Ford Drive

Privacy Policy

Ford Smart Mobility UK Limited (branded as Ford Drive) (“Ford”, “we”, “us” or “our”) is conducting a pilot to lease commercial vehicles (“Vehicles”) for the purpose of performing a study to research and validate how flexible lease and additional services is attractive to commercial customers and validate the ways in which vehicles perform for these customers (the “Pilot”).

This Privacy Policy explains how we collect, use and share personal information, when you submit an application, participate in the Pilot, visit our Ford Drive website (the “Website”) or when you contact us using details available on it.

INFORMATION WE COLLECT ABOUT YOU

We may collect information:

  • you submit (such as your name and contact details) by completing an application on the Website to register interest in participating in the Pilot (“Application”);
  • you share with us to help us to verify your Application and conduct licence and identity verification and credit and cash flow checks (“Eligibility Checks”);
  • when you apply to the Pilot, from third parties such as providers of Eligibility Checks including Credit Reference Agencies and Fraud Prevention Agencies (or through our Group Companies who engage with the providers on our behalf);
  • regarding the state of the Vehicle and how it is driven. This may include information about the Vehicle's location, driving route, mileage, vehicle speed and acceleration, braking conditions, steering angle, powertrain parameters, diagnostic codes and associated vehicle status, seat belt usage information and details of any accidents or substantially similar information (“Telematics Data”);
  • regarding the condition of the Vehicle, which may be collected by our delivery partners or shared with us when you upload photographs of the Vehicle to our Vehicle inspection app, along with a digital signature;
  • in the form of film footage and photographs of you, to be used for promotional purposes;
  • you provide when you contact us with a query such as your name and email address;
  • you include in survey responses, feedback or interviews relating to the Pilot;
  • about your activity on the Website, which is collected via cookies.

HOW DO WE USE YOUR INFORMATION?

We use the information you provide to us to:

  • assess and consider Applications and to make decisions about such Applications, including carrying out Eligibility Checks with our third parties, as described below;
  • assess the performance of the Pilot and the condition of the Vehicle;
  • recover the Vehicle in the event of theft, or non-payment of the subscription fees;
  • develop new and improved products, services and marketing and research strategies;
  • promote the Pilot through sharing film footage and photographs on Ford's social media accounts, including Ford's official Facebook, Twitter and Instagram accounts as well as any other media of Ford and our affiliates' choosing;
  • if requested, contact you in relation to your query;
  • understand how you use the Website to develop and improve our products, services and marketing strategies;
  • support compliance with valid notices or enquiries from law enforcement, for example in relation to speeding fines.

OUR LEGAL BASIS FOR USING YOUR INFORMATION

The UK's data protection law allows us to use your personal information provided we have a legal basis for doing so. The legal basis that we rely on to use your information is that:

  • we have a legitimate interest in collecting Applications for and conducting the Pilot and, if requested, contacting you with further information.
  • there may be circumstances in relation to managing your Application or the Pilot where we believe it is necessary to use your personal information to comply with a legal or regulatory obligation.

SHARING YOUR INFORMATION

We may share your information with third parties in the following circumstances:

  • Fleet Management: We may share your information with our fleet management company, Ford Fleet Management (“FFM”). More details about FFM's use of your personal information is set out in its full Privacy Notice. FFM recommends that you review this notice which is available online at FFM.
  • Service Providers: We may share your information with our service providers. Where we do this, we ensure they are subject to agreements that oblige them to use the information only as we instruct, and to keep it securely.
  • Eligibility Checks: In order to assess your Application, we may share your information with third parties to assist in conducting Eligibility Checks (as described below).
  • Group Companies: Ford may also share your personal information with Ford Motor Company and other Ford Motor Company Group companies worldwide. When we share your personal information, we will make sure that is used for purposes which are compatible with those described in this notice. A list of the companies within Ford Motor Company Group is available at www.ford.co.uk.
  • Social Media: We may share film footage or photographs of you on Ford's official social media accounts for promotional purposes.
  • Law enforcement and other government agencies: We may also share your personal information in order to comply with a legal requirement or requests from public authorities; to protect or defend our or another's rights or property; to protect individuals' personal safety; or to detect, prevent, or otherwise address fraud, security, safety, or privacy issues.
  • Asset purchasers: We may share your personal data with any third party that buys, or to which we transfer, all or some of our assets and business. In this case, we will make efforts to ensure that the buyer uses it in a manner that is consistent with this Privacy Policy.

ELIGIBILITY CHECKS

In order to process any Application, Ford will perform Eligibility Checks on you with one or more trusted third-party provider (“Providers”) or using information located on Companies House. Our Providers may include HooYu (a Mitek company) or Direct ID.

To do this, we may supply your personal information to Providers to allow them to contact you and conduct the Eligibility Checks. The Providers will then supply to us information such as banking transaction data, your credit status and details regarding your driving licence (including age, length of licence and number of penalty points that you have).

We will use this information to:

  • Assess your eligibility for the Pilot and whether you can afford to take the product;
  • Verify the accuracy of the data you have provided to us;
  • Prevent criminal activity, fraud and money laundering;
  • Recover debts;

We may periodically receive information about you from the Providers during the Pilot to ensure that you remain eligible.

Our use of Credit Reference Agencies & Fraud Prevention Agencies

In order to process your application, Ford and our Providers will perform credit and identity checks on you with one or more Credit Reference Agencies (“CRAs”). Ford may also make periodic searches at CRAs to manage your account with us and to ensure that you can afford to make your payments. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

  • Assess your creditworthiness and whether you can afford to take the product;
  • Verify the accuracy of the data you have provided to us;
  • Prevent criminal activity, financial crime, fraud and money laundering;
  • Manage your account(s);
  • Trace and recover debts;

Ford will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs. When CRAs receive a search from us they will place a search footprint on your credit file that maybe seen by other lenders. If you exercise a right to withdraw from the agreement leaving sums outstanding, we will notify this debt to the CRAs. We may also use information obtained from your performance of this and any other agreement you have with us and our group.

If you have lived in another country within the last three years, we may ask our group to search your record with CRAs in that location.

If you are a business or a director, Ford Credit will search the personal record of you, your partners and/or your directors and company secretary in addition to the record of your business with a number of CRAs and they will keep details of our search. Information held about you (and where you are a business, your partners and/or directors and company secretary) by these agencies may already be linked to records relating to other people with whom you have a financial association. In connection with your application, you may be treated as financially linked with them and assessed with reference to any such associated records. This information will be available to other businesses and organisations that make similar searches.

For further information, please visit Experian.

The personal information we have collected from you will be shared with fraud prevention agencies to help us make credit related decisions. Your personal data will be used to prevent fraud and money laundering, and to verify your identity.

If fraud is detected or you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention to help make credit decisions following the commencement of this agreement including but not limited to the reassessment of a credit limit. For these purposes we may make further searches.

Automated decision making

As part of the processing of your personal data, decisions may be made by automated means. This means that we sometimes make decisions about you using only technology, where none of our employee or individuals have been involved. For example, we may do this to decide whether to offer you a product or service. If you wish to have an automated decision reviewed by someone you can contact us in writing.

PRIVACY MODE

If you are successful in your Application, we acknowledge that you may use the Vehicle in accordance with the rental agreement for limited personal and domestic use. You may therefore request that Telematics Data, is not shared with us during certain hours of the day when the Vehicle is not being used in a commercial context. You can notify us of your preferences by calling during business hours (between 9:00 to 17:00) on the contact details which we provide to you.

OVERSEAS TRANSFERS

The IT systems on which we store your information may be located outside the European Economic Area, including in countries where the law provides less protection for personal information. If this is the case, we will ensure that appropriate safeguards are in place to protect the personal information and to ensure it is kept securely. You may contact us for a copy of the safeguards which we have put in place to protect your personal information in these circumstances.

YOUR RIGHTS AND HOW TO CONTACT US

You have the right as an individual to find out what information we hold about you and for what purposes, as well as to make corrections if necessary. You also have the right in some circumstances to object to our continuing to process your personal data, or to ask us to delete, restrict the use of, or port your information to another service provider.

If you are unhappy about how we use your information, we hope that in the first instance you will let us know so that we are able to address your concerns. However, you are also entitled to lodge a complaint to the Information Commissioner's Office, which is the authority that upholds information rights in the UK.

If you have questions or concerns regarding our use of your personal information, or would like to exercise any of your rights, please contact:

Email: dpeurope@ford.com

Post: Privacy Enquiry
PO Box 616 HULL
HU9 9PR

HOW LONG DO WE KEEP YOUR INFORMATION?

We only keep your information in identifiable form for as long as is necessary for as long as is reasonably necessary for the purposes for which it was collected and as required to comply with applicable legal and regulatory obligations. This generally means holding the information for as long as one of the following apply:

  • your information is reasonably required in order to manage your Application or to run the Pilot
  • your information is reasonably required in order to protect and defend our rights or property (this will generally be the length of the relevant limitation period in your jurisdiction) or
  • we are otherwise required to keep your information by applicable laws or regulations.

We use appropriate systems, policies and procedures and technology to protect and maintain the security and accuracy of your information.

CHANGES TO THIS POLICY

We may update this policy from time to time. If we change this policy, we will notify you of the changes. Where changes will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights in relation to your personal information (for example, to object to the processing).

Version 2. May 2024