Part 2 - Breakdown cover purchased from RAC
Purpose and legal basis for using your information
If you purchase breakdown cover from us, we will use your data for the following purposes:
Providing our service to you
Our purpose for using your data | Our lawful basis |
Pricing your cover: Provide you with a price for your cover (which may include profiling and automated decision making) | Performance of contract |
Breakdown service: To provide you with our breakdown service | Performance of contract |
Administration: Administering your cover including making changes to your cover, taking payments or cancelling your cover | Performance of contract |
Your rights: Complying with your data protection requests under the UK Data Protection regulation and the General Data Protection Regulation | Legal obligations |
Our business activities
Our purpose for using your data | Our lawful basis |
Pricing activities: Using data to develop risk acceptance criteria, develop pricing models with our external partners (which may include profiling) | Legitimate interest |
Business operations and service improvements: Making improvements to our products and services including internal testing, reporting and analysis; business processes and operations including quality assurance, governance, management and audit practices. | Legitimate interest |
Marketing: Using your information for the purpose of marketing activities, including the use of determining the marketing communications we send to you (which may include profiling) and analysis of our marketing activities. | Legitimate interest |
Market Research: organisations who help us to conduct surveys to understand customer views and help us to develop and improve our products and services. | Legitimate interest |
Legal and regulatory
Our purpose for using your data | Our lawful basis |
Disclosure: Disclosing your information to regulators and law enforcement agents as required to do so by law. | Legal obligations |
Fraud detection, debt recovery and legal claims: To prevent or detect fraud, recover debts owed to RAC and using data for the purpose of legal proceedings. | Legitimate interest |
Training and Monitoring: To help us with our training and monitoring, we record all of our inbound and outbound telephone conversations. | Legitimate Interest (for recording telephone calls) |
For each different purpose for which we use your data, we need to have a lawful basis. The different lawful bases are set out in the UK Data Protection regulation and the General Data Protection Regulation. The ones we’re relying on are:
- Consent: We rely on this basis to give you choice where you may not usually expect your information to be recorded. This legal basis is set out in article 6(1)(a) of the UK Data Protection regulation and the General Data Protection Regulation.
- Performance of contract: We rely on this basis when our use of your data is necessary for the performance of the contract between you and RAC and to take steps at your request prior to entering into the contract. This legal basis is set out in article 6(1)(b) of the UK Data Protection regulation and the General Data Protection Regulation.
- Legitimate interest: We rely on this basis when our use of your data is necessary for the purposes of our legitimate interest which does not unduly impact you rights and freedoms. This legal basis is set out in article 6(1)(f) of the UK Data Protection regulation and the General Data Protection Regulation.
- Legal obligations: We rely on this basis when we have a legal obligation to use your data in a certain way. This legal basis is set out in article 6(1)(c) of the UK Data Protection regulation and the General Data Protection Regulation.
RAC Motoring Services will be the data controller for the information about you collected for these purposes which means that we are responsible for the way in which we use your data.
The information we collect
The information which we collect about you to provide you with breakdown services will include:
Information about you
Category of information | Examples |
Key personal details | Name, date of birth, etc |
Contact details | Home address, email address, telephone number |
Your family and beneficiaries | Their name and relationship with you |
Payment details | Bank and card payment details |
Your relationship with RAC
Category of information | Examples |
Your purchases and policies | Details of your cover with us including start and end date and scope of cover. |
Services which we provide to you | Details of the services which we provide to you which may include the time, date and location of your vehicle, the cause of breakdown, etc. |
Communication preferences | Your preferences for how you would like us to contact you. |
Marketing preferences | Your preferences for the marketing you would like to receive from us. |
Communicating with us | Telephone conversations and communication by email, post and social media. |
We may also collect and process special category data where you disclose a vulnerability to us. A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm - particularly when a firm is not acting with appropriate levels of care. Any data pertaining to customer vulnerabilities will be processed with consent to understand the needs of the customer and ensure we respond to those appropriately.
How we get your information
- From you: The personal information which we use is typically provided by you directly to us.
- Our members and applicants for our products may provide us with personal information about other beneficiaries under their policies. If you provide us with any information about other individuals, please inform them beforehand and direct them to this privacy notice.
- Third party intermediaries, brokers and third parties who are authorised to introduce or sell our products and services who provide us with the information necessary to process any applications or requests for products or services.
- DVLA and other agencies who provide vehicle data obtained under licence.
- Information Commissioner’s Office, law enforcement agencies and other public bodies may provide us with information about individuals who have made a complaint or in relation to their investigations and law enforcement activities.
- Aggregators / comparison websites: Comparison sites partnered with RAC share your personal data for the purpose of providing you with a quote for your breakdown cover. For further information on how comparison sites use your personal data please see their respective privacy notices.
- Driving Theory app: basic contact details are sent to the RAC when using the RAC Driving theory app.
- Breakdown details: Your whereabouts, VRN, photos.
How long we keep your information
The RAC keeps your personal information for as long as the law requires, according to the rules and regulations.
Where we record your face to face conversation with one of our agent, we will hold that recording for 3 months.
Who we share your information with
To administer and provide our breakdown service, RAC Motoring Services may share your data within the RAC Group, potentially with RAC Financial Services Limited and RAC Insurance Limited.
We may also share your data with third parties who are instructed by us, such as:
- IT providers: for administration and management of our internal systems;
- Contractors and specialists: Territorial contractors who provide breakdown and recovery services during busy periods, subcontractors and other specialists who help us provide our breakdown service;
- Parts and Equipment providers: to help us repair your vehicle when needed;
- Hire car providers: and onward travel and accommodation specialists if you benefit from additional product provisions;
- Additional services: Accident management and legal services when these services are available to you;
- Fraud detection and crime prevention agencies: organisations that help us with fraud protection and statutory law enforcement agencies.
- Regulators and governmental bodies: such as the Financial Conduct Authority or Information Commissioner’s Office if necessary to meet our mandatory reporting requirements.
- Financial organisations: such as banks that allow us to make or receive payments,
- Professional advisors and purchasers: for the purpose of providing us with professional advice. If RAC is sold, we may need to disclose your personal information to our advisers and any prospective purchasers and their advisers.
- Recordsure: If you purchase RAC breakdown cover in person from one of our agents, we will ask you for your consent to record the conversation for our training and monitoring purposes. Recordsure provides the application which we use to record the conversation.
- Financial credit agencies: such as Klarna who provide online financial services such as interest free payments for provision of batteries at the roadside if required by you.
- Complaints: when you make a complaint to the RAC, depending on the nature of your complaint, we may share information with the company Huntswood.
- Debt recovery and tracing agents: to recover any outstanding funds owed to us by you, this can include trying to find you.
Automated decision-making
Automated decisions are decisions which are made about you using only technology and which aren’t made with the direct input of an actual person.
We use automated decision-making, including profiling, for several different purposes:
- To determine the risk of providing you with a product or service;
- To decide whether to offer a product or service;
- To determine the price of the product or service; and
- Our breakdown management system utilises automated decision making when prioritising breakdown and recovery jobs based on relevant risk factors.
We use automated decision making where it’s necessary in order to provide you with the product or service.
Where your information is held
We are a UK based organisation but we do offer services to our members across Europe, such as our European Breakdown cover. It is possible that we may transfer your personal information outside of Europe, for example, where one of service providers has operations outside of Europe and such transfer is necessary. Where your data is transferred outside of Europe, we will ensure that suitable safeguards are in place to make sure that your data is protected. The safeguard will usually be reliance on standard contractual clauses.