The following document is designed to outline the approach adopted by Haynes Brothers Ltd for the handling of the GDPR legislation, brought into law on May 25th 2018.
It outlines the options available and the general approach supported.
The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
This definition provides for a wide range of personal identifiers to constitute personal data, including name, identification number, location data or online identifier, reflecting changes in technology and the way organisations collect information about people.
The GDPR applies to both automated personal data and to manual filing systems where personal data are accessible according to specific criteria. This could include chronologically ordered sets of manual records containing personal data.
Personal data that has been pseudonymised – eg key-coded – can fall within the scope of the GDPR depending on how difficult it is to attribute the pseudonym to a particular individual.
There are different lawful grounds that we rely on to use your personal information and we will collect and use your personal information in the following situations:
The GDPR refers to sensitive personal data as “special categories of personal data”
The special categories specifically include genetic data and biometric data where processed to uniquely identify an individual.
Personal data relating to criminal convictions and offences are not included, but similar extra safeguards apply to its processing.
When someone visits one of our company websites we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website.
To understand how users use the Haynes Group Websites and our services and the things they are interested in, we may collect your Internet Protocol addresses (also known as IP addresses). Your IP address is a unique address that computer devices (such as PCs, tablets and smartphones) use to identify themselves and to communicate with other devices in the network.
Haynes Group uses a third-party service, Aptus based in the United States, to help maintain the security and performance of the Haynes Group website. To deliver this service it processes the IP addresses of visitors to the Haynes website.
Haynes Group conducts 3-monthly Penetration Testing to its own IP addresses. Typically, penetration tests are used to identify the level of technical risk emanating from software and hardware vulnerabilities. Penetration Testing is an appropriate method for identifying the risks present on a specific, operational system consisting of products and services from multiple vendors. It is also applied to systems and applications developed 'in-house'.
Please note, our company websites may contain links to other websites (such as those of our manufacturers and suppliers) that are not controlled by us or our service providers. These links are provided for your convenience. We are only responsible for our own privacy practices and our security of Haynes Group Websites. We recommend that you check the privacy and security policies and procedures of every other website that you visit.
Most browsers automatically accept cookies but you can usually change your browser to prevent cookies from being stored. With experience, you can usually choose to switch off all cookies or to allow only certain ‘trusted’ sites to place cookies. For further information on cookies and Flash cookies and how to switch them off see the Information Commissioner’s website at www.ico.gov.uk or visit www.allaboutcookies.org or www.aboutcookies.org.
PLEASE NOTE, IF YOU DO TURN COOKIES OFF, THIS WILL LIMIT THE SERVICE THAT WE CAN PROVIDE TO YOU AND MAY AFFECT YOUR USER EXPERIENCE.
If you send us a private or direct message via social media the message will be only be stored by Haynes for the duration of the query and then deleted. It will not be shared with any other organisations. Haynes operate and manage our own social media accounts and no other third parties are involved.
When you call the Haynes, tracked telephone lines will collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness. Recorded calls are retained for twelve months. Call Recording is switched off when taking financial information over the phone.
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
If you use our online service booking form we will collect your name, email address, phone number and details of your car and request. This information will be transferred to our DMS system and will be retained following their policies.
We may use auto-responders to communicate with you by e-mail. To protect your privacy, we use a verified opt-in system for such communications and you can always opt-out of such communications using the links contained in each auto-responder message. If you have difficulties opting out, you may contact us by email, using a website contact form, or in writing by mail at the details at the bottom of this policy.
Your access to certain parts of our website may be protected by a user name and a password. Do not give your password to anyone. If you enter a section of our website that requires a password, you should log out when you leave. As a safety precaution, you should also close out of your web browser completely and re-open it before viewing other parts of the Internet.
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for up to seven years and typically three years from the conclusion of any relevant contract. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
If we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually, we do not identify any complainants unless the details have already been made public.
Haynes tries to meet the highest standards when collecting and using personal information. For this reason, we take any questions we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
We have to hold details of persons who have requested a service to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes about our legitimate interests in informing customers of expiry dates for items such as (but not limited to ) MoT tests, finance expiration dates.
Haynes tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 2018. If we do hold information about you we will:
To make a request to Haynes for any personal information we may hold you need to put the request in writing addressing it to our Data Protection Officer at Haynes Group using the address provided below. This request will be free and information will be made available by the Haynes Group within 31 days.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting Haynes.
In many circumstances, we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. You can also get further information on:
The information you provide to us will be held on our server in the United Kingdom and may be accessed by or given to our staff.
We may pass your data onto any law enforcement agency, court, regulator, government authority or other third parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you before collecting your information if we intend to use or disclose it for such purposes. If you do not want us to use your information for marketing purposes the latest communication received will have an opt-out avenue. You can also email us by Clicking Here and asking for your data to be removed or you can write to us at the address below.
By using our Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
We take the business of reviews seriously and use a company called Judge Services to conduct our after-sales reviews for our Used Vehicle departments. Judge Services adhere to the UK’s Consumer Protection from Unfair Trading Regulations (CPRs) and advertising rules. They also follow the Competition and Markets Authority guidance for online reviews and endorsements.
They work under the Information Commissioner’s Office, which regulates these laws and publish marketing guidance, to understand what is needed to be legally compliant. Should you wish to find out more about Judge Services please contact them at:
11 Cardale Court
Data Protection Officer
Haynes Brothers Ltd
23 Ashford Road,
Kent. ME14 5DQ
Or email us by Clicking Here.
We may amend this Policy from time to time. If we make substantial or material changes in the way we wish to use your personal information we will communicate by providing a prominent notice on the Website or by contacting you directly. If you do not agree with these changes, please do not continue to use our company Websites.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Haynes collection and use of personal information. This Privacy Notice will be reviewed annually and this will be due in May 2021.
This privacy notice was last updated on May 31st 2020.
List of Manufacturers and Subsidiary Companies that Haynes Group provide information to, alongside reputable third parties used for relevant processing:
Ford Motor Company Limited, Eagle Way, Brentwood, Essex. CM13 3BW.
FCE Bank PLC, Manchester Business Centre, Number One 1 Tony Wilson Place, Manchester M15 4FN.
Ford Lease, Oakwood Drive, Emersons Green, Bristol, United Kingdom. BS16 7LB.
ALD Automotive, Oakwood Drive, Emersons Green, Bristol, United Kingdom. BS16 7LB.
IVECO Ltd, Cranes Farm Road, Basildon, Essex. SS14 3AD
FCA Italy S.P.A., Corso G. Agnelli 200, 10135 Turin, Italy.
Case IH, CNH Industrial N.V., Corporate Office, 25 St. James's Street, London, SW1A 1HA
JCB Finance Limited Ltd, The Mill, Rocester, Staffordshire ST14 5JW
1. J.C. Bamford Excavators Limited (company number 00561597)
2. JCB Sales Limited (company number 0792807)
3. JCB Service (company number 0564955)
4. JCB Landpower Limited (company number 2321141)
5. JCB Earthmovers Limited (company number 0934508)
6. JCB Heavy Products Limited (company number 2517503)
7. JCB Access Limited (company number 03943798)
8. JCB Power Products Limited (company number 5846086)
9. JCB Power Products Broadcrown Limited (company number 09783957)
10. JCB Compact Products Limited (company number 1980852)
11. New Holland Agriculture, Cranes Farm Road, Basildon, Essex. SS14 3AD
WillCreate Media, Suite 3, The Thorne Estate Business Park. Ashford, Kent. TN26 3AF
JudgeService, 12 Cardale Ct., Cardale Park, Harrogate. HG3 1RY
IDoMarketing, Canterbury Innovation Centre, 4a University Road, Canterbury, CT2 7FG
Rhino Design (Manchester) Ltd, Monaghan House, Clarendon Street, Hyde, Cheshire, SK14 2EP