25 May 2018
Introduction – Who We Are
RTS Consultants (UK) Ltd, Fimtrac F&I and Compliance Ltd, RTS Consultants (International) Ltd, trading as RTS Group (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
RTS Group’s registered office is at The Paddocks, Notton, Lacock, Chippenham, Wiltshire SN15 2NF and we are a small group of companies registered in England and Wales as follows:
- RTS Group Ltd (parent company), Company Number 09338709
- RTS Consultants (UK) Ltd, Company Number 03184066
- RTS Consultants (International) Ltd, Company Number 07051657
- Fimtrac F&I and Compliance Ltd, Company Number 07055295
We are registered on the Information Commissioner’s Office Register; registration number
- RTS Consultants (UK) Ltd ZA361036
- Fimtrac F&I and Compliance Ltd ZA361078
and act as the data controller/processor when processing your data. Our Compliance Officer can be contacted at The Paddocks, Notton, Lacock, Chippenham, Wiltshire SN15 2NF.
Information That We Collect and Use
RTS Group processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect and use from you includes:
- Information about who you are eg your name, date of birth and contact details;
- Information connected to the service provided;
- Information about your contact with us eg meetings, phone calls, emails/letters;
We collect information in the following ways:
- An application form for a role with us;
- Phone conversations with us;
- Emails or letters you send us;
- Registering for one of our training events;
- Our online services such as our website, social media and mobile device application (apps)
How We Use Your Personal Data (Legal Basis for Processing)
RTS Group takes your privacy very seriously and only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below:
- We collect your personal data in the performance of a contract or to provide a service;
- We collect and store your personal data as part of our legal obligation for business accounting and tax purposes;
- We will occasionally send you marketing information where we have assessed that it is beneficial to you as a client and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests;
- We will collect and use your personal data where you have given us your permission (consent) in order to send you information about our services or about roles available within RTS Group;
You have the right to access any personal information that RTS Group processes about you and to request information about:
- • What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and Disclosing Your Personal Information
We may share your information with third parties for the reasons outlined in “How we Use Your Personal Data”. Those third parties may include:
- Companies within the RTS Group;
- Your employer;
- The motor manufacturer owner of the franchise with whom you are employed;
- Companies we have chosen to support us in the delivery of our services eg training delivery, event delivery;
- Companies that help us in our contact with you eg internet service provider;
- HM Revenue and Customs eg for the processing of payroll (if applicable);
RTS Group takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimize loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and undertake annual training on this.
Transfers Outside the EU
Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. The majority of your information is processed in the UK and European Economic Area (EEA).
However, RTS Group utilise some products or services (or parts of them) that may be hosted/stored in non-EU countries (eg USA, India), which means that we may transfer any information which is submitted by you through the website outside the European Economic Area (“EEA”) for the below purposes:
- website hosting;
- App hosting;
- email servers;
- marketing database;
Therefore, when you use our website, send us an email or apply for a role, the personal information you submit may be stored on servers which are hosted in non-EU countries. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by RTS Group to protect your data and comply with the relevant data protection laws.
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to RTS Group, however, as this information is required for us to provide you with our services /deliver your learning and development and our legitimate interests, we will not be able to offer all our services without it.
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
How Long We Keep Your Data
RTS Group only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Special Categories Data
Owing to the services that we offer, RTS Group sometimes needs to process sensitive personal information (known as special category data) about you, to allow us to book flights or hotels on your behalf and to inform caterers of dietary requirements. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Where we rely on your consent for processing special category data, we will obtain your explicit consent through an explicit mechanism. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.
Lodging A Complaint
RTS Group only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
Wiltshire SN15 2NF
Tel: 01249 445622
Information Commissioner’s Office
Wycliffe House, Water Lane
Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate) 01625 545745 (national rate)