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Privacy Policy

Data Protection Policy (All Companies - Compliant with GDPR)


 The organisation is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out the organisation's commitment to data protection, and individual rights and obligations in relation to personal data.

This policy applies to the personal data of job applicants, employees, workers, contractors, volunteers, interns, apprentices and former employees, referred to as HR-related personal data. This policy does not apply to the personal data of clients or other personal data processed for business purposes.

Questions about this policy, or requests for further information, should be directed to:-

Threeways Garage, Data Controller, Faenol Avenue, Abergele, Conwy, LL22 7HT Tel No. 01745 825847



"Personal data" is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

"Criminal records data" means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.

Data protection principles

The organisation processes HR-related personal data in accordance with the following data protection principles:

• The organisation processes personal data lawfully, fairly and in a transparent manner.

• The organisation collects personal data only for specified, explicit and legitimate purposes.

• The organisation processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.

• The organisation keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.

• The organisation keeps personal data only for the period necessary for processing.

• The organisation adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

The organisation tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.

Where the organisation processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.

The organisation will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the employment, worker, contractor or volunteer relationship, or apprenticeship or internship is held in the individual's personnel file in hard copy or electronic format, or both, and on HR systems. The periods for which the organisation holds HR-related personal data are contained in its privacy notices to individuals.

The organisation keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data. Subject access requests Individuals have the right to make a subject access request. If an individual makes a subject access request, the organisation will tell him/her:

• whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;

• to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;

• for how long his/her personal data is stored (or how that period is decided);

• his/her rights to rectification or erasure of data, or to restrict or object to processing;

• his/her right to complain to the Information Commissioner if he/she thinks the organisation has failed to comply with his/her data protection rights; and

• whether or not the organisation carries out automated decision-making and the logic involved in any such decision-making.

The organisation will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

To make a subject access request, the individual should send the request to . In some cases, the organisation may need to ask for proof of identification before the request can be processed. The organisation will inform the individual if it needs to verify his/her identity and the documents it requires.

The organisation will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the organisation processes large amounts of the individual's data, it may respond within three months of the date the request is received. The organisation will write to the individual within one month of receiving the original request to tell him/her if this is the case. If a subject access request is manifestly unfounded or excessive, the organisation is not obliged to comply with it. Alternatively, the organisation can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the organisation has already responded. If an individual submits a request that is unfounded or excessive, the organisation will notify him/her that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require the organisation to:

• rectify inaccurate data;

• stop processing or erase data that is no longer necessary for the purposes of processing;

• stop processing or erase data if the individual's interests override the organisation's legitimate grounds for processing data (where the organisation relies on its legitimate interests as a reason for processing data);

• stop processing or erase data if processing is unlawful; and

• stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override the organisation's legitimate grounds for processing data. To ask the organisation to take any of these steps, the individual should send the request to

Data security

The organisation takes the security of HR-related personal data seriously. The organisation has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Where the organisation engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

Data breaches

If the organisation discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. The organisation will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

International data transfers

The organisation will not transfer HR-related personal data to countries outside the EEA.

Individual responsibilities

Individuals are responsible for helping the organisation keep their personal data up to date. Individuals should let the organisation know if data provided to the organisation changes, for example if an individual moves house or changes his/her bank details.

Individuals may have access to the personal data of other individuals (and of our customers and clients) in the course of their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, the organisation relies on individuals to help meet its data protection obligations to staff and to customers and clients.

Individuals who have access to personal data are required:

• to access only data that they have authority to access and only for authorised purposes;

• not to disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation;

• to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);

• not to remove personal data, or devices containing or that can be used to access personal data, from the organisation's premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and

• not to store personal data on local drives or on personal devices that are used for work purposes.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the organisation's disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.


The organisation will provide training to all individuals about their data protection responsibilities as part of the induction process (and at regular intervals thereafter).

Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them

GDPR – Data Processing Legitimate Interests Assessment (LIA)

Companies: Threeways Garage Limited, Threeways Service Station (Abergele) Limited, Threeways Motorhomes Limited, Easy Clean Car Centre Limited, Threeways Holdings Limited, Threeways Subway Limited.

This LIA relates to the electronic and hard copy documentation of data gathered and processed by the above named companies to enable them to carry out their duties as a business to transact with data subjects and perspective customers, businesses and other legitimate commercial functions in accordance with our Privacy Notice.

Part 1: Purpose test

You need to assess whether there is a legitimate interest behind the processing of Data.

a) Why do you want to process the data?

b) What benefit do you expect to get from the processing?

c) Do any third parties benefit from the processing?

d) Are there any wider public benefits to the processing?

e) How important are the benefits that you have identified?

f) What would the impact be if you couldn’t go ahead with the processing?

g) Are you complying with any specific data protection rules that apply to your processing (eg profiling requirements, or e-privacy legislation)?

h) Are you complying with other relevant laws?

i) Are you complying with industry guidelines or codes of practice?

j) Are there any other ethical issues with the processing?


a) We want to process the data to ensure we are able to communicate with the data subject.

b) Being able to communicate any associated enquiries, services or products relevant to the data subject.

c) 3 rd parties will benefit from being able to communicate effectively regarding enquiries, services or products relevant to the data subject.

d) Yes

e) E.g ensuring safety reminders for MOT are issued

f) Potential risk of important information such as servicing, MOT or product recalls not being issued to the data subject.

g) Yes

h) Yes

i) Yes

j) No


 Part 2: Necessity test

You need to assess whether the processing is necessary for the purpose you have identified.

a) Will this processing actually help you achieve your purpose?

b) Is the processing proportionate to that purpose?

c) Can you achieve the same purpose without the processing?

d) Can you achieve the same purpose by processing less data, or by processing the data in another more obvious or less intrusive way?


a) Yes

 b) Yes

c) No, it would not be achieved without the processing of subjects’ data

d) We aim to process all subjects data in the least intrusive and most efficient manner.


 Part 3: Balancing test

You need to consider the impact on individuals’ interests and rights and freedoms and assess whether this overrides your legitimate interests.

Nature of the personal data

a) Is it special category data or criminal offence data?

b) Is it data which people are likely to consider particularly ‘private’?

c) Are you processing children’s data or data relating to other vulnerable people?

d) Is the data about people in their personal or professional capacity?

a) No

b) We may need to collect some financial data in relation to finance related products. We made also need to enquire about endorsements or criminal convictions in relation to hire, demonstration or company vehicles.

c) We do not process children’s data. Some disability customers data may be processed in relation to Motability sales and/or vat exemptions

d) Both. We have both private and business customers Reasonable expectations

Reasonable expectations

a) Do you have an existing relationship with the individual(s)?

b) What’s the nature of the relationship and how have you used data in the past?

c) Did you collect the data directly from the individual? What did you tell them at the time?

d) If you obtained the data from a third party, what did they tell the individuals about reuse by third parties for other purposes and does this cover you?

e) How long ago did you collect the data? Are there any changes in technology or context since then that would affect expectations?

f) Is your intended purpose and method widely understood?

g) Are you intending to do anything new or innovative?

h) Do you have any evidence about expectations – eg from market research, focus groups or other forms of consultation?

i) Are there any other factors in the particular circumstances that mean they would or would not expect the processing?

a) Yes with some data subjects LIA template 20180319 v1.0 4

b) Past data has been used to provide information on products, services, important reminder information and marketing communication.

c) Yes. The data subject was asked to opt-in to each of the various communication contact options.

d) Any 3rd party information obtained complies with all GDPR and Data Protection regulations.

e) Some data has been obtained a number of years ago, routine data cleansing has been in action to maintain the most up to date information and any individual instances of data update actioned.

f) Yes

g) No

h) No

i) Not known at this time.

Likely impact

a) What are the possible impacts of the processing on people?

b) Will individuals lose any control over the use of their personal data?

c) What is the likelihood and severity of any potential impact?

d) Are some people likely to object to the processing or find it intrusive?

e) Would you be happy to explain the processing to individuals?

f) Can you adopt any safeguards to minimise the impact?

a) The processing will not impact other than for its intended use

b) No, the data subject will have the right to access, rectify, get copies or erase any personal data

c) There is limited likelihood of impact and the severity minimal based on the information and intended use.

d) No – all rights of the data subject will be followed

e) Yes

f) All safeguards, including training, systems, personnel and 3rd party companies are maintained to minimise risk and impact.

Can you offer individuals an opt-out?



Making the decision

This is where you use your answers to Parts 1, 2 and 3 to decide whether or not you can apply the legitimate interests basis.

Can you rely on legitimate interests for this processing?


Do you have any comments to justify your answer? (optional)


All answers to the above questions have been answered to the best of knowledge and information held at the time and with the interests of the data subjects in mind.

LIA completed by

Peter Cooper





What’s next?

Keep a record of this LIA, and keep it under review.

Do a DPIA if necessary.

Include details of your purposes and lawful basis for processing in your privacy information, including an outline of your legitimate interests.


Job Applicant / Employee Privacy notice

Data controller: Mr C Cunnah (Managing Director) – Threeways Group of Companies Tel No. 01745 825847

As part of any recruitment process, the organisation collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations

What information does the organisation collect?

The organisation collects a range of information about you. This includes:

• your name, address and contact details, including email address and telephone number;

• details of your qualifications, skills, experience and employment history;

• information about your current level of remuneration, including benefit entitlements;

• whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;

• information about your entitlement to work in the UK; and

• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

• Driving Licence and details of any convictions • Call recording data inbound, outbound and internally for training and quality purposes

The organisation may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

The organisation may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. The organisation will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does the organisation process personal data?

The organisation needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you. In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.

The organisation has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.

The organisation may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

Where the organisation processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

(The organisation will not use your data for any purpose other than the recruitment exercise for which you have applied. OR If your application is unsuccessful, the organisation may keep your personal data on file in case there are future employment opportunities for which you may be suited. The organisation will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.)

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes for example; members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with for example; former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

The organisation will not transfer your data outside the European Economic Area.

How does the organisation protect data?

The organisation takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does the organisation keep data?

If your application for employment is unsuccessful, the organisation will hold your data on file until after the end of the relevant recruitment process. If you agree to allow the organisation to keep your personal data on file, the organisation will hold your data on file for a further 12 months for consideration for future employment opportunities. At the end of that period your data is deleted or destroyed. Some data such as call recording may be stored locally for up to 90 days and via secure cloud based servers for up to 6yrs in line with GDPR and data protection relating to your work related duties. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;

• require the organisation to change incorrect or incomplete data;

• require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and

• object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing. If you would like to exercise any of these rights, please contact Mr C Cunnah at

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.

Privacy Notice

THREEWAYS GROUP (Threeways Garage Limited, Threeways Service Station (Abergele) Limited, Threeways Motorhomes Limited, Easy Clean Car Centre Limited, Threeways Holdings Limited, Threeways Subway Limited.


At Threeways we take your privacy seriously and will only use your personal information for the following purposes, to administer your account and to provide products and services you have requested from us. We will never sell your data on to 3 rd parties. Under the General Data Protection Regulations, which is law from May 2018, we are required to gain your consent to process your personal data and will also request your consent as to the methods we can use to contact you.


Threeways are a group of companies consisting of the following individual companies which are responsible for the processing of your personal information. Our registration numbers with the Information Commissioner’s Office are:-

Z5595689 Threeways Garage Limited

ZA286261 Threeways Service Station Limited

ZA286255 Threeways Motorhomes Limited

ZA286269 Easy Clean Car Centre Limited

ZA286278 Threeways Holdings Limited

ZA286287 Threeways Subway Limited

We are a privately owned company based at Faenol Avenue, Abergele, Conwy, LL22 7HT.


The personal data you have provided, we have collected or have received from 3rd parties may include but are not limited to:

- Name, address and address history, date of birth, gender, marital status, contact details including telephone and email address.

- Financial information, including credit/debit card details (this is not retained in electronic format and is securely held and destroyed in conjunction with all PCI DSS compliance).

- Employment details, criminal convictions and any relevant medical information in relation to driving of demonstrator, hire or company vehicles.

- Registration and vehicle details (past and present).

- If you contact us through any digital channel, we may collect IP addresses and cookie information for fraud prevention and to improve customer experience.


We may contact you as advised by Hyundai, Suzuki, Fiat, Isuzu (International Motors), Swift, Autotrail, Trigano and our other suppliers (a full listing can be found via the link at the foot of this notice) to ensure the ongoing safety and care of your vehicle, products and any related policies. We will register your vehicle keeper details and will cross check your data with DVLA to ensure accurate and timely communications can be made.


We may contact via post, e-mail, telephone and text message, for essential work such as reminders of MOT and services. We check driver and vehicle profiles including drive time to our dealership, vehicle age and type of work due to help prioritise customer contact.

If you benefit from our products and services, we may share your personal data with a number of companies in relation to that product and service (as applicable) in order for it to be maintained. These companies may also act as data controllers with respect to the data you provide to us. The data compiled is from various sources (a full list can be found below) to deliver a more personalised experience for you. You may opt out of any form of marketing by expressing your wish to do so when we check or collect your personal information or by contacting our data protection officer below.

When you visit our website we will use Cookies on your browser. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. We may track your interactions with Threeways via email and text activity and record phone calls for quality and training purposes. For further information please visit or


If you should apply for finance from us the information you provide specifically for this purpose will be disclosed to various finance providers for the purpose of considering the application. The finance companies may use this information to carry out searches with credit reference agencies and other regulatory and statutory bodies. A record of those searches will be kept and may be used by other lenders in assessing applications from you and members of your household for credit in the future. The finance companies will crosscheck this information with other lenders to prevent fraud and may use this information for statistical or marketing purposes. The finance companies may use credit scoring as part of their decision making process. In some cases, the information provided on this form may be disclosed to a Credit Reference Agency, such as Experian or Equifax. Credit reference agencies may also use this information to carry out further searches for other regulatory and statutory bodies. They may also disclose information to other companies and the finance providers may use such information to advise you of any of our or their services or of another person’s services which may be relevant to you. We will on request tell you of the purposes for which we will use this information.


We operate CCTV across the site in order maintain security of all buildings, vehicles, property, employees and customers. This is stored for a period of 1-3months. This is not used for any other purposes and is not located in personal or sensitive areas e.g toilets.

We do not share any footage with any 3rd parties and it is only available to the authorities subject to a request if a criminal activity is being investigated.


All calls inbound and outbound are recorded for training and quality purposes. We will store call recordings for up to 90 days locally and up to 6yrs for via secure cloud based server. We do not share any call records with 3rd parties. We operate a strict policy that only senior line managers have access to view call recording data. All GDPR and data protection is covered by this privacy notice, our employee contracts and our legitimate interest policy statements. Notice for call recording are located within this document, within our Employee Privacy Notice and on our phone auto-attendant and are published on our website.


Except as required by law, we will not use or disclose your personal information for any purpose for which you have not given us your consent or later withdraw your consent. If you withdraw consent, you agree that in spite of this withdrawal we may continue to use the personal information previously provided to us to the extent that we are contractually obligated to do so and to the extent necessary to enforce any contractual obligations you may have for example a finance agreement.


We retain your details for as long as we have evidence that you still own the vehicle, products or policies we sold to you or worked on unless you ask us to delete these details sooner. We take steps to ensure that any business that we work with have security protocols and policies in place to manage and record your data privacy and preferences correctly and that your data is stored securely. The security of your data is paramount. Documentation can be supplied on request from our Data Protection Officer details of whom can be found below.


In the Data Protection Act 1998 and under the General Data Protection Regulations, you have the right to:

- Access to and request copies of your personal data

- Rectification of your data

- Erasure of your data

- Object to us or restrict the processing of your data and where our systems allow, give electronic access to copies of your data in a digital format.

Threeways reserves the right to update or amend this data privacy notice in line with customer feedback or updates in legislation and it will be published at and A full listing of our manufacturers and nominated suppliers, who we may share your information with, is available on request to


Address: Data Protection Enquiry, Threeways Garage, Faenol Avenue, Abergele, Conwy, LL22 7HT


If we are unable to resolve any issues you raise within 30 days you have you have the right to complain to the Information Commissioners Office @

Threeways Garage Limited is an appointed representative of ITC Compliance Limited which is authorised and regulated by the Financial Conduct Authority (their registration number is 313486). Permitted activities include advising on and arranging general insurance contracts and acting as a credit broker not a lender.

We can introduce you to a limited number of finance providers. We do not charge fees for our Consumer Credit services. We typically receive a payment(s) or other benefits from finance providers should you decide to enter into an agreement with them, typically either a fixed fee or a fixed percentage of the amount you borrow. The payment we receive may vary between finance providers and product types. The payment received does not impact the finance rate offered.

All finance applications are subject to status, terms and conditions apply, UK residents only, 18’s or over, Guarantees may be required.