Drive Smart with the Motability Scheme Fitted box Privacy Notice

Maintaining the security of your personal data is a priority for Motability Operations Ltd, (“MO”, “we”, “us”, “our”) and we are committed to respecting your privacy rights. We are also dedicated to ensuring that your data is processed lawfully and fairly and being transparent about what data we collect about you and how we use it.

This Privacy Notice explains how we and our technology supplier will collect and use the journey data gathered by Drive Smart with the Motability Scheme Fitted Box Telematics Device (Drive Smart).

It is important that you are aware that journey data will be collected and transmitted any time the Telematics Device is enabled.

You should also read the Privacy Notice provided with your Hire Agreement, as it explains how we will use the information that you provide us and that we collect from you. You can find information on your rights, how to contact us and make a complaint in this notice.

Data captured by the Drive Smart Fitted Box Telematics Device

Once installed the Fitted Box Telematics Device will record and analyse your journey data and your driving behaviour. All of your Journey data will be collected and retained by the Fitted Box Telematics device, when the Motability Scheme Vehicle is driven. The Fitted Box Telematics Device only starts recording when the engine starts and will stop recording when your journey ends. We do not record you 24/7.

It will capture and send your specific location, direction, current speed; duration of journey; braking and cornering, amongst other factors to our technology supplier’s server and we will use the information to understand road type, speed and other conditions relating to your journey. This information will be used to build up a profile of how, where, and when your car is driven. This information will be combined to form a drive score based on your driving behaviour.

How we use the data collected from the Drive Smart Fitted Box Telematics Device

We will use the journey data from the Fitted Box Telematics Device for assessing driving behaviour and your eligibility to drive your Scheme Vehicle which are reflective of driving behaviour as well as other rating factors.

Your data may be used for the following purposes:

• To help us to understand safe driving behaviours, which will inform our development of similar products, services and systems;
• To provide educational content to improve driver behaviour and manage risk;
• To determine MO’s responsibility for vehicle loss and damage and/or the entitlement to insurance benefits;
• To help prevent and detect fraud;
• To support troubleshooting and issue resolution

We will use your information in this way so that we can assess your driving score to determine the risk you pose as a driver.

How long we keep your personal data and the journey data

We will collect, process and retain your personal and journey data in accordance with data protection legislation and our policies on data retention. After seven years we will either delete or completely anonymise your data and so it is no longer identifiable to you. This allows us to use the journey anonymised data for statistical and analytical purposes.

How our suppliers use your personal data and the journey data

When you give us your information, it will be shared with our technology supplier.

The information collected by the Fitted Box Telematics Device will be used by our technology supplier for research and analytical purposes. Any information that our technology supplier shares with third parties will be made anonymous and will not contain any of your personal information. This will prevent personal data or journey data results being directly linked to you.

Our technology supplier will use your journey data for the purposes below.

• Road and vehicle usage including for road safety issues, real time traffic flow, environmental impacts such as idle time at junctions, journey times, distances and speeds, and the analysis of junctions and the risk they represent;
• Driving behaviour analysis and profiling including determining what constitutes safe and dangerous driving and the typical behaviours of various segments of the UK population;
• Analysis of the causes of, and forces involved in, collisions and other road incidents; and,
• Researching and refining techniques for analysing motor vehicle telematics data.

We and our technology supplier can use your personal information in this way because it is in our legitimate interests to provide the services in the most efficient way and understand risks of driving behaviour. We will always ensure that we keep the amount of your personal information that we collect and the extent of the processing to the absolute minimum to achieve this efficiency.

Transferring information outside the United Kingdom (“UK”)

We may transfer your personal information to countries outside of the UK, where it is necessary for the purposes for which we collected it. When we transfer your personal data outside of the UK, we ensure a similar degree of protection afforded to it by implementing at least one of the following safeguards:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK Data Protection Authority

Where we use certain service providers, we may use specific contracts approved by the European Commission and/or the UK Data Protection Authority which give personal data the same protection as it has in the UK or obtain contractual assurances from the third party given access to your personal data that your personal data will be protected by standards which are equivalent to those that protect your personal data when it is in the UK.

When do we use computers to make decisions about you?

Information recorded from your Fitted Box Telematics Device will be assessed automatically to generate your driving score. This score will be based upon a review of your specific location, direction and current speed, as well as information to understand road type, speed and other conditions relating to your journey. The driving score will be assessed against our internal models of driver behaviour to generate a driving score.

How to contact us about this privacy notice or request the deletion of data

If you have any questions about this privacy notice or how we handle your personal data, please contact the Data Protection Officer (DPO) by writing to the DPO at Motability Operations Limited, 22 Bishopsgate, 6^th Floor, London EC2N 4BQ or by email at dataprotection@mo.co.uk(opens in a new window).

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. The ICO can be contacted on 0303 123 1113 or via the website at www.ico.org.uk(opens in a new window).