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Supplemental Privacy Policy

Supplemental Privacy Notice to Prospective and Current Electric Vehicle Leasing and Rental Customers

This Supplemental Privacy Notice supplements DriveElectric’s existing Privacy Policy (which can be found here) and provides an explanation of the processing undertaken by DriveElectric when it shares personal data within the UK energy network companies as part of a trial intended to enable parties within the UK energy network to modernise EV infrastructure (known as ‘Project Skyline’).

When you:

  • make an enquiry for leasing or rental of an electric vehicle or related equipment (the EV Provider) regarding an Electric Vehicle (EV) or EV related equipment such as charge points; and/or
  • lease or purchase an EV or EV related equipment from the EV Provider; and/or
  • make use of an EV charging point in your local area,

the EV Provider may then share certain information with CrowdCharge.

CrowdCharge is a limited company registered in England under company number 08585146 and, for the purposes of this Supplemental Privacy Notice along with the EV Providers, acts as a data controller.  References to “we“, “our” or “us” also means CrowdCharge.

1. What personal data is shared with CrowdCharge?

The following is a list of the categories of information which are collected by the EV Provider (if relevant) and shared with CrowdCharge:

  • your address and postcode;
  • the make and model of the EV (including where it was assembled);
  • the stage of your customer journey (e.g. whether you have made an enquiry to an EV Provider, received a quote or made an order to purchase an EV);
  • the dates of the order/purchase/delivery;
  • the location data of an EV or EV charging point;
  • maximum EV charging demand data of an EV or EV charging point;
  • full type (EV/PHEV) and vehicle make and model;
  • existing payload demands on the property (e.g. heating type).

The EV Provider does not share any sensitive information (e.g. health data, information about religious or philosophical beliefs, ethnicity or race, criminal offence data etc.) about an individual which would be classified under the data protection law as “special category data”.

2. Why is your personal data being shared?

EVs are set to replace traditional vehicles over the next few decades. Global sales of EVs have accelerated in recent months and governmental commitments in the investment of EVs has followed suit.

However, there is currently no existing system in place to alert electricity network operators (who are often collectively referred to as ‘Distribution Network Operators’ or DNOs) as to EV demand in any given area or region within the UK. This means that it becomes harder for DNOs to have the infrastructure in place to ensure sufficient power is delivered to areas where it is needed due to demand for charging EVs.

In order to ensure that DNOs receive accurate and reliable data about likely EV demand, the EV Providers have agreed to share certain information, as part of a five month trial, regarding the potential and actual sales of EVs across the UK to enable the DNOs to prioritise EV infrastructure to those places with greatest demand.

CrowdCharge acts as an intermediary and is responsible for cleaning and de-duplicating the data before it is then shared via a secure data transfer service called Electralink Limited (who combine it with technical data relating to power supply), with the DNOs for analysis.

3. How is the sharing of your personal data lawful?

We set out below how your personal information is used and what the legal basis is for being able to use your personal data in each way.

Legitimate Interest – processing your data is legal if it based on ‘legitimate interests’. To do so, the impact of the processing on your interests and rights has been considered, and have placed appropriate safeguards to ensure that intrusion on your privacy is reduced by as much as possible.

The legitimate interests of the EV Providers, CrowdCharge, Electralink and the DNOs are:

  • to enable accurate and reliable data to be shared within the UK energy networks to enable effective, fast planning and implementation of infrastructure to support the growing EV market. This can only be achieved by permitting CrowdCharge to collect the raw data (including your personal data) from the EV Providers, clean the data and then share it to the DNOs for analysis;
  • to ensure that the implementation of infrastructure by the DNOs is targeted and scalable and that there is enough power being routed from the DNOs to the EV charging points to meet the demand in the system;
  • to enable more consumers to have access to low carbon technologies by ensuring that DNOs are able to respond to demand;
  • to ensure that DNOs are able quickly to identify and respond to problems; and
  • to deliver costs savings to consumers by ensuring that a customer is not charged at the outset for largescale infrastructure projects which are not yet required.

4. Who will have access to your personal data?

As part of the trial, your personal information will be shared with the following recipients:

  • Crowd Charge Limited (an English company with company number 08585146);
  • Electralink Limited (an English limited company with company number 03271981); and
  • the electricity DNOs (e.g. Scottish and Southern Electricity Networks, UK Power Networks).

If you would like to know more information as to who will have access to your data, please contact us (see “How to Contact Us” below).

5. How is your data protected?

Appropriate technical and organisational measures will be put in place to safeguard your personal data. These measures are designed to provide a level of security appropriate to the risk of processing your personal information for example: the EV Providers will send your information to CrowdCharge via a secure transfer process.  The information will then be held in an encrypted secure database before it is shared with the DNOs via a secure connection via ElectraLink.  Great care is taken to ensure that access to personal information is limited to only those who require such access to perform their tasks and duties.  For this reason, there is no intention to share personal information with any other persons or parties or used for any other purposes than those described above.  If you would like more information as to your data is secured please contact us (see “How to contact us” below).

For the purposes of this Supplemental Notice, your personal data is not transferred or shared with any entities who are based outside of the UK and/or the European Economic Area (EEA) and all transfers of data between the UK and the EEA will be conducted on the basis of an adequacy decision determined by the appropriate governmental and/or regulatory bodies (from time to time in force).

6. Data retention

We will securely retain your personal data for the longer of the following periods:

  • for the purposes of which the personal data was collected and in any event for no longer than 12 months from the completion of the information sharing trial (referred to in section 2 above); and/or
  • in order to establish or defend legal rights or obligations; and/or
  • to satisfy any industry reporting obligations.

If you have any questions regarding how long your information is retained please contact us (see “How to contact us” below).

7. Your data protection rights

You have certain rights under the data protection laws in respect of your personal data.  These include a right to access your personal data and a right to object to the processing.  You also have a right to complain to the data regulatory in the UK known as the Information Commissioner’s Office (information about how to do this is available on their website: www.ico.org.uk).

For more information and detail in relation to your data protection rights, please refer to our Privacy Policy which is accessible via our website (https://www.drive-electric.co.uk/privacy).

8. How to contact us

Please email if you have any questions about this Supplemental Privacy Notice or concerns regarding your data please contact your EV Provider and/or CrowdCharge.  To contact your EV Provider, please consult the relevant EV Provider’s privacy policy which can be accessed via the EV Provider’s website or otherwise contact us direct by emailing us atsupport@drive-electric.co.uk.