Part 2 - RAC Breakdown via our partners

Purpose and legal basis for using your information

We provide RAC Breakdown services to the customers of our partner organisations. Those partners include vehicle manufacturers, banks, and insurance companies. You may be entitled to RAC Breakdown services through your relationship with one of our partners even if you haven’t purchased the cover directly from RAC.

For example:

you may receive the benefit of RAC Breakdown when you purchase a new vehicleyou may receive the benefit of RAC Breakdown when you purchase a new vehicle, open a new bank account or hace chose RAC Breakdown as an add-on to your insurance policy.

This part of our privacy notice explains how we will use your personal data when you are covered by RAC Breakdown via one of our partners.

When providing you with RAC Breakdown, RAC Motoring Services may be:

a data controller, which means that we will be responsible for how we use your data; or
a data processor, which means that we will use your data on behalf of our partner who will be the data controller.

Confirmation of whether we are a data controller, or a data processor will be included in the Welcome Pack you receive when your cover begins.

Where we are solely responsible for our use of your data (so we will be a controller), we may use your data for the following purposes:

Providing our service to you

Our purpose for using your data	Our lawful basis
Breakdown service: To provide you with our breakdown service.	Performance of contract / Legitimate interest
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, administration 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: If we have permission to do so, we may use 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

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

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:

Performance of contract: We rely on this basis if we have a contract directly with you and when our use of your data is necessary for the performance of 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. Where we provide you with a service but we don't have a contract directly with you, we rely on legitimate interest as our lawful basis. 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.

The information we collect

The information which we collect about you to provide you with breakdown services may 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 if you need to purchase any additional parts or services

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
Communicating with us	Telephone conversations and communication by email, post and social media

Our services

Category of information	Examples
Vehicle details	Make, model, vehicle registration number
Dashcam footage	We use dashcams on our patrols which may record your image
Breakdown details	Your whereabouts, VRN, photos

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 or our contractors.
Our partners: If you have complimentary RAC breakdown cover because of your relationship with one of our partners (for example because you have purchased a vehicle from one of our partner vehicle manufacturers), they will provide us with basic information about you so that we can verify your entitlement to breakdown cover.
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.
Driving Theory app: basic contact details are sent to the RAC when using the RAC Driving theory app.

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.

If we are a data processor, and we are only using your data on behalf of our partner (who will be the data controller), we will hold your data in accordance with the partners’ instructions. Details of how long they ask us to hold your data may appear in their privacy notice.

Who we share your information with

To administer and provide our breakdown service, RAC Motoring Services may share your data within the RAC Group.

We may also share your data with third parties who are instructed by us, such as:

Our partner: When you are entitled to complimentary breakdown cover as a result of your relationship with one of our partners, we will typically share your data with the partner, primarily for invoicing, customer care and reporting purposes. For example, where our partner is a vehicle manufacturer, we may share information relating to vehicle faults with the partner.
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
Fraud and crime: Fraud detection and crime prevention agencies: organisations that help us with fraud protection and statutory law enforcement agencies.
Regulators: 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. For example, if RAC is sold, we may need to disclose your personal information to our advisers and any prospective purchasers and their advisers.
Debt Recovery and Tracing Agents: to recover any outstanding funds owed to us by you, this can include trying to find 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.

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:

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 our 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.