Privacy Notice

This notice explains what personal information Behind the Wheel collects about you, why we collect it, how long we keep it, who we share it with, and what rights you have. It is given to you under Articles 13 and 14 of the UK General Data Protection Regulation.

1. 1. Who is responsible for your data

   1. Behind the Wheel is a sole trader business carried on by Sarah Solts, DVSA Approved Driving Instructor, registration number 460324. Sarah Solts is the data controller for the purposes of the UK General Data Protection Regulation and the Data Protection Act 2018.
   2. You can contact us about anything in this notice by email at sarah@solts.com or by telephone on 07800 700777. A postal address is available on request.
   3. We are registered with the Information Commissioner's Office as a data controller and pay the data protection fee. Our entry can be found on the public register maintained by the Information Commissioner at ico.org.uk, and our registration reference is available on request.
   4. We are a very small business and we do not have, and are not required to have, a Data Protection Officer. Sarah deals with all data protection matters personally.

2. 2. What we collect and why

   What we collect	Why we need it
   Enquiry detailsYour name, mobile number, the area you live in, and anything you tell us in your message	To answer your enquiry and arrange a first lesson. Submitted through the website form, by telephone, text, WhatsApp or email.
   Contact and booking detailsName, mobile number, email address, and the address we collect you from	To arrange, confirm and change lessons, and to reach you if plans change.
   Licence detailsLicence number, category, expiry, and any endorsements you tell us about	To confirm you are lawfully entitled to drive and that our insurance covers you. Without this we cannot teach you.
   Progress recordsNotes on what you have covered, what you found difficult, and readiness for test	To plan your lessons properly and to give you honest advice on when to book a test.
   Health informationAny condition, disability, medication or injury that could affect safe driving	To teach you safely and to comply with the law. See clause 4, this is treated with extra care.
   Payment recordsAmounts, dates and bank transfer references	To keep proper business accounts. We are required by tax law to hold these.
   Incident informationWhat happened, when, and who was involved	Only if there is an accident, a near miss, a complaint or an insurance claim.
   Dashcam footageVideo from a camera fitted to the tuition vehicle, if one is fitted	Safety and insurance evidence. See clause 9.

   1. We do not collect your bank account details. Payment is made by transfer from you to us, which means we see only the reference and the amount received.
   2. We collect no more than we need. If you give us information we do not need, we will not keep it.

3. 3. Our lawful basis for using it

   1. Performance of a contract, Article 6(1)(b). Most of what we do with your information is simply to deliver the lessons you have booked, including arranging times, teaching you and recording progress.
   2. Legal obligation, Article 6(1)(c). We must keep records of money received under section 12B of the Taxes Management Act 1970, and we must comply with a lawful request from the DVSA, the police or a court.
   3. Legitimate interests, Article 6(1)(f). We rely on this to respond to an enquiry before any contract exists, to keep our insurance valid, to deal with a complaint, and to establish or defend a legal claim. We have considered your interests and we do not believe any of this is unexpected or intrusive.
   4. Consent, Article 6(1)(a). We rely on consent only where we ask for it separately, for example before using a photograph of you on our website or social media. You can withdraw consent at any time and we will remove the material.

4. 4. Health information

   1. Information about your health is special category data and is given greater protection by law. We ask for it only where it affects your fitness to drive or your safety during a lesson.
   2. Where we need it, we rely on your explicit consent under Article 9(2)(a). You do not have to give it, but if we cannot satisfy ourselves that you are fit to drive, we may not be able to teach you.
   3. If an accident, insurance claim or legal claim arises, we may also rely on Article 9(2)(f), which permits processing where necessary to establish, exercise or defend legal claims.
   4. We do not share health information with anyone unless you ask us to, or unless it is required for an insurance claim or by law. It is never used for any other purpose.
   5. You are responsible for telling the DVLA about any notifiable medical condition. We do not report your health information to the DVLA on your behalf, and we do not monitor whether you have done so.

5. 5. Where we get your information from

   1. Almost everything we hold comes directly from you, by telephone, text message, WhatsApp, email, the website enquiry form, or in conversation during a lesson.
   2. Where a parent or guardian books lessons for someone under 18, we receive that person's information from them.
   3. We may receive information from our insurer or from the DVSA if a claim or a complaint arises.

6. 6. Who we share it with

   1. We do not sell your personal information to anyone, and we do not share it with marketing companies, lead generators or data brokers.
   2. We share it only where necessary, with the following.
   3. Our form provider. Enquiries submitted through the website form are delivered to us by a third party form service, which processes the message on our behalf and does not use it for its own purposes.
   4. Our insurer and broker. Where an incident or claim arises, and only to the extent needed to deal with it.
   5. Our accountant. Payment records only, for the preparation of accounts and tax returns.
   6. The DVSA, the police, HM Revenue and Customs, or a court. Where we are required by law to provide information, or where it is necessary to establish or defend a legal claim.
   7. Where we use a supplier to process data on our behalf, they act only on our instructions under a written contract and cannot use your information for their own purposes.

7. 7. Information sent outside the UK

   1. Some of the services we use to run the website are provided by companies based outside the United Kingdom, including in the United States. This applies to our website form provider and to the font service that displays the text on our pages, which receives the internet address of your device when a page loads.
   2. Where information is transferred outside the United Kingdom, we rely on the safeguards permitted by Article 46 of the UK GDPR, which in practice means the International Data Transfer Agreement or the UK Addendum to the European Commission's standard contractual clauses, or on a finding of adequacy by the Secretary of State.
   3. You can ask us for details of the safeguards that apply to any particular transfer.

8. 8. How long we keep it

   What	How long
   Enquiries that do not lead to lessons	Deleted within 6 months.
   Your tuition recordContact details, licence details, progress notes, health information	Kept only while we are teaching you. Deleted within 30 days of you passing your test or tuition otherwise ending.
   Payment records	At least 5 years after the 31 January filing deadline for the relevant tax year, as required by section 12B of the Taxes Management Act 1970. These show payments only.
   Incident, complaint and claim records	Until the matter is finally resolved and any limitation period for a claim has expired.
   Dashcam footage	Overwritten automatically. Footage is only retained where it relates to an incident, and then only until that matter is resolved.

   1. We do not keep your tuition record for future marketing, and we do not build a mailing list from former students.

9. 9. Dashcam footage

   1. A dashcam may be fitted to the tuition vehicle. Where one is fitted, a notice is displayed in the vehicle so that you know.
   2. It is there for safety and for insurance evidence, and we rely on our legitimate interests under Article 6(1)(f). It is not used to assess your progress and it is not shared with anyone except an insurer, the police, or as required by law.
   3. Footage is overwritten on a continuous loop. We only download and keep a clip where it relates to an incident.
   4. You may ask for a copy of footage that shows you. We may need to obscure other people who appear in it before we provide it.

10. 10. Our website and cookies

    1. Our website does not set advertising cookies, does not track you across other websites, and does not run analytics that profile you.
    2. The website loads fonts from a third party font service. When a page loads, that service receives the internet address of your device. This is necessary for the page to display correctly.
    3. Our web host keeps standard server logs, which may include your internet address, for security and to keep the site running.
    4. Our cookie notice explains this in more detail, and confirms that this website sets no cookies at all.

11. 11. Marketing

    1. We do not send marketing emails or texts. If that ever changes, we will only do so where you have agreed, and every message will carry a simple way to stop.
    2. Contacting you about a lesson you have booked, or replying to an enquiry you have made, is not marketing.
    3. We sometimes post about passes on social media. We do this only with your consent, and for anyone under 18, only with the consent of a parent or guardian. You can withdraw that consent at any time and we will take the post down.

12. 12. Students under 18

    1. Where a student is under 18, the booking is made with a parent or guardian, who is responsible for payment and who we will keep informed as necessary.
    2. We take particular care with the information of anyone under 18, we collect no more than is needed to teach them safely, and we never publish their image or name without the consent of a parent or guardian.

13. 13. How we keep it safe

    1. Records are held on password protected devices with encryption enabled, and access is limited to Sarah alone.
    2. Paper notes, where kept, are stored securely and are destroyed once no longer needed.
    3. No system is completely secure, but we take steps appropriate to the size of the business and the sensitivity of the information.
    4. If a breach occurs that is likely to result in a risk to your rights, we will report it to the Information Commissioner's Office within 72 hours, and we will tell you where the law requires it.

14. 14. Your rights

    1. You have the right to be told how your information is used, which is what this notice does.
    2. You have the right of access, meaning you can ask for a copy of the information we hold about you.
    3. You have the right to have inaccurate information corrected.
    4. You have the right to ask us to delete your information, which we will do unless we are required to keep it for tax purposes or for a claim.
    5. You have the right to ask us to restrict what we do with it while a query is resolved.
    6. You have the right to object to processing we carry out on the basis of legitimate interests.
    7. You have the right to portability, meaning you can ask for the information you gave us in a machine readable form.
    8. Where we rely on consent, you have the right to withdraw it at any time, and withdrawing it does not affect anything done before you did.
    9. There are no automated decisions and no profiling. Every decision about your tuition is made by Sarah personally.
    10. To exercise any right, email sarah@solts.com. There is no charge. We will respond within one month, and we will tell you if we need longer because a request is complex.

15. 15. How to complain

    1. If you are unhappy with how we have handled your information, please tell us first at sarah@solts.com. We would rather put it right ourselves.
    2. You also have the right to complain to the Information Commissioner's Office at any time. Visit ico.org.uk, telephone 0303 123 1113, or write to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
    3. Complaining to the Information Commissioner does not affect any other legal right you have.

16. 16. Changes to this notice

    1. We review this notice at least once a year, and whenever the way we handle information changes.
    2. The current version is always the one published here. The version number and review date are shown at the top of the page.