HONDA DEALERS PRIVACY NOTICE (UK)
October 2019
This Privacy Notice tells you how Honda Motor Europe Limited (“Honda”, “we” or “us”) process your personal data in the context of its relationship with Honda authorised Dealers (“Honda Dealers”) and their personnel (including employees, contractors, officers and representatives) (“Dealer Personnel”). It also describes your data protection rights, including a right to object to some of the processing that Honda carries out. More information about your rights, and how to exercise them, is set out in the “Your Choices and Rights” section.
What Personal Data We Collect
We process the following types of personal data from Dealer Personnel.
· Contact information: such as your name, position, business phone numbers and business email.
· Performance metrics: such as information that allows us to assess the performance of the Honda Dealer, including Dealer Personnel.
· Customer satisfaction reports in which customers may share feedback about particular personnel.
· Event Management such as your name, phone, email, dietary information. Depending on the location of the event we may need your passport and driving license information, and where necessary we may need your next of kin. Where the event also invites partners, we may ask for similar information on your partner.
Why We Collect, Use and Store this Personal Data
We collect, use and store your personal data for the reasons set out below.
· Where necessary for Honda's legitimate interests, as listed below, and where our interests are not overridden by your data protection rights.
o Making Dealer Personnel contact details available to Honda personnel, Honda group companies, other Honda Dealers, third parties providing services to Honda Dealers and the Honda Dealer Network Council
o Planning our business and operating the Honda Dealer network.
o Protecting our legitimate business interests and legal rights. This includes, but is not limited to, use in connection with compliance, regulatory, auditing, legal claims (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements.
o Considering the performance of Dealer Personnel, as required to evaluate the performance of the Honda Dealer, and also to run our awards program.
o Maintaining the security of our equipment, facilities and electronic platforms.
· Where necessary to comply with a legal obligation.
o For compliance with anti-money laundering and other regulations that require the screening of members of the Honda Dealer network.
How We Share Your Personal Data
(a) Transfers within the Honda Group of Companies
We share your personal data with other members of the Honda group to maintain a directory of Honda dealerships and to manage, support and coordinate dealership services.
For the purposes mentioned above, your personal data will be processed in, or accessed from, members of the Honda Group of Companies situated in jurisdictions outside the European Economic Area ("EEA") that do not have equivalent data protection laws to those in the EEA. When we transfer your data within the Honda Group of Companies, we make use of standard contractual data protection clauses, which have been approved by the European Commission.
(b) Transfers to companies providing services under contract
Your personal data will be shared with companies providing services under contract to the Honda Group of Companies, including the companies set out below (to the extent that you make use of the relevant service):
· IT help desk provider (current provider: ATOS IT Services UK Limited);
· IT hosting (current provider: IBM Belgium SPRL/BVBA);
· IT maintenance provider (current provider: IBM United Kingdom Limited);
· E-learning providers (current provider: Raytheon Professional Services GmbH);
· Training providers (Raytheon Professional Services GmbH, and other various ad-hoc providers);
· Performance Metrics & Performance database support
(current provider: River Limited, APD Limited);
· Mystery shops (current provider: various providers);
· Event planning providers (various);
· Dealer Marketing Centre Helpdesk (current provider: Karmarama);
· Dealer Marketing Centre Platform (current provider: Redwing Limited);
· Dealer Asset Portal (current provider: Redwing Limited);
· The Hub email Marketing tool (current provider: Sign-up-to Limited);
· Honda Connections (current provider: Impact Limited);
· Point of Sale Materials
(current provider: RRDonnelly Limited, Impact Limited);
· Honda DNA: (current provider: River Limited);
· Honda Dealer Rewards: (current provider: Power2Motivate);
· Customer insurance providers (Aviva Limited);
· Vehicle Recalls (Hawk Incentives);
· Technical Bulletins SMS updates (current provider: Ultima Business Solutions)
· External legal advisors (current provider: Deloitte);
· Telephone Dealer contact (current provider Chameleon Contact Specialists Ltd);
Further to the above purposes, we will transfer your personal data to organisations outside of the EEA. When doing do, we may use standard contractual data protection clauses, which have been approved by the European Commission. We may also transfer your data to organisations in the US who participate in the EU-US Privacy Shield or which have corporate rules in place to protect your data, which have been approved by EU data protection authorities. For further information, including to obtain a copy of the documents used to protect your information, please contact us as described in the Contact Us section below.
(c) Transfers to government authorities
Personal data will be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.
Your Choices and Rights
You have the right to ask Honda for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Honda processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority. Your relevant data protection authority could be in the place where you live, or where you work, or where a breach of data protection obligations has occurred.
Data Retention
We will retain your personal data only for as long as we need it for Honda's legitimate interest in accordance with applicable law or to meet a legal requirement, after which we will take steps to delete your personal data or hold it in a form that no longer identifies you.
Contact Us
The data controller for your personal data is Honda Motor Europe Limited, Cain Road, Bracknell, Berkshire, RG12 1HL.
If you have questions about this Privacy Notice or wish to contact us for any reason in relation to our personal data processing, please contact HME UK’s Data Protection Manager (dpm-uk@honda-eu.com).