dh Licence Check takes the security of your personal data extremely seriously. We recognise our responsibilities in this area and the following policies outline these responsibilities.
Data Controller or Data Processor?
The GDPR identifies different obligations of Data Controllers and Data Processors.
It is important to understand these definitions to make sure that the right arrangements are in place.
A variety of different relationships are possible in relation to sharing personal data. These include:
So what is our Relationship?
You will be the Data Controller of information relating to your workers or prospective workers in relation to limited personal information that might be provided by you to allow access to our services.
In relation to the personal data that we engage with, both that provided in relation to individual workers and that gained from the DVLA as an authorised intermediary of the DVLA we are a separate Data Controller.
Arrangements with the DVLA make it compulsory that we are the Data Controller when acting as an intermediary providing licence check services, and we have obligations to manage the purpose and manner in which personal data is processed accordingly, this includes in respect of arrangements with customers who may access driver information.
Should there be a Data Processing Agreement between us?
As we are not your Data Processor the new Data Laws do not require us to enter into a data processing agreement in relation to you as a Data Controller. However, as you may know, the DVLA imposes obligations on all those accessing driver information originating from DVLA driver records.
Accessing driver licence information via us as an intermediary supplier of driver licence services is, therefore, subject to specific GDPR obligations required by DVLA, which apply to us and you as a customer accessing driver data. This is the same obligation for everyone accessing driver information originating from the DVLA. The DVLA requirements substantially reflect the requirements each of us would have under GDPR obligations. We are providing updated information forming part of the Driver Hire/dh Licence Check terms of service which reflect those obligations, and which will apply to future engagement between us.
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