I am a self employed driving instructor, trading as “Driving Lessons with Martin (Nottingham)”. In my business role, as a professional driving instructor, I require some personal information about the people who take driving lessons with me or enquire about lessons.
This policy details my approach to the collection, generation and holding of personal data. For the purpose of this policy, “you” refers to anyone who contacts me about driving lessons, learners who have lessons with me and qualified drivers taking post-test lessons (e.g. Pass Plus) with me.
How do I collect information about you?
Whenever you contact me (via the website contact form, by email, phone call or any messaging service e.g. Text, WhatsApp, Facebook), I will store your messages and contact details on my phone/PC.
When you make an enquiry about lessons, I will ask you for information about the health of you and your household. If this leads to arranging lessons, I will request some more information from you (from your Driving Licence, as well as your contact details, if not already known) before lessons can commence.
Some additional information about you is generated by me.
What information do I collect, generate and hold about you?
The data I collect from you (that identifies you) and hold is:-
- Information from your Driving Licence
- Address in Nottingham (if different from Driving Licence)
- Contact details (email and phone number), including emergency contact details
- Information about the health and occupation of you and members of your household (introduced in response to the Covid-19 pandemic)
- Messages from you (e.g. Text, WhatsApp, Facebook or email)
The data I generate about you (that identifies you) and hold is:-
- Record of your lessons (dates and times)
- Record of your payments (dates and amounts)
- Record of your learning (using a 1-5 scoring system)
- Reference number (generated by myself) that links all data about you
- Driving Test results (capturing only your first name, date of test and test result)
- Any video footage from an in-car dashcam, while you were driving. To note, the dashcam primarily captures images of other road users, identified by the vehicle registration number, and the general public (on pavements or crossing roads) but the rear facing cam attachment may capture images of the occupants of the car. To also note that the audio option on the dashcam is usually switched on (recording our voices) but if you prefer to have the audio switched off you can request that at the beginning of any lesson.
- Website Traffic from statcounter.com (identifying pages visited by IP Addresses) or Google Search Console (identifying common searches for my website, using Google.)
Why do I need this information?
The information I collect from you is only used in my role as a self employed driving instructor and either enables me to fulfil my contract with you, meet my legal obligations (e.g. providing evidence that I satisfied myself that anyone driving my car has a valid driving licence) and allows me to perform a health risk assessment (prior to lessons starting), in response to the Covid-19 pandemic.
The information I generate about you is used to fulfil my contract with you (e.g. monitoring your progress in driving lessons) and to satisfy a legal requirement to be able to identify the driver of my car at any given time. I also have a legal obligation to maintain accurate records of payments received.
Some information I generate is used for statistical purposes.
The contact phone number you provide to me will be stored on my phone and used to allow me to make contact with you in respect of driving lessons. I may also contact you, after you have passed your test, to see how you are getting on with your driving or to make arrangements for further sessions (if you have indicated an interest in any post test lessons). If you have provided a testimonial for my website, I will also retain your contact details (in case I am required to verify the source of the testimonial).
What do I do with it?
Data collected by me is used to enable me to:-
- Confirm that you (and I ) are not at risk due to Covid-19 health related issues
- Verify your online Driving Licence
- Keep a record of your lessons dates/times (partly to plan my diary and partly to be able to confirm the details of the driver using my car at any given time)
- Contact you during the course of your lessons, in respect of your lessons, or to check on your driving progress after you have passed your test
- The emergency contact (usually a parent or member of your household) is only used in emergency health situations (e.g. if you were to become very ill during a lesson)
- Maintain an accurate record of payments made and the progress you have made throughout the course of your lessons
- Book a driving test on your behalf (if agreed with you)
- Validate my accounts and have evidence for my annual self assessment (tax) return (to satisfy HRMC)
- Provide evidence of any liability in the event of an incident (dashcam video footage)
- Provide training videos (dashcam video and audio footage), featuring me as the driver. If training videos feature you as the driver. I will seek your written consent first.
- Analyse results of driving tests, purely for my own statistical purposes and review of my approach to test preparation (identifying you only by your first name and date of test)
- Analyse the performance of my website and understand how website visitors access/use my website
- Pass on your email address and phone number to a third party purely to arrange free online theory training. This is only done with your additional consent.
- Provide your contact details to NHS Test & Trace (in the event that I am required to do so, after testing positive for coronavirus, Covid-19)
I hold data on a number of Excel files. My weekly diary is written using Microsoft Word. Any saved dashcam videos are in Quick Time Movie file format. All of these files are on my business PC at home. I also create and maintain a paper based record called a “Driver Record”. This record captures dates of your lessons as well as dates and amounts of payments made in addition to recording the progress you have made, in your driving lessons against a driving lesson learning syllabus (simply noting what you have covered in your lessons and scoring your progress, using a 1-5 scoring system).
What do I NOT do with it?
I do not use your data for marketing purposes or provide it to any other party, with the exception of where it is requested by a law enforcement body (Police or DVSA) or AA Driving School Accident Management or insurance company (for insurance purposes, as requested, in the event of an incident resulting in any damage to my car, if you were the driver) or to arrange free online theory training (with your consent) with a third party provider.
Any sensitive information you share with me about your personal life or your health (in writing or verbally) will not be recorded and will not be shared with others by me.
How secure is your information?
Electronic data is held on a password protected PC. Excel files are password protected files. My PC is protected from malicious attacks using F-Secure Safe (Antivirus/Malware) software. Files are backed up and stored on a second PC at my home address (also protected by password access and anti-virus/malware software. Transfers of data between the two PCs are made using a USB memory stick, which is held securely within my home address.
Paper based files are held in folders at my home address except on the day of a pupil’s lesson, when they will be in my driving school car (which is locked when not attended).
Dashcam footage from the current day is stored on a SD card within the dashcam. The dashcam footage is deleted at the end of each day (unless I have agreed with you to retain any footage from your lesson).
How long do I keep your information?
If you phone/message me but do not arrange lessons with me, your messages/contact details will be held on my phone or PC for up to 30 days (from the date of your last contact) and then deleted.
Any information provided to me that informs a health risk assessment is retained for the the duration of your lessons up to a maximum of 30 days after your lessons have stopped permanently.
Once you have started lessons with me, all other information is held until you have permanently stopped lessons with me (e.g. passed your test or moved away from Nottingham) and retained for up to 30 days after lessons have permanently stopped (except for the following data):-
- Record of Lessons/Payments (6 full accounting years)
- Log of Website Traffic (Most recent 500 pages visited – Approx 6 weeks)
- Dashcam Footage (Footage from lessons is held on an SD card on a recording loop. This means that footage is overwritten after approx 8 hours of recording, with the exception of where I have chosen to save footage to capture an incident or to share with you (for training purposes, with your consent) and retained until it is no longer needed for those purposes).
- Contact Details – Your email address and/or phone number are/is retained after lessons have stopped as I may make contact with you at a later date (e.g. to request a review/testimonial or check-in with you to see how you are getting along with your driving). These details are usually retained for a maximum of one year (after lessons have stopped or our last contact) but I will delete your contact details earlier if you make a request.
- Emergency Contact Details – Deleted after lessons have stopped permanently
Please note that if you stop lessons temporarily and agree a date of resumption, I will retain all your records as if you were an active pupil. However, if you stop lessons with me temporarily but do not indicate when you plan to resume or do not make contact with me for 30 days (after your last lesson), I will assume that you have stopped lessons permanently.
Can I see what information you hold about me?
Upon written request (by email to firstname.lastname@example.org), I will supply you with details of all the information I hold about you (within 28 days of your request) or confirm that I have deleted information I have held about you (where information has passed its retention period and has already been deleted/erased/destroyed). Information is provided free of charge. However, in the event of repetitive requests (three times or more), I will charge an administration fee of £25 (to cover my time and printing costs).
April 2018 – Original version
June 2019 – Clarification that email address is used (with learner’s consent) to arrange free online theory training
September 2019 – Policy updated to reflect that a new rear facing dashcam may capture images of you while you are in the car.
January 2020 – Policy updated to reflect that my website has now moved to the secure https protocol and the reference to online theory training is made generically (rather than the specific name of the current provider, as this may change from time to time). I have also made clear that I may use your contact details (email/phone) to make contact after you have passed your test (to seek a review/testimonial or to ask how you are getting on with your driving).
April 2020 – Clarifying that some personal details (i.e. your phone number and/or email address) are retained to maintain contact with you after you have stopped lessons (but will delete these details on request).
20.3 – New version numbering. This version reflects information provided for a new “Health Risk Assessment”(introduced to mitigate risks related to Covid-19).
20.4 – Updated version to reflect that I may be required to provide your contact details to NHS Test & Trace. Where there is no contact/communication from you for a period of 30 days, your data will be treated as if you have stopped lessons permanently (this period has been reduced from 90 days).
21.0 – Annual Review (December 2020). Policy updated to reflect the fact that dashcam footage is deleted at the end of each day (unless agreed with you to retain any footage during your lesson) and that information related to your health is retained until 30 days after you permanently stop taking lessons. The policy now includes reference to emergency contact details.