Motability (operating as "Motability Foundation") is committed to protecting the privacy and security of your personal information.
Motability Foundation is a registered charity and the ‘data controller’ of personal information that we collect from you (including through our websites) and use for our charitable [and other] purposes.
The websites available at https://www.motabilityfoundation.org.uk/ and https://www.motabilityenterprises.co.uk (both referred as our “Site”) are operated by Motability Foundation. Motability (operating as "Motability Foundation") is a registered charity in England and Wales (number 299745) and a Registered Charity in Scotland (number SC050642) and our registered office is at Warwick House, Roydon Road, Harlow, Essex CM19 5PX ("Motability Foundation", “we”, “us” or “our”)
For the purpose of applicable data protection laws, we are the ‘data controller’ of any personal information that we collect from you or that you provide to us.
This means that we are responsible for deciding how we hold and use personal information about you.
Motability Scheme Customers
Importantly, the Motability Scheme is operated by Motability Operations Limited, which has a separate Privacy Notice explaining why and how it uses personal information relating to Motability Scheme customers.
That Privacy Notice is found on Motability Operations’ website here: https://www.motability.co.uk/utilities/privacy-notice/.
Motability Foundation Charitable Grant Applicants or Motability Scheme Enquirers and Health Professionals
Charitable Grant Applicants will receive additional data processing notices in relation to their charitable grant applications which will set out in further detail the information that is needed and how it will be used.
We collect your personal information from application forms you fill in, from your use of our Site, and from our other communications with you.
The personal information we collect about you is made up of the information you give us during your use of the Site and your other communications with us. For example:
(i) when you fill in forms on our Site, download information, request newsletters or other services, or contact us about the Motability Scheme;
(ii) if you contact us or we contact you for any reason, we may keep a record of that communication; and
(iii) we collect details of your visits to our site including traffic data, location data, weblogs and other communication data, and the resources that you access.
You can access and browse the majority of our Site without disclosing your personal data.
However, you can switch these off if you wish.
Cookies contain information that is placed on your computer or other browsing device.
It is possible to switch off cookies by setting your browser preferences, although turning cookies off may result in a loss of functionality when using our Site.
We collect different types of personal information depending on your relationship with us.
We collect names and contact details about most individuals and certain additional information from Motability Scheme Customers and applicants for the Scheme.
The personal information we collect from visitors to our Site might include:
- Personal details (such as your name and address);
- Email addresses;
- IP addresses; and
- Information regarding what pages are accessed and when.
In addition, we collect from Customers and Scheme Applicants the following data:
- Personal details (such as your name and address);
- Contact details (such as telephone and email addresses);
- Family information (children, dependents etc.)
- National Insurance Number
- Financial information
- Health information
- Details of representative, partner and other vehicle users.
We use your personal information for different purposes, depending on your relationship with us.
Those purposes include operating and improving our Site, and monitoring and recording communications.
If you are a Motability Scheme Customer or an applicant for the Scheme, we will also use your personal information for the purposes of verifying your eligibility for the Scheme, monitoring and overseeing the Scheme, and for the other compliance or governance related reasons, as well as to communicate with you.
We may use your personal information for the following purposes:
- to ensure that content from our Site is presented in the most effective manner for you and for your computer/device;
- to provide you with information, publications and marketing communications about the Motability Scheme and any products and services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
- to seek your opinions on matters of interest to us;
- for internal analysis and research, and for testing the Site; and
- to allow you to participate in interactive features of our Site, when you choose to do so.
If you are a Motability Scheme customer, then we will use your information for additional purposes, as described in your vehicle lease agreement and any separate documents which you may complete as a Motability Scheme customer (for example, your application for a vehicle and any application for financial help), including:
- to verify eligibility for the Motability Scheme;
- to consider and determine any application for financial help and to assess your vehicle needs;
- to comply with legal and regulatory requirements and
- to adhere to responsible good governance requirements;
- to monitor and oversee the performance of the Motability Scheme, including the quality of service and the value for money provided to customers to ensure that it meets the needs of disabled people; and
- for internal analysis and research for the benefit of disabled persons in accordance with our charitable objectives.
Where possible, and particularly for our monitoring and oversight purposes, and our internal analysis and research purposes, we will endeavour to protect individuals’ privacy rights by converting personal information into anonymised data (so that a person cannot be identified from it).
Direct Marketing Communications
We may send you Lifestyle magazine, details of affinity products, and other communications by different means of communication, based on your contact preferences.
If you have provided your consent for this during the application process or otherwise, we may mail you Lifestyle magazine and we may otherwise contact you by post, phone call, email, text messages or other means with details of additional products and services which are from particular third parties, including providers of financial services, and which may be of interest to you.
These include but are not limited to specialist insurance products and travel services (known as ‘affinity products’).
While the sending/receipt of these communications by electronic means (email, SMS, telephone calls, etc.) usually requires your specific consent, the processing of personal information for these communication purposes more generally (e.g. forming a contact database, deciding what communications we think will be of interest to you, etc.) relies on the legitimate interests of Motability Foundation who will be the sender of these marketing messages.
You can tell us at any time if you would prefer not to receive such direct marketing from Motability Foundation.
Monitoring and Recording Communications
We monitor and record telephone calls for legal and compliance purposes, and we may share call recordings with Motability Operations to help address issues raised by Scheme customers.
Motability Foundation has a telephone call recording system in operation which records: (i) all incoming telephone calls; (ii) all outgoing telephone calls from its Charitable Operations team; and (iii) internal calls to/from its Charitable Operations team. An ‘incoming call’ is a call received by Motability Foundation (including any calls re-directed from Motability Operations), and an ‘outgoing call’ is a call made by Motability Foundation.
Motability Foundation records these calls for the following purposes:
- to establish the existence of facts relevant to its activities; for example, to keep a record of information given via telephone by or to Motability Scheme customers or applicants;
- to ascertain compliance with regulatory practices or procedures relevant to Motability Foundation; for example, to ensure that Motability Foundation is complying with its own policies and procedures, and with applicable laws;
- to ascertain or demonstrate standards that are, or ought to be, achieved by Motability Foundation personnel; for example, for quality control and staff training; and
- to prevent or detect crime; for example, to monitor for or to detect evidence of fraud or corruption.
Motability Foundation determines the nature and extent of its call recording appropriate for the above purposes, taking into account:
- the importance which it attaches to the sensitive and responsive handling of all calls with Motability Scheme customers including those customers who may have a cognitive impairment, and the need for rigorous quality control and staff training to achieve this;
- the importance which it attaches to identifying, remedying and addressing the root cause of those calls which are not regarded as a good experience by Motability Scheme customers or applicants, recognising that such calls are likely to be isolated occurrences;
- the results of its data protection impact assessment in relation to call recording; and
- the advice of its Data Protection Officer.
Motability Foundation may (from time to time) record telephone calls for other purposes, provided that the individuals involved in such telephone calls consent to the telephone call(s) being recorded for the stated purpose.
Motability Foundation will use all reasonable efforts to ensure that callers are aware of the recording of telephone calls by the use of a pre-recorded message which notifies individuals making incoming calls that:
- Motability Foundation records both incoming external calls and all subsequent incoming/outgoing calls to/from the Charitable Operations team for the purposes set out above; and
Motability Foundation treats a caller’s election to proceed with an incoming call following the playing of the pre-recorded message as signifying that person’s consent to the recording of such incoming and outgoing calls in accordance with the notification provided.
Motability Foundation intends to make call recordings available to Motability Operations where it is necessary to hear the call first hand:
- to establish facts and understand the customer’s circumstances to address the issue being raised;
- to enable a customer complaint to be addressed appropriately; and
- to understand the context in which information is being provided.
Motability Foundation does not make call recordings available to any other third parties, unless it is legally obliged to do so.
Motability Foundation will not retain telephone recordings for any longer than necessary for the purposes for which they are collected, or as required by applicable legal or regulatory requirements, whichever is longer.
When recording incoming and outgoing telephone calls, Motability Foundation will comply with applicable data protection laws and our internal ICT and Data Protection Policies and Procedures (including but not limited to: ICT systems Policy, Data Protection Policy; Data Retention Policy; and Further Processing of Personal Data Policy.)
Research and Innovation Purposes
If you are in receipt of a Motability Foundation grant, Motability Foundation may use your personal data to conduct evaluation or innovation research.
This helps Motability Foundation to understand the impact of its activities on beneficiaries, improve its programmes and services, and better understand the mobility and transportation needs of disabled people.
Motability Foundation will endeavour to protect individual’s privacy rights by anonymising data wherever possible.
If as part of our research you consent to your personal data being used in reporting, the relevant text will be shared with you in advance of being circulated in the report.
We retain your personal information for as long as is necessary to fulfil the purposes it was collected for (and sometimes we anonymise it, so that the data will no longer identify you).
We will retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of Motability Foundation;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing (which may include our legitimate interests, where the processing is necessary for the performance of a contract, or in some cases where you have specifically consented to the processing);
- the nature, types and volumes of personal data we have collected; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
In some circumstances (for example when we collect statistical data about Site users' browsing actions and patterns) we may anonymise your personal information so that it can no longer identify you or be associated with you, in which case we may use such information without further notice to you.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the relationship with you, or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
‘Third party service providers’ include our contractors and designated agents, other entities within our group, service partners involved in the provision of Motability Scheme vehicles, and third parties involved in verifying eligibility for the Motability Scheme or in assessing applications for financial help.
The following activities are carried out by third-party service providers: IT and data storage services, professional advisory services, administration services and emailing services.
All our third-party service providers are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
For Motability Scheme customers, we may also share your personal information with third parties to verify your eligibility for the Scheme and for the other purposes described in our separate documents with you. Third party recipients of your personal information for these purposes include the Department for Work and Pensions (DWP), Veterans UK, Motability Operations, credit reference agencies, vehicle convertor and adaptors and RSA or DirectLine as the Motability Scheme insurer.
We may also share the personal information of our Site visitors with our Scheme delivery partners to enable us to deal with your request(s).
We may share your personal information with other third parties, for example in the context of the possible restructuring of the charity. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Transferring information outside the UK and/or the European Economic Area (‘EEA’)
We will not ordinarily transfer personal information outside of the UK. However, if any third party recipients of your data are based outside the UK (so that their processing of your personal data will involve a transfer of data outside the UK) we will ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data through ‘Adequacy Regulations’ made under applicable data protection laws; and
- where we use certain service providers, we may use specific contracts approved by the Information Commissioner’s Office which give personal data the same protection it has in the UK.
Our email sending service provider Mailchimp is based in the USA. Our contract with Mailchimp incorporates the ‘standard contractual clauses’ which have been approved by the European Commission and the UK Secretary of State.
Please contact our Data Protection Officer if you want further information on the specific mechanism to be used by us if we are to transfer your personal data outside of the UK.
We use appropriate measures to keep personal information secure, and we take steps to ensure that our third party service providers do the same.
We have procedures in place to deal with data security incidents, which may involve reporting to regulators and/or to you.
We place great importance on the security of all personal information for which we are a data controller.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed, altered or disclosed in an unauthorised way.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a need to access it for the purpose of their work.
They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with data security incidents, and we will notify you and any applicable regulator (including the Charity Commission and/or the Information Commissioner’s Office) of a known or suspected personal data breach where we are legally required to do so.
As an individual whose personal information we are processing, you have certain legal rights as the ‘data subject’, including rights to access, rectify, and erase your data, in certain circumstances.
Informing us of changes to your data
It is important that the personal information we hold about you is accurate and current.
Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal information
Under certain circumstances, you have the right under applicable data protection laws to:
- request access to your personal information. This enables you to receive details of the personal information we hold about you and to check that we are processing it lawfully;
- request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- request erasure of your personal information, also known as the ‘right to be forgotten’. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
- object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes the processing unfair as it affects you. You also have the right to object where we are processing your personal information for direct marketing purposes;
- request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it; and
- request the transfer of your personal information to another party
If you want to exercise any of the above rights, please email: DataProtectionOfficer@motability.org.uk.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.
Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
Please note that the data subject rights listed above are not absolute and we may be entitled (or required) to refuse requests where exceptions apply.
In the limited circumstances where you may have provided your consent to the use of your personal information for a specific purpose (for example, in relation to the sending of electronic direct marketing which you have indicated you would like to receive from us), you have the right to withdraw your consent to the use of your information for that purpose at any time.
You can withdraw your consent to the use of your personal information at any time by contacting our Data Protection Officer by post at: Warwick House, Roydon Road, Harlow, Essex CM19 5PX, or by email: DataProtectionOfficer@motability.org.uk.
Once we have received notice that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so.
Please mark all email correspondence with: “FAO Data Protection Officer”.
You also have the right to make a complaint to the Information Commissioner’s Office (‘ICO’, whose website is available at: www.ico.org.uk), the UK supervisory authority for data protection issues.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.