Processing, Personal Data and Data Subjects
The CB System collects data, which includes Personal Data, from vehicles or mobile devices belonging to Customers that have been fitted with CB Tracking Units or through CB Mobile Apps that have been downloaded. For the purposes of the GDPR the Customer is the data controller and CB is the data processor. Data becomes Personal Data when the user of the vehicle or the Mobile Device about which the data is collected can be identified in some way, for example where a driver ID module is fitted within the vehicle and it identifies the driver of the vehicle. Data collected from a Mobile Device is invariably Personal Data as the user of the Mobile Device is generally known.
At the request of the Customer, pursuant to the Agreement, CB stores the data collected on its secure servers but does not process the data in any other way except to archive it after a period of time and to delete it either at the request of the Customer or at the expiry of the Agreement. The Customer can access the data on-line via a secure password protected web portal and can view it in real time, download it or prepare reports. CB has no active role in this other than to provide the System. CB has no control over how the data is used by the Customer.
The purpose of the processing is to record the data and to provide a web portal for the Customer to access the data on-line for use in connection with its business. The Customer can use the data to improve the efficiency of its business by’ for example’ checking the real time locations of its assets/employees. It can use the data to modify driver behaviour to ensure the health and safety of the driver and others and to reduce emissions and improve fuel consumption. There are many ways that a Customer can use the data in connection with its business. It is up to the Customer to comply with the GDPR as a data controller in relation to its employees and others who may be affected.
The processing is for the duration of the Agreement with the Customer or until the Customer requests that the data is deleted. Normally CB takes no part in this process other than to delete the data either at the request of the Customer or in accordance with the Terms and Conditions after the expiry of the Agreement.
The type of Personal Data we will process fall into the following categories by CB solutions:
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