Loading...

Privacy Policy

Privacy Policy

Context and overview

Introduction

Cotswold Motor Group Ltd. needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees, and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled, and stored to meet the company’s data protection standards — and to comply with the law.


Why this policy exists

This data protection policy ensures Cotswold Motor Group Ltd.:

  • Complies with data protection law and follow good practice
  • Protects the rights of staff, customers and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

 

Data protection law

The Data Protection Act 1998 describes how organisations — including Cotswold Motor Group Ltd. — must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say that personal data must:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant, and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection


People, risks, and responsibilities Policy scope


This policy applies to:

  • The head office of Cotswold Motor Group Ltd.
  • All branches of Cotswold Motor Group Ltd.
  • All staff and volunteers of Cotswold Motor Group Ltd.
  • All contractors, suppliers and other people working on behalf of Cotswold Motor Group Ltd.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • Driving Licence details
  • Interests and Hobbies


Data protection risks

This policy helps to protect Cotswold Motor Group Ltd. from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.


Responsibilities

Everyone who works for or with Cotswold Motor Group Ltd. has some responsibility for ensuring data is collected, stored, and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

  • The board of directors is ultimately responsible for ensuring that Cotswold Motor Group Ltd. meets its legal obligations.
  • The Group HR and Process Manager, Karen Evans, is responsible for:
    • Keeping the board updated about data protection responsibilities, risks and issues.
    • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
    • Arranging data protection training and advice for the people covered by this policy.
    • Handling data protection questions from staff and anyone else covered by this policy.
    • Dealing with requests from individuals to see the data Cotswold Motor Group Ltd. holds about them (also called ‘subject access requests’).
    • Checking and approving any contracts or agreements with third
      parties that may handle the company’s sensitive data.
  • The Group IT Manager, Stephen Murray, is responsible for:
    • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
    • Performing regular checks and scans to ensure security hardware and software is functioning properly.
    • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
  • The Group HR and Process Manager, Karen Evans, is responsible for:
    • Approving any data protection statements attached to communications such as emails and letters.
    • Addressing any data protection queries from journalists or media outlets like newspapers.
    • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
  • Cotswold Motor Group Ltd. will provide training to all employees to help them understand their responsibilities when handling data.
  • Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords must be used and they should never be shared.
  • Personal data should not be disclosed to unauthorised people, either within the company or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
  • Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.


Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  • Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between employees.
  • If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.


Data use


Personal data is of no value to Cotswold Motor Group Ltd. unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers.
    Always access and update the central copy of any data.
  • Credit Card information will not be stored electronically or in hard copy.

Call recordings will be paused when credit card details are given over the phone.


Data accuracy


The law requires Cotswold Motor Group Ltd. to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Cotswold Motor Group Ltd. should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • Cotswold Motor Group Ltd. will make it easy for data subjects to update the information Cotswold Motor Group Ltd. holds about them.
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
  • It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.


Subject access requests


All individuals who are the subject of personal data held by Cotswold Motor Group Ltd. are entitled to:

  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the company is meeting its data protection obligations.


If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at sar@cotswoldgroup.com. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.


Disclosing data for other reasons


In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Cotswold Motor Group Ltd. will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.


Providing information


Cotswold Motor Group Ltd. aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How the data is being used
  • How to exercise their rights


To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

This is available on request. A version of this statement is also available on thecompany’s website.

Company Information

Company Information

Registered Name: Cotswold Motor Group

Company Registered Number: 3028787

Place of Registration: England

Registered Office Address: Tewkesbury Road, Cheltenham, Gloucestershire GL51 9SG

VAT Number: 435362458

FCA Status Disclosure: Cotswold Motor Group Limited is authorised and regulated by the Financial Conduct Authority for regulated consumer credit activities and is an appointed representative of South Quay Limited in relation to its general insurance mediation. South Quays Limited is authorised and regulated by the Financial Conduct Authority.

Complaints Procedure

Complaints Procedure

BMW (UK) Limited (BMW) is committed to providing products and service of the highest standard. But we do understand that sometimes things can go wrong. If you have a concern or are dissatisfied in any way, we’ll do our best to help resolve the situation in a fair and transparent way.

BMW will investigate all complaints competently, diligently and impartially obtaining additional information as necessary. Every complaint will be assessed fairly, consistently and promptly taking into account all relevant factors to ensure a fair outcome for you.

Step 1

Discussion with your BMW Centre.

If you have a concern with either your vehicle or the service you have received at your BMW Centre, please firstly raise this with the Service Manager or Head of Business at the BMW Centre itself. They are best placed to address your concerns and if required, will contact us directly on your behalf.

 

Step 2

Contacting us.

Should you remain unhappy with your BMW Centre’s response, please contact us by your preferred method from the list below.

Customer Service
BMW (UK) Limited
Summit ONE
Summit Avenue
Farnborough
Hampshire GU14 0FB

Telephone:

0370 5050 160

Email:

customer.service@bmw.co.uk

We’re here:
9am - 6pm Monday to Friday

What you will need to provide.

To help us investigate and try to resolve your complaint, please provide us with the following information:

  • your name and address;
  • details of how we can contact you;
  • a clear description of your complaint;
  • details of what you would like us to do to rectify the situation; and
  • if appropriate, copies of any relevant supporting documentation.

Our commitment to you.

  • We’ll thoroughly investigate your complaint and offer a fair response that will take into account all the information available to us
  • We will do our best to resolve your complaint quickly, by the end of the next business day if possible. If this is not possible, and your complaint relates to our credit broking, we will:
    • within 5 working days, provide a written acknowledgement of your complaint and give you the details of who is handling the case and how to contact them
    • keep you updated on the progress of your complaint, and
    • within 8 weeks of receiving your complaint, we will either: write to you with our final response and the reasons for providing this response, or explain why we are not in a position to give you a final response and let you know when we expect to be able to provide it.
  • In some cases we’ll need to contact your BMW Centre for more information. If appropriate, we may refer the complaint directly to them for information or action
  • We may not always provide the answer you are looking for, but we’ll make sure we offer a clear explanation for our decision

 

Financial Services

If your complaint relates to a finance agreement with BMW Financial Services, please click below for details on BMW Financial Services’ complaint handling procedure.

Find out more

 

Step 3

What if I remain unhappy with your response?

If you are dissatisfied with either our final response, or the reasons for any delay in providing our final response you may be able to ask the Financial Ombudsman Service for an independent review.

To be able to ask them for an independent review your complaint must be in relation to our credit broking activities that is to say any marketing material or recommendations we make in relation to any finance offers from BMW Financial Services (GB) Limited and you must have given us the opportunity to find a resolution first. You must also be a private individual, or a business, charity or trust with an annual turnover of less than 2 million euros and fewer than 10 employees.

If you wish to pursue your complaint to the Financial Ombudsman Service you must do so within 6 months from the date on which we send you our final response letter. The Financial Ombudsman’s details are:

The Financial Ombudsman Service
Exchange Tower
London
E14 9SR

Telephone:

0300 123 9 123

Email:

complaint.info@financial-ombudsman.org.uk

Website:

www.financial-ombudsman.org.uk

You may also raise a complaint with any of the trade bodies listed below.

 

Motor Codes

Motor Codes is a government-backed, self-regulatory body for the motor industry. BMW subscribes to the New Car Code, which covers the sale of new cars, warranties, the availability of replacement parts, and advertising and complaint handling. In addition, our BMW Centres subscribe to the Service and Repair Code which commits them to open, transparent and fair methods of business aiming to maintain consistently high standards.

Telephone:

0207 3441 651

Email:

consumer@motorcodes.co.uk

Website:

www.motorcodes.co.uk

 

BVRLA conciliation

BMW is a member of the British Vehicle Rental and Leasing Association (the BVRLA). If you are not happy with our final response and would like to refer your complaint to the BVRLA’s conciliation scheme, you may email them at:

complaint@bvrla.co.uk

or write to them at:

BVRLA
River Lodge
Badminton Court
Amersham
HP7 0DD

 

The European Commission’s Online Dispute Resolution Service

European legislation guarantees consumers:

  • fair treatment;
  • products which meet acceptable standards;
  • a right of redress if something goes wrong.

To help ensure that companies meet the standards set by the European Parliament, consumers now have the right to address their complaint to the European Commission’s Online Dispute Resolution (ODR) Service. For full details please go to:

http://ec.europa.eu/consumers/odr/