Privacy Policy

Privacy Notice

1. Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.

We know that there's a lot of information here, but we want you to be fully informed about your rights, and how Co-wheels uses your data. For simplicity, throughout this notice, when we refer to "we" or "us"; it means Co-wheels Car Club. We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It's likely that we'll need to update this Privacy Notice from time to time. We'll notify you of any significant changes, but you're welcome to come back and check it whenever you wish.

2. The personal data we collect

If you register as a Co-wheels member;

• your name, address as it appears on your driving license, billing details & address if different to that on your driving license, date of birth, email and telephone number.
• an encrypted record of your login password.
• your driving license details and history with regards to any driving offences, as well as asking for specific information relating to medical conditions that may affect eligibility for holding a driving license.
• Details of your interactions with us through our Member Support Team through our various support channels or where changes have been made to your account on a self-service basis through the Co-wheels booking system.
• Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's license). This will include details of your full name, address, date of birth and facial image.
• Details of your visits to our websites or apps, and which site you came from to ours.
• Details of your bookings and use of our vehicles including GPS and vehicle tracking data.
• Payment card information.

To assist with the reporting of insurance claims some vehicles may be fitted with dash cams, in such instances we may also collect video footage of your journey and or any activity within the lens capture area of the camera.

Information gathered by the use of cookies in your web browser.

Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

When you use one of our vehicles we will collect information such as GPS locations during your booking and also information relating to driving styles such as speeds, acceleration and deceleration rates and g-force information.

If you only register on the Co-wheels website for information and offers then we will only collect your name, email address and postcode so that we can personalise the information that we send you.

Our services are not intended for children under the age of 17 and we do not knowingly collect data relating to children.

3. How we collect your personal data

• When you register and use the Co-wheels booking system and also when you use one of our vehicles
• When you sign up on the Co-wheels home page for further information or to be kept updated for offers
• If you engage with us on social media.
• When you download or install one of our apps.
• If you contact us by any means with queries, complaints, details about a breakdown or accident.
• If you ask us to email you information about a product or service.
• When you enter prize draws or competitions.
• If you choose to complete any surveys, we send you.
• When you comment on or review our products and services.
• When you fill in any forms. For example, if you are involved in an accident, a member of our team may collect additional personal data or that of third parties for insurance purposes on your behalf.
• When you've given a third-party permission to share with us the information they hold about you. For example, when you provide us with your DVLA sharing code.
• When you visit our website, we may collect information via cookies, pixels and tags, more information on this can be found under section 5 of this privacy policy.

4. The legal bases we rely on for processing personal data

The law on data protection sets out several different reasons for which a company may collect and process your personal data, including:

Contract
In certain circumstances, we process your personal data in order to enter into a contract with you or for the performance of the contract. For example, we need your name and address to be able to send your smart card to you and we need your email address so that you can access the booking system to use the Co-wheels service.

Complying with a legal obligation
If the law requires us to, we may need to collect and process your data.

For example, we need your driving license details to ensure that you are legally eligible to use the Co-wheels service and be covered by our insurance.

Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, to be able to provide a service and also identify ways to improve our service and your experience of using our cars we have a legitimate interest and need to hold and process your data.

Consent

In specific situations, we may process personal information based on your consent.

5. How and why we use your personal data

Remember, if you choose not to share your personal data with us, or refuse certain permissions, we will be unable to provide you with membership and access to book our vehicles.

We will use the data you provide us with to determine your eligibility for membership of Co-wheels Car Club. This will include checking the driving license and driving history information you have provided us with to determine whether you are covered on our insurance to drive our vehicles. Where a user is applying for an account and will therefore be responsible for billing and charges against an account, we may also carry out a credit reference to confirm identity and to assist with the prevention of fraud. Such checks will only be completed with your consent however failure to give consent within the application process may result in your application for membership being unsuccessful.

We will use your details to provide the service delivered by Co-wheels Car Club. This will include sending your smartcard and membership pack to the address you have provided us with, sending you emails so we can verify your email address and send you booking confirmations and billing details.

To protect our business and your account from fraud and other illegal activities by automatically checking your password when you log in against the one that you used at registration, or reset if you have updated your password.

To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.

If we discover any criminal activity or alleged criminal activity through fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.

We will use your personal data, preferences and details of your transactions to keep you informed by email about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time by contacting us as set out below.

To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, changes to Terms & Conditions of use, and legally required information relating to ongoing membership of Co-wheels Car Club These service messages will not include any promotional content and do not require prior consent when sent by email. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

To develop, test and improve the systems and services we provide to you. We'll do this on the basis of our legitimate business interests.

To comply with our contractual or legal obligations to share data with law enforcement or other relevant parties.

To send you surveys and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

We will use cookies, pixels and tags to identify which pages of our website are being used to help us analyse data about web page traffic and improve our website for our customer's needs. A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. We also use this data for Social Media adverts such as Facebook and Search Advertising, such as Google Ads, Social Media, Search Advertising and remarketing may display relevant ads tailored to you based on which parts of our website you visit, or to stop sending you adverts if they are not relevant to you. These cannot be used to identify you, and are simply used to say "This person visited this page, so show them ads relating to that page. This helps us tailor our marketing to better suit your needs and only display ads that are relevant to you.
We also collect, use and share Aggregated Data such as statistical or demographic data to build a general model of users and behaviours to improve and/or enhance the service. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to understand and analyse demand and interest for our services. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may use video footage captured on dash cams to aid in the assessment of insurance claims or eligibility of membership based on what may be deemed as acceptable or appropriate usage of our vehicles and we may use GPS and driving data, to analyse your driving during each trip thus prevent fraud, ensuring driver safety and the safety of passengers and other road users and to analyse customer driving styles and patterns. We may also use this data to send you notifications on your smart driving and also to maintain vehicle security and GPS tracking on overdue or unaccounted for vehicles or vehicles travelling outside of authorised jurisdiction as described in the Terms and Conditions of Service.

6. Using your data for direct marketing

We want to bring you offers and promotions that are most relevant to your interests at times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered as described above, for example your booking history. For this purpose, we may also combine the data that we collect directly from you with data that we obtain when you post on social media relating directly or indirectly to our pages and/or posts.

We will get your express opt-in consent before we share your personal data with any company outside Co-wheels for marketing purposes.

7. Protecting your data

We know how much data security matters to all our customers. We will treat your data with the utmost care and take all appropriate steps to protect it.

The booking system where you enter your personal data is secured by https technology and Co-wheels hold Cyber-Essentials certification, a government approved IT security certificate which has to be renewed on an annual basis.
Access to your personal data is password-protected, and sensitive data (such as your password and payment card information) is secured by encryption.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

8. How long we hold your personal data

Due to the nature of membership we will keep your personal data for as long as you remain a Co-wheels member. We need to do this to ensure that we can provide the service to you. If you close your account or it was not approved for any reason or you registered your details but did not fully submit an application, we will still retain your information on the basis below.

Retention Periods:

Closed Accounts & Non-approved Accounts

We will keep your data for 7 years, this is in case the information is required for legitimate or legal needs, for example, if an insurance claim is submitted or it is required for legal means. If after 7 years, there is a legal need to continue to hold the information we will do so until that requirement is satisfied.

Part-registered accounts

If you have not fully registered, we will contact you asking whether you want to continue your account or whether you wish to have your details removed.

9. Who we share your data with

We sometimes share your personal data with trusted third parties.

Where we provide services under a public contract, we may be required by the local authority to share contact details of our customers with that local authority when our contract for provision of services with the local authority comes to an end. This is to enable the local authority to provide a continuation of services through a new provider.

We provide only the information they need to perform their specific services.

They may only use your data for the exact purposes we specify in our contract with them.

If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

We only use companies with privacy and data policies which comply with data protection requirements.

Examples of the kind of third parties we work with are:

Companies who support our website and other business systems

Operational companies such as breakdown services and insurance companies.

Direct marketing companies who help us manage our electronic communications with you.

Social Media and Web Search companies to show you products that might interest you while you're browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.

Data insight companies to ensure your details are up to date and accurate.

Payment processors and your Bank for direct debit payments.

Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.

Credit Reference Agencies to confirm identity and assess eligibility for membership

Debt Recovery Agents to recover any outstanding monies owed.

Sharing your data with third parties for their own purposes:

We do not share your data with third parties for their own direct marketing purposes

If you are a driver on an account, then we may share your data with your account owner.

If we are delivering the service with third party support, we may share limited information with the third party so that they may contact you for monitoring and feedback purposes.

For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.

We may also be required to disclose your personal data to the police, other emergency services or other enforcement, regulatory or Government bodies (including private parking enforcement companies), in your country of origin or elsewhere, upon a valid request to do so or in case of emergency. This would include for example parking and traffic infringements. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

To assist us with responding to requests for information and to identify appropriate information to share with you, we currently use the following companies who will process your personal data as part of their contracts with us:

Alphabet inc.,
Meta Inc.,
ByteDance Limited,
X (formerly Twitter),
Linkedin,
TripIQ (this is the booking system),
Greater Than
Active Campaign –
Active Prospect (Leadsbridge, Make, Zapier)

We may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Third-party links

Our website http://www.co-wheels.org.uk may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

10. Where your data is processed

Where your data is processed within the United Kingdom or with the European Union it is done so under equivalent data protection requirements. Where we use providers to process personal data that are based in the US and process data in the US, we are utilising the UK Extension to the EU-US Data Privacy Framework.

11. Your data subject rights

Under the UK GDPR you have a number of rights with regards to your personal data, these are:

The right of access to the personal data we hold about you

The right to correct your personal data when incorrect, out of date or incomplete.

The right to object to processing and the right to request erasure of your personal data. This right does not apply where our continued use of the data is necessary for an overriding continued legitimate interest, where we have to process it under a legal obligation or for the establishment, exercise or defence of a potential legal claim.

You always have the right to object to processing of your personal data for marketing purposes.

The right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

The right to request the transfer of your personal data to you or to a third party.

The right to withdraw consent at any time where we are relying on consent to process your personal data.

You can contact us to request to exercise these rights at any time, initially by contacting our Member Support Team at info@co-wheels.org.uk or phoning on 0191 375 1050 who will pass the request to the Data Privacy Manager. Alternatively, you may write to: Data Privacy Manager, Co-wheels Car Club, Suite 1, 7-15 Pink Lane, Newcastle upon Tyne, NE1 5DW.

Checking your identity.

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

12. Opting out of direct marketing

There are several ways you can stop direct marketing communications from us:

Click the “unsubscribe” link in any email communication that we send you. We will then stop any further marketing emails from that us.

Email info@co-wheels.org.uk and let us know, please make sure you email us from the registered email address so that we can be sure we remove the right one.

Write to: Data Privacy Manager, Co-wheels Car Club, Suite 1, 7-15 Pink Lane, Newcastle upon Tyne, NE1 5DW.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

If you do not wish to participate in our Google Ads, Remarketing, you can opt out by visiting Google’s Ads Preferences Manager. If you wish to change or opt out of Facebook adverts then you can amend your settings by using this guide and stop specific ads or companies, including those from Co-wheels, by following this guide.

13. Contact

Co-wheels Car Club Community Interest Company is the controller and responsible for your personal data. Its company number is 6512325 and registered office is at Suite 1, 7-15 Pink Lane, Newcastle upon Tyne, NE1 5DW.

If you have any questions on this privacy notice or anything else relating to your rights, please contact our Data Privacy Manager who will be pleased to help you:

Email via info@co-wheels.org.uk or write to us at Data Privacy Manager, Co-wheels Car Club, Suite 1, 7-15 Pink Lane, Newcastle upon Tyne, NE1 5DW.

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioners Office.

You can contact them by calling 0303 123 1113 or go online to www.ico.org.uk/concerns

Tewkesbury Borough Council Pool Car Usage Scheme

1. Document Purpose

To provide clear guidance for Council Staff in relation to the Council’s Pool Car Scheme

2. Scope

This policy applies to all Council employees who would normally claim business mileage expenses or book vehicle hire for the purpose of business travel, with the exception of;

Elected Members

Agency staff

Election Day staff

3. Aims of the Policy

To ensure that staff are aware of the pre-requirements for registration as a pool car user including registering on the Co Wheels booking system and the occupational road risk policy.

To ensure that staff are aware of the procedures required to book and access pool cars.

To ensure that staff are aware of the expected conditions and usage of vehicles.

To reduce the annual business mileage expense claim paid by the authority.

To ensure that staff utilise cost and carbon efficient methods of transport when conducting council business.

To reduce exposure to risk by ensuring that staff are operating vehicles that are legal and roadworthy.

4. Implementation

From 25 March 2019, the council have implemented a corporate pool car scheme. Implementation of the scheme is required to reduce the council’s grey fleet mileage claims, therefore reducing the overall cost to the authority. The recent diagnostic review of Council transport arrangements recommended that the current mileage amount claimed by staff be reduced via the implementation of a corporate pool car scheme.

Pool Vehicles will be maintained via the Council’s Finance and Asset management team and the scheme administered via Co Wheels.

Heads of Service and Operational Managers within service areas will actively promote usage of the scheme, above the use of personal vehicles, and encourage the use of efficient means of transport/pool cars to their staff.

All employees required to use a car during the course of their duties are required to register via the scheme, in order to ensure that staff are appropriately licenced they must be registered on the occupational road risk policy scheme.

5. Usage of Pool Cars

Staff normally required to use their own vehicle to conduct their duties will be offered the use of a fleet pool car for business use only, provided and maintained by Co Wheels.

Under no circumstance should the vehicle be used for personal use

All car hire bookings must be made through the Co Wheels booking system using the online portal. Users will be guided to use one of the onsite pool cars.

All staff whether using a pool car (or their own vehicle in cases where an exemption applies will be required to register on the online portal and on the occupational road risk policy register managed by finance

Staff must elect to use a pool car over the use of their own vehicle to undertake council duties. Staff may use their own vehicles to undertake council duties; however no mileage payment will be paid unless the employee can provide evidence in line with the exemptions on appendix 1 Staff must however have previously registered and offered proof of licence and insurance requirements via the scheme to use their own vehicles in these circumstances to enable any payment.

Pool cars must be returned to the assigned depot at the end of each business day. At no time should the vehicle be used for personal use.

Personal vehicles can only be used in line with the relevant exemption please see exemptions in this policy.

6. Scheme Registration and Mileage Claims

Employees will be required to provide valid driving licence and insurance information in line with the road risk policy in order to register as a driver. Information will be held for validation purposes via the Co Wheels booking system for the course of the employee’s employment.

If a pool car is unavailable for an employee’s requested journey (or the employee has been provided a specific exemption agreed by the Head of Service), the employee will be required to note on their mileage claim the relevant exemption code in order for the claim to be validated. It is advisable for staff to document when they have attempted to book a pool car for the journey; this will be verified against the system.

When making a mileage claim staff will be required to put the relevant code of exemption on the mileage claim form and the authorising signatory is agreeing to the exemption to authorise the claim.

7. Accessing a Pool Cars

Staff will be able to book a pool car using the online booking system.

Staff will be able to access the pool car scheme through the Co Wheels app which will allow them to access the car during their booking period. The charge cards are stored within the glove compartment. A car will not be accessible outside the allocated booking slot. Should staff leave something in the vehicle and needs to access the vehicle to recover it, Co Wheels Customer Services must be contacted instead of booking the car out again. As such, please check to ensure you have removed any personal items before locking and leaving the vehicle

Due to the public service centre being operation 24/7 poll cars can be booked and used at any time of the day or night

The vehicles will be kept in the allocated and signed parking at the rear of the council offices adjacent to the delivery yard

8. Responsibilities of Drivers

On collection of the vehicle the pool vehicle user will be required to check the vehicle for damage and any defects are to be reported immediately to Co Wheels. This is in the driver’s interest to ensure there is no damage prior to using the vehicle.

Drivers must report any damage caused whilst the vehicle is being used immediately to Co Wheels.

Pool vehicles should be placed back on charge if returned with less the 60% charge

Pool vehicle must be returned no later than the prescribed booking time and in a clean and acceptable state for the next user.

Should the vehicle be required for longer than the booked slot due to circumstances outside of your control (e.g. a meeting has overrun or heavy traffic) please extend your booking via the Co Wheels app. If the system does not allow you to extend the booking then you must contact Co Wheels immediately so that alternative arrangements can be made for other users who have booked the vehicle.

Staff should try to amalgamate journeys as much as possible; if you are using the vehicle to attend a meeting where other council staff are attending and departing from the council offices, all efforts should be made to travel together.

The staff member that has booked the vehicle will be responsible for any misconduct or driving offence during the booked period

Staff are responsible for ensuring the most efficient use of the vehicle e.g. ensuring that visits are scheduled to be completed in a logical route, completing as many visits as possible at one time.

Staff must immediately cancel a pool car booking as soon as possible should they no longer require the vehicle e.g. a meeting has been cancelled. This will ensure that the vehicle is available for others to use and ensure the council is getting the most out of the scheme. If the staff member is sick their line manager must contact property to cancel any vehicle bookings previously made.

The user guide in each pool car explains how to report incidents and/or accidents, breakdowns and damage.

The council will not be responsible for the loss/damage or theft of any personal belongings left in the vehicle

9. Administration of the Scheme

Co Wheels will manage the booking facility of the pool car scheme, ensuring that all requests made are met, that the vehicle is maintained to a roadworthy standard with monthly visits.

If the employee incurs a fine for a motoring, congestion or parking offence/infraction, liability remains with the employee identified as having responsibility for the vehicle during the booking period in which the offence was committed along with a Co Wheels administration charge of £25.00.

10. Responsibility of Managers and Enforcement of the Scheme

Responsibility for ensuring fair use of the scheme remains the responsibility of the Operational Managers, and/or Heads of Service.

Managers are required to ensure that all mileage claims are accompanied by proof that a pool car was unavailable for each journey, or details of a specific exemption or written agreement by the Head of Service.

Managers will be required to ensure that all mileage claimed is supported by both a description of the purpose of the journey and an accurate mileage calculation (post-code to post-code), verifiable via the use of route planning software (e.g. Google Maps).

All vehicles are tracked using vehicle telemetry system. Usage reports will be used to analyse actual usage against booked usage.

It will be the responsibility of managers to signpost all new starters to register for the scheme if their role requires the use of a passenger vehicle.

Managers must verify any mileage claimed is exclusive of home to office normal commuting mileage

Managers must support any new members of staff if their role requires use of a pool car.

Serious and/or persistent breaches of this policy may result in disciplinary action being taken against an employee

NB: training on using automatic vehicles will be provided to staff on request.

Pool Car Exemptions:

1. Personal vehicles may be used if a pool car is not available. Vehicles will need to be booked as much in advance as possible and every effort should be made to rearrange the journey time to when a vehicle is available.
2. For journeys under 20 miles with a visit that will be longer than 4 hours, a personal vehicle can be used.
3. Where the Officer’s visit is within their normal commuting mileage and the mileage claim is minimal (no more than 10 miles) a personal car can be used.
4. Where officer’s mileage is incurred for the purpose of the elections on Election Day their own private vehicle must be used and a mileage claim made.
5. Out of hours officers who are essentially on-call- these officer’s operate on an “emergency” type basis out of hours, so may not be practical to come to the offices to collect a pool car. It wouldn’t be considered practical if the journey time is excessive compared to the required journey.
6. Employees with disabilities or temporary medical condition that require a vehicle to be adapted may use their personal vehicle until an adapted vehicle is available or the medical condition improves.
7. An employee may choose to use their personal vehicle without claiming any mileage for their journey. If the employee chooses to use their vehicle no future claim can be made
8. If the booking recommends alternative methods to travel i.e. train or one day hire car this alternative should be taken.
9. Employees that have multiple work locations that they are required to work contractually at these locations and do not finish work at the start location therefore the vehicle cannot be returned to the offices then a personal vehicle can be used.

Key points before booking a vehicle:

Is the journey necessary- can you have a conference or skype call?

Can you amalgamate journeys to make better use of the vehicle?

10.1 In exceptional circumstances use of your own vehicle outside of the above agreed exemptions must be agreed in writing for the journey with the relevant staff members Head of Service. An email will be acceptable to demonstrate this.