Call Assist Privacy Policy

Introduction

This Privacy Policy explains in detail how Call Assist Ltd (“We/Us/Our”) collect, use, share and protect your personal data when you interact with Us as a customer, client, website visitor, or supplier. It will also provide you with a better understanding of your rights relating to your personal data and how you can exercise those rights.

Throughout this document We refer to Data Protection Legislation which means the Data Protection Act 2018 (DPA2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the aforementioned legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people of the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time.

We encourage you to take the time to carefully read the sections below. We would also ask that you share this Privacy Policy with anyone whose personal data you intend to share with Us (such as other named drivers of your vehicle).

Updating this Privacy Policy

We reserve the right to amend or update this Privacy Policy at any time and in response to changes in the Data Protection legislation. We will notify you of any changes We consider to be significant, but it is important that you come back from time to time to check for any updates and to ensure that you are happy with them.

Who We are?

We are Call Assist Ltd, Axis Court North Station Road, Colchester, Essex, CO1 1UX (Registered in England and Wales, Registered Number: 3668383). Authorised and regulated by the Financial Conduct Authority (Firm Reference Number: 304838).

For the personal data that We collect when you visit Our website, or when We interact with you when you are supplying services to Us or are one of Our clients, We are the Data Controller for your personal data. For personal data that We process to deliver vehicle recovery services to You on behalf of your insurer, We may be a Data Controller or Data Processor depending upon the insurer your policy is with.

Data Protection Officer (“DPO”)

We have a dedicated Data Protection Officer. Should you wish to exercise any of your rights under the Data Protection legislation, or have any questions relating to this Privacy Policy, please direct your enquiry to the Data Protection Officer, Call Assist Ltd, Axis Court, North Station Road, Colchester, Essex CO1 1UX or email: DPO@call-assist.co.uk.

Personal data

Personal data is information about you from which you can be identified. Dependent on which service you receive from Us, We will process different types of personal data about you. We will not process any personal data about you that We do not actually need in order to provide Our services to you.

Collecting your information

We may collect your information directly when you:

• Visit Our website
• Use Our social media
• Email, call or text Us

We may collect information from your employer where you are a representative of one of Our insurers or suppliers.

Where you are a customer of vehicle recovery services, We will be sent some basic information about you and your policy by the insurer with whom you have a policy.

What personal data do we collect?

The types of personal data We collect include:

• personal details, such as title and your full name
• contact details, such as your email address and telephone number
• date of birth
• home address
• vehicle information, such as vehicle registration, make and model, reported faults
• identification documentation, such as your UK driver’s licence, Passport, EU Identity Card, Council Tax Bill, Credit Card Statement, Pension Book and Bank Account Statement (only for the purposes of verifying your identity if you submit a rights request)
• credit/debit card details, such as the 16 digit card number, name stated on the card, expiry date, and CV2 number. We only provide the mechanism which collects this information, but it is never transmitted through or stored within Our systems
• details of beneficiaries, such as named drivers
• special categories of data, such as details regarding your health (medical conditions, disabilities) limited to those that might affect the provision of Our services to you
• records of your communication with Us, such as call recordings, emails, text messages, survey comments, complaints regarding Our products or services, made in any form, including complaints made orally, by email, letter and/or by online contact form submissions
• information relating to contests or any promotions entered
• marketing communication, such as your response to marketing from Us or through Our third parties
• policy information, such as policy start date, any callouts and/or claims made
• telemetry information, such as your mobile phone location data and IP address (which is a unique number identifying your computer), all web pages associated with Call Assist Ltd that are viewed, server requests, details of the browser (including browser type, timings, connections, updates and exceptions), and details of the device you are connected with
• fraud and theft information, such as any suspected or actual instances of fraud or theft
• Information We obtain from third parties, such as third party databases available to the insurance industry and firms, loss adjustors and/or suppliers appointed in the process of handling a claim
• cookies, for details on how we collect cookies please view our Cookies Policy.

What are Our legal grounds and purposes for collecting your personal data?

The legal basis for processing your personal data can differ depending on the personal data that We collect.

The legal basis We mainly rely on for processing personal data is legitimate interests (Article 6(1)(f) of the UK GDPR), provided your interests and fundamental rights do not override those interests. The purposes for which We will process your personal data on the basis of legitimate interest are listed below:

• To deliver Our vehicle recovery services to customers on behalf of Our insurers
• To respond appropriately to any customer queries or complaints you may have, and otherwise manage Our relationship with you
• To record Our calls for training and monitoring purposes
• To continually assess and improve Our service provision
• To assist with the security of Our infrastructure
• To ensure the proper running of Our website through the use of cookies
• For the prevention and detection of fraud, financial crime and money-laundering
• To maintain Our working relationship and contractual arrangements with Our suppliers and clients

In some cases, We may use personal data to comply with a legal obligation (Article 6(1)(c) of the UK GDPR). The purposes for which We will process your personal data on the basis of legal obligation are listed below:

• Retaining information in line with Our HMRC and FCA obligations, such as information related to financial transactions and records of complaints
• To fulfil any data subject rights requests that you may submit

In a small number of circumstances, We will seek your consent (Article 6(1)(a) of the UK GDPR) to process your personal data for the following purposes:

• to send you direct marketing emails to keep you informed of Our products and services, including but not limited to breakdown cover (e.g. other automotive or financial products, or other carefully selected offers which We believe may interest you)

Where We rely on your consent to process your personal data, you can withdraw your consent at any time by pressing the ‘unsubscribe’ button at the bottom of Our marketing emails.

Special category data

On occasion, We may also collect and store the following ‘special category’ personal data. Where We process this data, alongside a lawful basis, We have identified a special category condition for processing the data in accordance with Article 9 of the UK GDPR and the Data Protection Act 2018:

• We may collect details regarding your health (medical conditions, disabilities) where special assistance is required, in order to ensure We can provide an appropriate recovery vehicle to fit your needs (Article 9(2)(g) UK GDPR)

Automated decision-making

We use automated software to undertake an initial review of claims made using online reporting applications, such as Our app or self-service function. This software determines whether a claim should be approved or rejected. Where a claim is rejected, this decision is always reviewed by a staff member who makes the final decision about any claim rejections.

We also use automated software to allocate a vehicle recovery operator to your recovery. Any failure to auto-allocate is reviewed by a staff member to ensure appropriate allocation.

If you would like to know more about these processes, please contact Us using the details below.

Disclosing and sharing your personal data

We will only disclose/share your personal data or your policy in the following circumstances:

• it is with companies within the Call Assist Group (for the purposes of this Privacy Policy, “Call Assist Group” means Call Assist Ltd and any company or entity which Call Assist Ltd own more than 15% of the issued share capital. Companies in the Call Assist Group shall include, without limitation, Call Assist Ltd, and any other company that is incorporated within the Call Assist Group at any time in the future)
• in the event that We undergo re-organisation or are sold to a third party, in which case you agree that any personal data We hold about you will be transferred to that re-organised entity or third party
• if you have given Us consent to do so
• it is with regulatory bodies
• it is with fraud prevention and credit reference agencies
• it is required by law
• in case you make a complaint to Us about the service We have provided, We may be obliged to forward details about your complaint, including your personal data, to the Financial Ombudsman Service (“FOS”)
• it is being provided to Recovery Operators or other suppliers as required to fulfil Our contractual and legal obligations, and in which case your personal data will be limited to the minimum ordinarily required for service provision. Additionally, these service providers will only be able to use your personal data to provide the specific services.

We only share your personal data with third parties that can provide sufficient guarantees that they will process your personal data securely and in accordance with Data Protection Legislation. Our data processors cannot do anything with your personal data unless We have instructed them to do it. They will not share your personal data with any organisation apart from Us or further sub-processors which must process your personal data to the same high standards.

In the unfortunate event that you have to make a claim, then We will need to disclose your personal data to any other party involved in that claim. This will usually include:

• third parties involved with the claim, their insurer, solicitor or representative
• the insurer providing your policy
• medical team, the police or other investigators.

International personal data sharing and transfers

It may be necessary to transfer your personal data to other Group companies or service providers located outside of the UK and European Economic Area (EEA). We will not transfer your data outside the UK and EEA unless it is to a country which is considered to have equivalent Data Protection laws or We have taken all reasonable steps to ensure the firm has suitable standards in place to protect your personal data – usually in the form of entering into standard contractual clauses with the UK Addendum with the receiving party.

In the unfortunate event that you have broken down outside the UK and make a claim, then We will need to disclose your personal data to Our European business partner that is contracted to handle claims on Our behalf outside of the UK. All details for assistance required outside of the UK will be dealt with through them. They will select a local Recovery Operator in the country in which you have broken down and will send required job details to the Recovery Operator. The data passed is limited to your: full name, contact number and location of the breakdown.

Your rights

Under the Data Protection legislation, you have a number of rights relating to the personal data We hold about you. This includes the right to:

• ask for a free copy of any personal data We hold about you
• ask for correction of any inaccurate personal data held about you
• object to the use of your personal data for direct marketing
• ask for your personal data to be deleted from Our system/database. Please note that there are times when We will not be able to delete your personal data. This may be as a result of Us fulfilling Our legal and regulatory obligations, or where there is a minimum statutory period of time for which We have to keep your personal data. If We are unable to fulfil a request, We will always let you know Our reasons
• not to be subject to any automated decision making (without human involvement) where that decision produces a legal or significant effect on you. This means you can ask that We involve one of Our members of staff in the decision-making process
• obtain, move, copy or transfer your personal data in a format which enables you to transfer that personal data to another organisation. You may ask to have your personal data transferred by Us directly to the other organisation, if this is technically feasible
• request that We suspend Our processing of your personal data. Where We suspend Our processing of your personal data, We will still be permitted to store your personal data, but any other processing of this personal data will require your consent, subject to certain exemptions (for example, processing is required by law or to prevent crime)
• where We rely on your consent to process your personal data, you have the right to withdraw your consent at any time

You also have the right to complain to the Information Commissioner’s Office if you are not satisfied with Our use of your personal data (https://ico.org.uk).

Should you wish to exercise any of your rights under the Data Protection legislation, please direct your enquiry to the Data Protection Officer, Call Assist Ltd, Axis Court, North Station Road, Colchester, Essex CO1 1UX; email DPO@call-assist.co.uk.

Data Security

Your personal data is considered to be an important asset to Us, and as such, We make reasonable effort to ensure the necessary measures are in place to prevent unauthorised or inappropriate access, use, modification, disclosure or destruction.

Measures We take to keep your personal data secure include, but are not limited to:

• making regular backups of files
• protecting file servers and workstations with virus scanning software
• using a system of passwords so that access to personal data is restricted
• allowing only authorised staff into certain computer areas
• using data encryption techniques to code data when in transit
• ensuring that staff are only given sufficient rights to any systems to enable them to perform their job function.

Retaining your data

We retain your personal data in order to provide you with Our range of products and services to you and/ or to fulfil Our legal and regulatory obligations. If you decide that you no longer wish to use Our products and services, We will retain your personal data in line with Our Retention Policy and/or Our legal and regulatory requirements.

Our Retention Policy is available upon request by contacting: DPO@call-assist.co.uk.

Links to Other Website

In this website certain links, including hypertext links, will lead you to website or pages that are not under Our control. These links are provided for your information and convenience and the inclusion of any link does not imply endorsement by Us in any way of the site to which a particular link leads. We accept no responsibility or liability for the content of other websites. If you are redirected to another website via Our website, you will need to contact that organisation separately to remove your details from their records. No one may link into this site without prior written consent.