1. Who we are
[Company legal name] Ltd (“we”) runs Pick a Driver and is the controller of the personal data described here. We are registered with the Information Commissioner's Office under number [ICO registration number]. For anything about your data, contact [privacy email address]. [Solicitor: confirm whether a Data Protection Officer is required.]
This notice is for operators, drivers and their staff who use Pick a Driver. We don't collect passengers' details: jobs only describe areas, times and vehicle needs.
2. What we collect
- Account details: your name, email address, whether you're a driver, operator or both, and when you signed in.
- Operator business details: company name, licensing authority, operator licence number and your operator code.
- Documents: copies of operator, driver and vehicle licences and insurance you upload, with their reference numbers, issuing authority, vehicle and expiry dates, and our review decisions and notes. A driving licence can show other information, such as your address, date of birth and any endorsements. [Solicitor: assess whether endorsements count as criminal offence data and what safeguards are needed.]
- Connections: which operators you're connected to and the status of each connection.
- Availability and location: when you go available, your pickup area, where you're heading, vehicle and seats. If you choose to share it on the network map, an approximate position. We don't track your location continuously.
- Jobs and bids: jobs you post, bids, selections, dispatches, acceptances, cancellations, journey payment status and platform fee records.
- Messages from us: the notifications we send you, whether each was emailed, your email preferences and your unsubscribe link.
- Legal and security records: which version of our terms you accepted and when (with your browser type), a log of important account actions, and your network (IP) address, which we use for sign-in rate limits.
3. Why we use it and our lawful bases
- To run Pick a Driver for you (accounts, connections, jobs, bids, fees, notifications): because it's necessary for our contract with you.
- To check documents before jobs go ahead: necessary for our contract and our legitimate interest in a safe, lawful network.
- To show your approximate position on the map: only when you switch it on, as part of the service you've asked for. You can turn it off at any time.
- To keep Pick a Driver secure and prevent misuse (rate limits, logs, suspensions): our legitimate interests.
- To keep business and tax records of fees: our legal obligations.
- To email you updates: necessary for our contract and our legitimate interests. You choose which categories you get in My account. We don't send marketing.
We don't sell your data, use it for advertising or make decisions about you by automated means alone. Our reviewers make document decisions.
5. Service providers
These companies process data for us under contract and only on our instructions:
- Hosting, database and document storage: [Cloudflare, Inc. or Amazon Web Services EMEA SARL, as finally chosen].
- Email delivery: [Amazon Simple Email Service or Resend], to send sign-in links and notifications.
- Map tiles: OpenStreetMap Foundation tile servers. When a map loads, your browser asks them for map images, which shares your IP address with them.
- Payments (when real fees start): [Stripe Payments Europe, Ltd]. During the pilot no payment details are collected.
6. International transfers
Some providers may process data outside the UK. Where they do, we rely on UK adequacy regulations or the UK International Data Transfer Agreement or Addendum. [Solicitor: confirm the mechanism for each provider and region.]
7. How long we keep it
- Sign-in links: expire after 15 minutes and are deleted within a day. Sign-in sessions: last up to 30 days.
- IP addresses used for rate limits: deleted after 24 hours.
- Availability: deleted a day after it expires.
- Account and connection details: while your account is open, then [12 months] after closure.
- Documents: while your account is open and for [12 months] after a document expires or is replaced, to show what was checked for past jobs. If you delete your account, the files are deleted straight away and only their details (type, reference, expiry date and review result) are kept.
- Job, bid and fee records: [6 years] after the end of the financial year they relate to, for tax and dispute purposes.
- Security logs (sign-ins, refused access, rate limits, data downloads and deletions, with network address): 90 days.
- Notifications: [12 months], or until you delete your account.
- If you delete your account: your name, email, availability, connections, notifications and email preferences are removed straight away. Job, bid and fee records stay for the period above, without your name.
[Business: confirm these periods. Automatic deletion is in place for sign-in links, sessions, rate-limit records, availability and security logs; the others need scheduling before launch.]
8. How we protect it
Pick a Driver uses encrypted connections, sign-in links stored only as secure hashes, private document storage that only the owner and reviewers can open, rate limits, audit logs, and encryption of stored service credentials. No system is perfectly secure. If a breach is likely to put you at high risk, we'll tell you.
9. Your rights
Under UK data protection law you can ask us to: give you a copy of your data; correct it; delete it; restrict or object to how we use it; or give it to you in a portable format. Some rights have exceptions, for example where we must keep fee records.
You can download a copy of your data and ask for your account to be deleted from My account, or email [privacy email address]. We'll reply within one month.
10. Changes and complaints
We'll tell you about significant changes to this notice before they take effect. If you're unhappy with how we handle your data, please contact us first. You can also complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.