Privacy notice for Sub-contracted self-employed drivers

    In accordance with the general data protection regulation (GDPR), we have implemented this privacy notice to inform you of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
    This notice applies to former and current sub-contractors (self-employed drivers).

    Under GDPR, all personal data obtained and held by us must be processed accordingly to set the core principles. In accordance with these principles, we ensure that:

    Processing is fair, lawful and transparent
    Data is collected for specific, explicit, and legitimate purposes
    Data collected is adequate, relevant and limited to what is necessary for the purpose of processing
    Data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay,
    Data is not kept for longer than necessary for its given purpose
    Data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction, or damage by using appropriate technical or organisational measures
    We comply with the relevant GDPR procedures for international transferring of personal data.

    We keep several categories of personal data on self-employed drivers we use in order to carry out effective and efficient processes. We keep this data in a personal file relating to each driver and we also hold the data within our computer systems, for example, our rota system.

    Specifically, we hold the following types of data:

    Personal details such as name, address, address history and phone numbers
    Name and contact details of your emergency contact
    Your photograph
    Your gender, marital status, information of any disability you have or other medical information
    Right to work documentation
    Information on your race and religion for equality monitoring purposes
    Information gathering via the recruitment process such as that entered into a CV or included in a CV cover letter
    Signed contractor and health and safety forms
    Insurance certificates
    Proof of address
    Mothers first and maiden name
    Email address
    National insurance numbers
    Bank account details
    Tax and VAT codes
    Driving licence
    Criminal convictions
    Drug and alcohol test results
    Information relating to your work with us, including:
    1: Performance related data
    2: pay rates
    3: planned/historical work
    4: details of formal and informal proceedings involving you from contracts worked on
    5: external training modules undertaken
    CCTV footage
    Building access card records
    IT equipment use including telephones and internet access.


    You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your contracted work and on-going.

    In some cases, we will collect data about you from third parties, such as contractors you are conducting work for, DVLA, Eurofin and In Sync.

    Personal data is kept in files or within the company’s HR and IT systems.

    The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the contract we have with you, including ensuring you are paid correctly.

    The information below categorises the types of data processing we undertake and the lawful basis we rely on.

    Activity requiring your dataLawful basis
    Carry out the contract that we have entered with you e.g. using your name, contact details, address history and information involving you (such as DBS/DVLA checks, drug and alcohol tests) to assess on going eligibility to work on the contractPerformance of the contract
    Ensuring you are paidPerformance of the contract
    Carrying out checks in relation to your right to work in the U. KLegal obligation
    Making reasonable adjustments for disabled contractorsLegal obligation
    Making decisions about pay ratesOur legitimate interests
    Ensuring efficient administration of contractual benefits to youOur legitimate interests

    Effectively monitoring both your conduct, including timekeeping and attendance, your performance and to undertake procedures where necessaryOur legitimate interests
    Maintaining comprehensive up to date records about you to ensure, amongst other things, effective correspondence can be archived and appropriate contact points in the event of an emergency are maintainedOur legitimate interests
    Assessing training needsOur legitimate interests
    Dealing with legal claims made against usOur legitimate interests
    Preventing fraudOur legitimate interests
    Ensuring our administrative and IT systems are secure and robust against unauthorised accessOur legitimate interests
    Sharing with third parties to support/ assess your on-going work with us (section H below)Performance of the contract

    Special categories of data that we hold are data relating to your health

    We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented process to guard against this.

    We only keep your data for as long as we need it for, which will be at least for the duration of your work with us though in some cases we will keep your data for a period after your work has ended. Some data retention periods are set by law. Retention periods can vary depending on why we need your data, as set out below.

    RecordStatutory Retention Period
    Pay rates (including bonuses)6 Years
    Worked hours2 years after they are made
    RecordRecommended Retention Period
    Assessments under health and safety regulations and records of consultations with safety representatives and committeesPermanently
    HMRC approvalsPermanently
    Driver files, training records (personal data, ID records, application forms, contract)6 years after end of end of work
    Driver drug and Alcohol test result6 years after end of end of work
    DBS checks6 years after end of end of work
    Performance data6 years after end of end of work
    Payment/invoicing and days worked records6 years after end of end of work
    Van hire records/ insurance documents6 years after end of end of work


    Automated decision-making means making decisions about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely based on automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

    You have the following rights in relation to the personal data we hold on you:
    The right to be informed about the data we hold on you and what we do with it;
    The right of access to the data we hold on you. More information on this can be found in the section headed “access to data” below and in our separate policy subject access request”;
    The right for any inaccuracies in the data we hold on you, however they come to light, to be corrected this is also known as ‘rectification’;
    The right to have data deleted in certain circumstances. This is also known as ‘erasure’;
    The right to restrict the processing of the data;
    The right to transfer the data we hold on you to another party. This is known as ‘portability’;
    The right to object to the inclusion of any information;
    The right to regulate any automated decision-making and profiling of personal data.
    More information can be found on each of these rights in our separate policy on rights under GDPR.

    Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.