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 describes how we collect and use the personal data you provide to us during the application process, when we provide services to you during the term of your lease, by using our website (motability.co.uk the “Website”), or as and when you otherwise engage with us.
What personal data do we collect and why?
We collect, store, and use the following categories of personal data about you. Some of the personal data is collected directly, for example when make an application to join the Scheme, set up on on-line account, or send an email to our customer services team. Other personal data is collected indirectly, for example from your browsing history. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
|Categories of personal data
|How we use it
|Personal data: name, date of birth, national insurance number, driver licence number, award type and bank details
|Contact data: address, telephone number (including mobile number) and email address
|Vehicle data: VIN number, registration number and connected vehicle data including but not limited to mileage data, technical vehicle data, charging data and location data
|Your online browsing activities on the Website, and Internet protocol address (IP)
|Consent (you always have the option to opt out)
|Other publicly available personal data, including any which you have shared via a public platform (such as an X feed or public Facebook page).
|Personal data we receive from trusted third parties who provide services to our customers, such as the Department for Work and Pensions, Veterans UK, Social Security Scotland, Driver Vehicle Licensing Agency, manufacturers, supplying dealers, service agents, accident managers, Motability (the registered charity) and other service providers
|Personal data you have shared for the purpose of market research (e.g. via surveys)
|Analytics tools to understand user data
We may also use your personal data in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
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.
Who we share personal data with?
We may share your personal data with third party providers as set out below:
- Companies or organisations that we have engaged to provide services on our behalf (e.g. the providers of insurance, accident manager, roadside assistance, replacement tyres, replacement windows, the supplying dealer or manufacturer of the vehicle, research agencies, cloud service provider, software services provider)
- Dealers and manufacturers where it is necessary to provide you with a vehicle, product or service
- Providers of back-up and storage services
All our third-party service providers are required to take appropriate security measures to protect your personal data. The personal data we share with them is limited to the information they require to provide their services.
We may also share your personal data with the third parties as set out below:
- Department for Work and Pensions, Veterans UK or Social Security Scotland (as relevant)
- Driver Vehicle Licensing Agency
- Motability, the registered Charity
- Any law enforcement agency, court, regulator, government authority or third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise protect our rights or the rights of any third party
- In the event of termination of the Scheme agreement between us and Motability (the registered Charity), we will disclose your personal data to Motability or the newly appointed service provider.
Transferring information outside the United Kingdom ("UK")
We may transfer your personal information to countries outside of the UK, where this is necessary for the purposes for which we collected it. Whenever 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.
How we protect your data
We are committed to keeping your personal data safe and secure. Our security measures include:
- Security controls which protect our infrastructure from external attack and unauthorised access
- Regular cyber security assessment and business continuity exercises to ensure we are ready to respond to cyber security attacks and data security incidents
- Internal policies and procedures relevant to data and data security.
In addition, we limit access to your personal data to those employees, agents, contractors and third-party service providers 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 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 purposes and in line with our internal policies. Further information in relation to data retention may be obtained by contacting the Data Protection Officer.
Your rights relating to your personal data
It is important that your personal data accurate and current. Please keep us informed if your personal data changes during your relationship with us.
You have the following rights:
- to ask what personal data we hold about you at any time
- to ask us to update and correct any out-of-date or incorrect personal data (rectification), erase or restrict the processing of personal data that we hold about you
- to object to processing of your personal data although we may not be able to continue to provide you with the services.
You can exercise any of the above rights at any time by contracting us
- If we are using legitimate interest to process your personal data you always have the right to opt out if there is something about your particular situation which makes you want to object to processing on this ground
- If you want to opt out of receiving Scheme news and/or updates on changes or developments to the Scheme you can do so by following the opt out links on any communications sent to you. Please note that this does not apply to communications about your vehicle, powered wheelchair, or scooter. However, you can choose your preferences as to how you prefer us to contact you. Alternatively, contact us on 0300 456 4566 to opt out.
Data protection officer
We have appointed the General Counsel to oversee compliance with this privacy notice. 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 DPO at Motability Operations Limited, City Gate House, 22 Southwark Bridge Road, London SE1 9HB.
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 ico.org.uk.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.