarding your experience of dealing with us;
- providing you with news and updates of a type you have asked to receive;
- monitoring fraud and other illegal or unlawful activity; and
- record keeping purposes.
• The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements. How long we keep data is primarily determined by how long we need it for the purposes we told you we were going to use it for, time periods set out in law and the period we need to keep it to defend ourselves against legal action. We also retain certain details for such period as may be necessary to validate and handle any motor insurance claims we receive after the statute of limitations has expired and any claims we receive where the claimant was not aware of the injuries until a long time after they were caused.
RIGHT TO RECTIFICATION
• It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. You may be able to update some of the personal information we hold about you through our customer portal. Alternatively, you can contact us using the details in paragraph 13.
RIGHT OF ACCESS
• You have a right to know what personal data we hold on you, why we hold the data and how we are processing the data. Please send your request using the details in paragraph 13 with as much information and detail as possible to help us identify the information you wish to access (ie date range, subject of request) and to allow us to deal with your request efficiently. To answer your request, we may ask you to provide identification for verification purposes.
• Upon receipt of a request, we will have 30 days to provide a response, with an extension of two further months if required. If we require more time to deal with your request, we will notify you of the delay, and the factors resulting in the delay, within 30 days of the receipt of the request. If we refuse your request, we will notify you within 30 days of the receipt of the request accompanied by the reason for the refusal.
• We will not charge a fee for any requests, provided we do not consider them to be unjustified or excessive. If we do consider these to be unjustified or excessive, we may charge a reasonable fee (also applicable for multiple copies) or refuse the request.
• You are entitled to contact the Office of the Data Protection Commissioner if we refuse your request. Contact details are below.
RIGHT TO UNSUBSCRIBE FROM MARKETING
• Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in paragraph 13. Please note however that the withdrawal of your consent will not affect any use of your personal information made before you withdrew your consent.
• If you want to stop receiving any information from us, such as news and updates, please let us know by updating your preferences through our customer portal or contacting us using the details in paragraph 13. It may take up to 28 days to unsubscribe you from marketing.
• Your decision to stop receiving information from us may result in the deletion of some of the personal information that we hold about you, but we may still retain personal information we require for other purposes, including where it is required for record keeping purposes.
RIGHT TO BE FORGOTTEN
• In certain circumstances you may be entitled to request the erasure of personal information that we hold about you:
- If the personal data is no longer required for the purposes for which it was obtained;
- Where data is being processed on the basis of consent, you withdraw consent to the processing and no other lawful basis exists;
- If the personal data is being unlawfully processed;
- Where you object to the processing of personal data and there are no overriding legitimate grounds for the processing;
- If your personal data requires deletion in line with legal requirements
• To make a request of this nature, please contact us, providing full details of the personal information you want to be erased and the reason(s) for your request. We will consider all requests upon receipt and confirm to you whether we are able to agree to your request.
• In certain circumstances we may need to retain some information to ensure your preferences are respected on completion of our duties. For example, we cannot erase all information about you where you have also asked us not to send you marketing material. Otherwise, your preference not to receive marketing material would be erased.
RIGHT TO RESTRICTION
• You have the right to restrict the extent of personal data processed by us in circumstances where:
- You believe the personal data is not accurate (restriction period will exist until we update your information);
- The processing of the personal data is unlawful but you wish to restrict the processing of data rather than erase it;
- Where the personal data is no longer required by us but you require the retention of the data for the establishment, exercise or defence of a legal claim;
- You have a pending objection to the processing of your personal data.
Where processing is restricted, your personal data will only be processed with your consent for the establishment, exercise or defence of legal claims; for the protection of the rights of other people; or for reasons important to public interest.
We will contact you to confirm where the request for restriction in fulfilled and will only lift the restriction after we have informed you that we are doing so.
RIGHT TO DATA PORTABILITY
• You have the right to the provision of all personal data held in relation to you in a structured, commonly used and machine readable format where:
- Processing is completed on the basis of contract;
- Processing is completed based on the provision of your consent;
- Processing is carried out by fully automated means.
You may also request that we send this personal data to another data controller where technically feasible.
RIGHT TO OBJECT
• You have the right to object to the processing of your personal data. However, the processing must have been undertaken on the basis of legitimate interest by us. If you wish to object to the processing of data, please contact us with your request as described in paragraph 13. We will then stop processing your personal data unless it is required for legal proceedings.
RIGHT NOT TO BE SUJECT TO AUTOMATED DECISION MAKING INCLUDING PROFILING
• You have a right not to be subject to a decision based solely on automated processing or profiling where such decisions would have a legal effect or a significant impact on you. In such circumstances you have a right to object to such processing.