The data controllers in respect of our website are the GDPR Team at Cuff Miller & Co. Limited. (company registration number: 00432124). You can contact the data controller by sending an email to firstname.lastname@example.org.
This document is to identifies areas where we record, communicate, process or otherwise store or transfer data between ‘us’ (we); Cuff Miller, Cuff Miller & Co. Limited, Cuff Miller and Company (Littlehampton) Limited. Or Cuff Miller Forces Cars and any other party.
Cuff Miller commit to high standards of data security and privacy in both physical and digital forms as detailed within this report. Please note that this is a ‘working document’ and will be updated as Regulations develop and evolve.
Should you have any questions, including specific queries please feel free to contact us.
In the first instance please address letters or email correspondence to:
Cuff Miller and Company (Littlehampton) Limited
Cuff Miller are a Ford Retail Dealership based in Littlehampton, West Sussex, established in 1947.
A motor dealer with a Ford Franchise, Cuff Miller supply new and used Ford vehicles, operate a Service Department maintaining and repairing vehicles; a parts department and an Esso fuel station.
Cuff Miller also operates a Fleet department who supply vehicles for Export and also for Military and Diplomatic personnel at home and abroad.
From the perspective of customer and any account data, this is predominately stored on a Dealer Management System (DMS) – Kerridge Rev8, which offers safeguards and GDPR.
Employee personal data is similarly stored within the DMS, however data is predominantly presented in printed form and kept with sensitive data in locked filing cabinets. From time to time Cuff Miller will take professional legal and HR advice via Peninsula as identified in the employee privacy statement.
By nature of the business some data does have to be shared with the manufacturer or organisations such as the DVLA for purposes of vehicle registration.
Cuff Miller does not use any third party for the purposes of contacting, marketing or promoting its products or services and does not sell data.
In brief, GDPR has five main focusing points.
Article 5 of the GDPR identifies six key principles governing companies such as Cuff Miller who may collect and process ‘personal’ or ‘sensitive data’.
GDPR applies to two specific categories as defined by the ICO (Information Commissioner’s Office)
Personal Data: “Any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier” (ICO, 2018). This may include such data as name, address, email address and the link between you and your vehicle. This includes digital and physical data that is not anonymised.
Sensitive Data: This includes such data such as sexual orientation, race, religion, politics, biometrics and genetics. These forms of information are not currently (04/2018) recorded by Cuff Miller, about either customers or employees.
Considering Article 6 of GDPR legislation (ICO, 2018a) and Recital 47 (ICO,2018b) and rational identified below; Internal investigation of Cuff Miller’s processes identifies that contact for the following purposes is deemed within both the customer’s interest and Cuff Miller’s legitimate interest:
It is the policy of Cuff Miller, that customer contact is made for the purposes of advice opposed to the marketing of products unless specified by the customer. NOTE, in all cases whereby a customer has exercised their right to erasure and/or expressed that they do not wish to be contacted, they shall not be contacted as per their own choice.
Cuff Miller provides a service between ‘us’, supplying and maintaining motor vehicles both new, from FMC and used. Beyond this, we offer the full range of facilities to ensure the vehicles are correctly maintained as per the manufacturer’s guidelines. Items checked as a result of scheduled servicing can be safety critical and could affect the vehicles overall condition including its road-worthiness if less unchecked or unmaintained. In extreme cases, this may lead to a failure and potential for injury or death of vehicle occupants or other road users. It is also likely the vehicle’s value or warranty will be affected. It is argued that there is legitimate interest and relationship between the data subject and controller is both “relevant and appropriate” (ICO, 2018b) the individual rights and freedoms are unlikely to be affected provided that the relationship is existing nd the customer has not already asked not to be erased, or not contacted.
Ultimately direct contact and thus processing of individual data is argued to be lawful for any of the following reasons under Article 6:
The rational used to decide the areas for contact under GDPR Article 6 (ICO, 2018a), Recital 47 (ICO, 2018b) have been established using guidelines  by the ICO (2018c).
The computer network at Cuff Miller is protected by a variety of methods. Including:
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
We use a third party server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
We AND/OR our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
In order to determine performance, the Cuff Miller website uses Google analytics; It is a breach of the user Google Analytics Agreement to share data which is “personally identifiable” data.
Analytics data contains generalised information about user demographics, based on their browsing and search history and also their activity online. This provides overview information such as general location (not specific) and otherwise general data; age range, gender, typical interests and hobbies and so on.
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.
Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/. You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
Cuff Miller engages in online activity in the form of Social Media for the purposes of marketing and promotion of its business and services. This includes Facebook, Twitter, Instagram and Linkedin.
By the same token, levels of security and visibility exist for users to select in most platforms (for example Facebook). It is considered then when an individual interacts with Cuff Miller using their own name, images, videos or graphics they are interacting in the public domain. As such, we ultimately find that we cannot be held accountable for the action of customers online via social media.
From time to time Cuff Miller will engage in online competitions requiring users to share, retweet or like a post or the various Cuff Miller social media pages. In order to be able to complete such competitions it may be necessary to view publicly accessible information, such as shared posts. Privacy settings are set by the user whom has full control over whether they choose to participate in any online interaction. As such it is deemed that interaction on Social Media is subject to the privacy policies of their relevant platforms and not the responsibility of Cuff Miller.
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your name, phone number, email address and any other information you provide in that email, including any information contained in any signature block.
When you contact us using our contact form, we collect your name, phone number, email address, enquiry and IP address.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
If you do not supply the optional information required by our contact form, we may not be able to respond to your enquiry properly.
When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us.
We do not record phone calls.
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Cuff Miller operates a CCTV system throughout the site, for the protection and safeguarding of employees, customers, the business, assets and prevention of crime. The use of CCTV is signposted throughout the site, is not covert and does not cover areas where an individuals privacy may be violated (for example changing or toilet areas.) In areas where cameras may be able to see into neighbouring windows/doorways etc. These areas are digitally ‘blanked’ showing only a black square to avoid invasion of privacy. These are operated in line with the Surveillance Camera Code of Practice (Home Office, 2013).
This section sets out how we obtain or collect information about you from third parties.
Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include referrers (such as existing customers, affiliates or business partners, in particular Ford Motor Company).
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one).
For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.
We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.
Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.
We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here.
Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Our web analytics service, Google Analytics, uses collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy. Information collected about you, once collected is anonymised and stored on an aggregate basis.
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
As with most businesses we use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
Although these companies provide a service which facilitates business operation we do not sure your personal data with them.
Our third party service providers are located in England.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by sending an email to email@example.com and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
We disclose your information to other third parties which are either related to or associated with the running of our business, where it is necessary for us to do so. Further information on each of these third parties is set out below.
Although third party access is not granted for the purposes of marketing, due to the varying number of systems that are used for day-to-day operation and mandated by Ford Motor Company, it is inevitable that in some cases, those supplying or maintaining such applications will have access to part of the system or programs. All systems are checked for compliance under GDPR.
Predominantly access is via Ford and it’s subsidiaries. See Ford Fair Collection Notice.
We also use a video reporting system; CitNow who provide the facility for Video Health Checks and for new and used vehicle videos. You can see how this data is used here: https://www.citnow.co.uk/data-protection-policy/
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts. Our accountants are located in England.
Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice. Our advisors are located in England.
Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example.
Although we will advertise such products or services on affiliate websites, Cuff Miller does not share your personal data with any affiliate site.
Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.
In particular, Ford Motor Company. See Ford Fair Collection Notice.
Our business partners are located in England.
Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business. Our independent contractors are located in England.
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them. Our insurers are located in England.
Indicating possible criminal acts or threats to public security to a competent authority.
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Server log information: we retain information on our server logs for 30 days.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email, via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 120 further months, after which point we will delete your information.
Order information: when you place an order for goods and services, we retain that information for seven years, in accordance with our legal obligation to keep records for tax purposes.
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
The GDPR makes specific requirements with regards to the processing of personal data and the operations of ‘Data Controllers’ and ‘Data Processors’. Through analysis carried out by the GDPR team we are satisfied that systems to ensure that these are secure and robust.
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to firstname.lastname@example.org:
As defined by the legislation under Article 17 of the GDPR individuals have the “right to be forgotten”. The specific circumstances as defined by the ICO (2018g) identify that Individuals have the right to have their personal data erased if:
However, it is also identified that the right to erasure are not absolute; with exceptions depending on the purpose behind the storage and processing of such data. Again, the ICO (2018g) guidelines identify that the right to erasure does not apply if processing is necessary for one of the following reasons:
Erasure requests can be made verbally, online or by post and are referred to the GDPR Team to action. The team will forward on a template ensuring that all required information is filled in either by post or email. Alternatively you can download the template here.
The team are contactable at:
Cuff Miller and Company (Littlehampton) Limited
As per ICO guidelines, the policy ensures that data has been erased within one calendar month.
Under the General Data Protection Regulation (2018i), you have the right of access, rectification and portability. Requests for information are similarly processed as per erasure requests via template (as above). Click here for ‘Right of Access’ template.
If you believe your details are incorrect on our system, please just contact us to update. You can do this by email via: email@example.com by phone on 01903 714367.
Specific requests may be able to be dealt with more rapidly than a general information request. Please contact the GDPR team.
Cuff Miller and Company (Littlehampton) Limited
We are happy to supply information either as a printed copy or PDF format.
We aim to complete all requests within 28 days ‘without undue delay’. In most cases this will be quicker.
As per ICO guidelines (2018i) in complex cases, it may be necessary to extend the response time by up to two months, or if multiple applications have been made by the same individual. In such cases Cuff Miller will notify you within the initial 28 day period.
If the request is “manifestly unfounded or excessive, taking into account whether the request is repetitive in nature” Cuff Miller will justify its decision and as per guidelines contact you;
Similarly, if the information requested includes information on other parties we may not comply with the request; or otherwise look for permission from the third party. In each case the Data Controller would consult ICO guidelines.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: https://ec.europa.eu/info/law/law-topic/data-protection_en
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by contacting
Cuff Miller and Company (Littlehampton) Limited
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here.
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet.
We do not knowingly contact or collect information from persons under the age of 17. The website is not intended to solicit information of any kind from persons under the age of 18.
In some cases, for example whereby a Motability vehicle applicant is below the age of 18, we will endeavour to collect the information of the ‘Appointee’ (designated driver) wherever possible.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to firstname.lastname@example.org.
Although the breadth of this document covers multiple aspects of data usage, security and privacy this document specifically looks at the main focus points of GDPR and principles governing all businesses.
All individuals have rights of access under the GDPR as defined, this is limited only whereby the rights or freedoms of other individuals. A process is in place to provide access within 28 days
All customers are asked to confirm details at each visit ensuring data accuracy. Employees are responsible for updating their own details as they change.
All individuals have right to erasure where there is no other legal requirement to keep the data, or if said data is not being used in legal proceedings.
Although much contact is made under the grounds of legitimate interest or in the performance of contract, customers are able to consent on a granular basis as is required under the GDPR
Cuff Miller operates a number of safe physical and virtual measure to maintain the security of data.
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
Google (2018) We are committed to complying with applicable data protection laws:
https://privacy.google.com/businesses/compliance/#?modal_active=none (Accessed Online 24/04/2018)
Gov.uk (2018b) Running a limited company:
https://www.gov.uk/running-a-limited-company/company-and-accounting-records (Accessed Online 05/05/2018)
Home Office (2013) Surveillance Camera Code of Practice:
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/282774/SurveillanceCameraCodePractice.pdf (Accessed online 16/04/2018)
Information Commissioner’s Office (2018) Guide to the general data protection regulation:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr (Accessed online 16/04/2018)
Information Commissioner’s Office (2018b) GDPR recitals and articles:
https://ico.org.uk/media/about-the-ico/disclosure-log/2014536/irq0680151-disclosure.pdf (Accessed Online 18/04/2018)
Information Commissioner’s Office (2018c) How do we apply legitimate interests in practice?:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/legitimate-interests/how-do-we-apply-legitimate-interests-in-practice/ (Accessed Online 18/04/2018)
Information Commissioner’s Office (2018d) Data Protection Officers:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/accountability-and-governance/data-protection-officers/ (Accessed Online 25/04/2018)
Information Commissioner’s Office (2018e) DVLA:
https://ico.org.uk/for-the-public/dvla/ (Accessed Online 27/04/2018)
Information Commissioner’s Office (2018g) Right to Erasure:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/ (Accessed Online 15/05/2018)
Information Commissioner’s Office (2018h) Special category data:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/special-category-data/ (Accessed Online 15/05/2018)
Information Commissioner’s Office (2018i) Right of access:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/ (Accessed Online 15/05/2018)
ZypeTV [CitNow] (2018) CitNow Data Protection Policy:
https://www.citnow.co.uk/data-protection-policy/ (Accessed Online 19/05/2018)
Vehicles in our workshop are independently inspected by the RAC to ensure they meet the high Ford standards for servicing and repair. The checks are conducted at random on customer vehicles throughout the year and include physical and visual quality checks.