Privacy Policy

Inclusive Driving is operated by Richard Bates, an Approved Driving Instructor (ADI No. 777357) and sole trader. I am committed to protecting your privacy and handling your personal information fairly, lawfully and transparently. I am registered with the Information Commissioner’s Office (ICO) as a data controller (ZB279567)

This policy explains what information I collect, how it is used, how it is stored, and your rights under UK data protection law.

1. Information I Collect

I may collect and store the following information:

  • Name, address, phone number and email address
  • Date of birth and driving licence details
  • Lesson notes, progress records and test results
  • Payment records (not card details)
  • Information you choose to share about medical conditions or support needs relevant to driving
  • Communications between us (email, text, phone)
  • Dashcam recordings (see Section 7)

2. How Your Data Is Stored

Your data is stored securely using:

  • MyDriveTime, a mobile app and online system used for lesson records, scheduling and payments
  • A password‑protected mobile device
  • Secure cloud storage for emails and documents

I do not store card details.

3. Why I Collect Your Data (Lawful Basis)

I process your data for the following reasons:

Contract

To provide driving tuition, manage bookings, record progress and communicate with you.

Legal obligation

To comply with the Road Traffic Act, insurance requirements, HMRC record‑keeping rules and other legal duties.

Consent

To record any disability‑related information needed to support your learning or to request reasonable adjustments from the DVSA.

Legitimate interests

To manage my diary, improve my service, ensure safety, and maintain accurate business records.

4. Who I Share Your Data With

I only share your information when necessary and for the following purposes:

  1. When required by law, for example, under the Road Traffic Act or when requested by law enforcement.
  2. To book driving tests with the DVSA.
  3. To request reasonable adjustments for theory or practical tests due to disability or medical needs.
  4. With MyDriveTime, which processes data on my behalf for scheduling, payments and lesson records.
  5. With my accountant or HMRC, if required for financial compliance.
  6. With my insurance provider, if needed in relation to an incident or claim.
  7. With other agencies involved in your driving tuition, such as Motability/AA/BSM, Driving Mobility, Regional Driving Assessment Centres, or vehicle adaptations specialists, but only with your explicit consent.
  8. In an emergency, I may share relevant information with medical personnel, emergency services, or other professionals where necessary to protect life or safety.

I do not sell or share your data with any third parties for marketing.

5. How Long I Keep Your Data

  • Lesson and payment records: 6 years (HMRC requirement)
  • Test booking information: until the test is completed
  • Disability‑related information: only for as long as needed to support tuition
  • Communications: as long as reasonably necessary for business purposes

6. Your Rights

You have the right to:

  • Access the data I hold about you
  • Request corrections
  • Request deletion (where legally permitted)
  • Restrict or object to processing
  • Withdraw consent for disability‑related information
  • Request a copy of your data in a portable format

To exercise any of these rights, contact me using the details below.

7. Dashcam Recording

For safety, training, safeguarding and insurance purposes, my vehicle is fitted with a dashcam. The dashcam records video of the road outside the vehicle and audio from inside the vehicle.

What is recorded

  • External video: road conditions, traffic, number plates, pedestrians and other road users
  • Internal audio: conversations between the learner and me, and incidental sounds inside the vehicle

Why recordings are made

Recordings are used for the following purposes:

  1. Safety and incident evidence: To provide accurate information in the event of a collision, complaint or insurance claim.
  2. Legal obligations: To provide information to the police or other authorities when required by law.
  3. Training and reflective practice: To review driving performance and improve the quality of tuition.
  4. Safeguarding and protection against allegations: To protect learners and the instructor from allegations of inappropriate behaviour.
  5. Social media and educational content: I may use dashcam footage for training or educational purposes on platforms such as YouTube. I will only use footage that does not identify the learner, or I will obtain explicit consent before using identifiable footage.

How long recordings are kept

  • External video and internal audio: may be retained for up to 90 days .

Your rights regarding dashcam footage

Learners may request that identifiable footage not be used for social media or training content. This does not affect the use of recordings for safety, legal, safeguarding or insurance purposes.

8. Contact Details

Data Controller: Richard Bates Inclusive Driving

If you have concerns about how your data is handled, you can contact the Information Commissioner’s Office (ICO) at ico.org.uk.