Privacy Notice

1. Who Is Responsible for Your Information

Stephen Shortland, trading as WhiteCars, is the data controller for the personal information described in this notice. This means WhiteCars decides why and how that information is used.

Questions or requests about personal information can be made using the telephone number or email address on this page.

2. Personal Information We May Collect

Depending on the booking and passenger’s needs, WhiteCars may collect:

• Names and contact details of passengers and people making or managing bookings
• Pickup addresses, destinations, journey dates and times
• Flight numbers, terminals and other travel information
• Passenger numbers and luggage requirements
• Payment, invoice and account records
• Communications, booking notes, complaints and feedback
• Contact details for schools, guardians, host families, welfare contacts or receiving persons
• Accessibility, mobility, assistance-dog, medical or safeguarding information where needed to provide the journey safely
• Information required by licensing authorities, law-enforcement bodies or insurers

WhiteCars aims to collect only information that is relevant and necessary for the particular journey or business purpose.

3. Where We Obtain Information

Information may be provided directly by a passenger or by another person arranging the journey, such as a parent, guardian, school, organisation, host family, travel coordinator or account customer.

WhiteCars may also obtain relevant information from allocated drivers, replacement licensed operators, payment providers, airports, airlines, public flight-tracking services, licensing authorities or other organisations involved in the journey.

4. Why We Use Information and Our Lawful Bases

WhiteCars uses personal information only where there is a lawful basis. The main purposes and bases are:

• Providing and managing bookings — contract. This includes quoting, confirming and completing journeys, contacting passengers and taking payment.
• Meeting legal and regulatory duties — legal obligation. This includes licensing, tax, accounting, insurance, safety and lawful disclosure requirements.
• Running and protecting the business — legitimate interests. This includes service administration, preventing fraud, maintaining security, handling complaints, recovering sums due and establishing or defending legal claims.
• Protecting someone in an emergency — vital interests. Information may be used or shared where reasonably necessary to protect a person’s life or physical safety.
• Accessibility, health or safeguarding information. Where this is special-category information, WhiteCars will use it only where an additional legal condition applies, such as explicit consent, vital interests, a relevant legal duty or the establishment, exercise or defence of legal claims.

Where WhiteCars relies on legitimate interests, those interests are balanced against the rights and reasonable expectations of the people concerned.

5. Who We May Share Information With

Where necessary and lawful, information may be shared with:

• The allocated licensed driver
• A replacement licensed private hire operator
• The person or organisation that arranged or is responsible for the booking
• A school, guardian, host family, welfare contact or receiving person
• Payment, banking, accounting, communications, IT or secure cloud-service providers
• Insurers, professional advisers and debt-recovery providers
• Torbay Council or another relevant licensing authority
• The police, courts, regulators, emergency services or other public authorities where required or permitted by law

WhiteCars does not sell personal information. Service providers are expected to use information only for the agreed service and to protect it appropriately.

6. International Transfers

Some technology or service providers may process information outside the United Kingdom. Where this happens, WhiteCars will take reasonable steps to ensure that an appropriate legal safeguard is in place, such as UK adequacy regulations or approved contractual protections.

7. How Long We Keep Information

WhiteCars keeps personal information only for as long as reasonably needed for the purpose for which it was collected and for any licensing, tax, accounting, insurance, safeguarding or legal requirement.

As a general guide:

• Booking, invoice, payment and business correspondence records may be retained for up to six years after the relevant transaction or the end of the business relationship.
• Complaint, incident and insurance records may be retained for up to six years, or longer where a claim, investigation or legal requirement remains active.
• Accessibility, welfare and safeguarding information will be kept only for as long as necessary for the journey, ongoing transport arrangement, safeguarding need or applicable legal requirement.
• Information no longer required will be securely deleted, destroyed or anonymised.

Specific records may be kept for a shorter or longer period where this is justified and lawful.

8. How We Protect Information

WhiteCars uses reasonable organisational and technical measures to protect information against accidental loss, unauthorised access, alteration or disclosure. Access is limited to people who need the information to arrange, provide or administer the service.

No system can be guaranteed completely secure. WhiteCars will assess and respond to suspected personal-data breaches and notify affected people or the Information Commissioner’s Office where the law requires this.

9. Your Data Protection Rights

Depending on the circumstances, you may have the right to:

• Ask for a copy of your personal information
• Ask for inaccurate or incomplete information to be corrected
• Ask for information to be deleted
• Ask WhiteCars to restrict how information is used
• Object to certain uses based on legitimate interests or to direct marketing
• Receive certain information in a portable format
• Withdraw consent at any time where consent is the lawful basis

These rights are not absolute and may be limited by legal, regulatory or contractual requirements. WhiteCars may need to confirm your identity before responding. There is normally no charge for making a request.

10. Automated Decisions and Marketing

WhiteCars does not use personal information to make solely automated decisions that produce legal or similarly significant effects.

WhiteCars will not use booking information for electronic direct marketing unless there is an appropriate lawful basis and any required consent. You can object to direct marketing at any time.

11. Children and Vulnerable Passengers

Some journeys involve children, students or vulnerable passengers. WhiteCars may receive their information from a parent, guardian, school, organisation or other responsible person and will use it only as necessary to arrange the journey, maintain safety, provide agreed welfare confirmations and complete the agreed handover.

The booking party should provide only information that is accurate, relevant and necessary.

12. Complaints

Please contact WhiteCars first if you have a concern about how your information has been handled:

Telephone: 01803 266266
Email: enquiries@whitecars.org.uk

You also have the right to complain to the Information Commissioner’s Office (ICO). Information about making a complaint is available at ico.org.uk/make-a-complaint or by calling 0303 123 1113.

13. Changes to This Notice

WhiteCars may update this Privacy Notice when its services, working practices or legal obligations change.

The current version will show its effective date. Material changes will be brought to people’s attention where reasonably practicable.