PRINCIPLES OF PERSONAL DATA PROTECTION WHEN OPERATING A DRIVING SCHOOL

 

With this document, we provide you with information on how the company Dopravní podnik města Hradce Králové, a.s. (hereinafter referred to as "DT") obtains and processes your personal data in connection with the operation of a driving school and related activities.

When processing personal data, we are governed by legal regulations, in particular Regulation of the European Parliament and of the Council of the EU 2016/679 of 27.4.2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the "EU Regulation"), which comes into effect on 25.5.2018.

This document will be updated periodically when the need arises for updating. The updated version of the Privacy Policy (hereinafter referred to as the "Policy") is effective upon publication on the www.dpmhk.cz website.

We protect your personal data to the maximum extent possible, which corresponds to the technical level of available means. Strict internal rules apply in DT determining which employees may have access to your personal data and to what extent they may process it, while access rights are narrowed down to the necessary minimum.

We encourage you to read this information carefully. We have done our best to make them as understandable as possible. If something is still not clear to you, we will be happy to explain any concept or passage to you. If you have any questions, please contact the contact person listed in section 1.2. below.

1. CONTROLLER OF YOUR DATA

The controller of your personal data is:

Dopravní podnik města Hradce Králové, a.s ., IČO: 25267213, registered office: Pouchovská 153/52, Věkoše, 500 03 Hradec Králové, registered in the Commercial Register kept by the Regional Court in Hradec Králové, Section B, File 1625.

Contact person and Data Protection Officer: GDPR Hradec s.r.o.,

with registered office: Fráni Šrámka 1139, 500 02 Hradec Králové, IČ: 06708218, contact person: Mgr. Jitka Moníková, e-mail: info@gdprhradec.cz, tel.: +420 495 510 765.

The Controller collects your data, disposes of it and is responsible for its proper and lawful processing. You may exercise your rights against the controller in the manner set out below.

2. PROCESSED DATA, THEIR PURPOSE AND REASON

We process only such data so that we can provide you with quality services related to the operation of a driving school. We process your personal data in the following processing methods and for the purposes listed below:

2.1. Admission to teaching and training and conduct of training

2.1.1. The BASIC (MANDATORY) data that we process about you for the purposes of the Application for Admission to Teaching and Training includes those that you provide to us in one of the following ways:

  • by completing the Application for Admission to Teaching and Training

Specifically, we process the following types of personal data of the applicant:

  • driving licence number,
  • name, surname and title,
  • date and place of birth,
  • birth number,
  • nationality
  • proof of identity,
  • phone
  • home address,
  • the signature of the applicant,
  • signature of the legal representative (if the applicant is not legally competent).

These data are part of each Application for admission to teaching and training, and are so required by the administrative authorities for the purpose of obtaining a driving license.

Reason (legal basis) why we process the data:

- performance of the concluded contract (we use this reason in accordance with Article 6 (1) (b) of the EU Regulation).

2.1.2. When providing driving school services, i.e. during the teaching and training of applicants for a driving license, the following OPERATING DATA are further processed:

  • name and surname,
  • date of birth
  • address
  • phone.

These data are listed in the class register of teaching and training of applicants for a driving licence and are thus required by the administrative authorities for the purpose of obtaining a driving licence.

Reason (legal basis) why we process the data:

- performance of the concluded contract (we use this reason in accordance with Article 6 (1) (b) of the EU Regulation).

2.2. Training for obtaining a professional card

2.2.1. The BASIC (MANDATORY) data that we process about you for the purposes of the Application for Initial Training for obtaining a Professional Card and the Application for the Professional Competence Examination include those that you provide to us in one of the following ways:

  • by completing the Application for Initial Training for obtaining a professional card
  • by completing the Application for the Professional Competence Examination

Specifically, we process the following types of personal data of the applicant:

  • driving licence number,
  • name, surname and title,
  • date and place of birth,
  • birth number,
  • residence addresses,
  • nationality
  • proof of identity,
  • phone
  • the signature of the applicant.

These data are part of each Application for Initial Training for obtaining a professional card and the Application for the Examination for Professional Competence, and are thus required by the administrative authorities for the purpose of obtaining a professional licence (card).

Reason (legal basis) why we process the data:

- performance of the concluded contract (we use this reason in accordance with Article 6 (1) (b) of the EU Regulation).

2.2.2. When providing driving school services, i.e. during the teaching and training of applicants for obtaining a professional license, the following OPERATING DATA are further processed:

  • name and surname,
  • date of birth
  • address
  • phone.

These data are listed in the class register of teaching and training of applicants for a driving licence and are thus required by the administrative authorities for the purpose of obtaining a professional licence (licence).

Reason (legal basis) why we process the data:

- performance of the concluded contract (we use this reason in accordance with Article 6 (1) (b) of the EU Regulation).

2.3. Training of professional drivers

2.3.1. The BASIC (MANDATORY) data we process about you for the training of drivers who hold a driving license and professional competence license includes the following personal data:

  • name and surname,
  • date of birth
  • card number,
  • address
  • signature.

These data are part of the training requirement for professional drivers and are so required by the administration.

Reason (legal basis) why we process the data:

- performance of the concluded contract (we use this reason in accordance with Article 6 (1) (b) of the EU Regulation).

2.3.2. When providing driving school services, i.e. during the teaching and training of applicants for a driving license, the following OPERATING DATA are further processed:

  • name and surname,
  • date of birth
  • address
  • phone.

These data are listed in the class register of teaching and training of applicants for driving licences and are so required by the administrative authorities.

Reason (legal basis) why we process the data:

- performance of the concluded contract (we use this reason in accordance with Article 6 (1) (b) of the EU Regulation).

2.4. Performance of the contract in the provision of driving school services – processing of other personal data

2.4.1. Data from mutual communication

We also process data on our mutual communication related to the provision of driving school services, such as when dealing with your comments or when handling complaints, etc. In this communication, we process the following personal data that you provide to us:

  • name and surname,
  • the address of the complainant,
  • provided contact (e-mail or telephone).

Reason (legal basis) why we process the data:

- when dealing with complaints and claims, these are acts related to the performance of the concluded contract (we use this reason in accordance with Article 6 (1) (b) of the EU Regulation);

2.4.2. Accounting and Taxes

We collect your identification and transaction data (in particular on monetary payments made, on canceled payments, on any refunds in the case of justified complaints) for the purpose of fulfilling our accounting and tax obligations imposed on us by applicable legislation (in particular the Accounting Act, the Value Added Tax Act, the Payment System Act).

These are the data that are listed on tax documents. Therefore, if a legal regulation obliges us to archive these documents, we also store your personal data, which must be stated on the documents.

Reason (legal basis) why we process the data:

- fulfillment of legal obligations (we use this reason in accordance with Article 6 (1) (c) of the EU Regulation).

2.4.3. Exercise (or defence) of rights

Should a dispute arise between the DT and you, we will process your personal data necessary to defend our legal claims in connection with the dispute until the end of the dispute. As a rule, in this context, we process the passenger's basic data, data on payments made, data from complaint proceedings, data from mutual communication, data on legal steps taken and its results.

Reason (legal basis) why we process the data:

- the processing is necessary for the legitimate interests of our company in defending our claims (we use this reason in accordance with Article 6 (1) (f) of the EU Regulation).

3. HOW LONG DO WE KEEP YOUR DATA?

We process personal data for the minimum period for which we are obliged to process personal data.

We process the personal data of applicants/drivers (see Articles 2.1 to 2.3 of this Policy) in our electronic database (and some documents such as the class register and complaints, also in paper form) for the duration of the contractual relationship that is the reason for the processing of such personal data.

Tax documents will be deleted within 1 month after 5 years from the monetary transaction, unless a longer period is required by law in a particular case.

Should a dispute arise between the DT and you, we will process your personal data necessary to defend our legal claims in connection with the dispute until the end of the dispute.

4. SOURCES OF PERSONAL DATA

We only process personal data that we have received from you or obtained when communicating with you. We do not search for and process personal data about you from public sources.

5. RECIPIENTS OF PERSONAL DATA

In principle, we manage your personal data within the DT and do not pass them on to third parties, unless it is necessary when it is necessary when transferring personal data to the Municipality of Hradec Králové within its public administration.

Some state administration bodies are entitled to request ad hoc information about you in order to fulfil their legal obligations (e.g. the Police of the Czech Republic, financial control authorities, the SAO). We only provide data if the right to request such data is required by law.

6. WHAT ARE YOUR RIGHTS?

Right of access to personal data

You have the right to access all processed personal data. At your request, we will provide a copy of the processed personal data in a machine-readable format.

Right to rectification of personal data

You have the right to have changed personal data corrected (or incorrectly disclosed data for any other reason). We will correct the changed data (e.g. from a new identity document).

Right to erasure of personal data

You have the right to erasure of your personal data that we would process unlawfully.

Right to restrict the processing of personal data

You have the right to block your personal data under the conditions set out in Article 18 of the EU Regulation (especially if an objection is raised, there is a dispute about the legitimacy of data processing).

Right to data portability

You have the right to obtain from us providing you with automated personal data in a structured, commonly used and machine-readable format, or to transfer this data to another controller, if technically feasible.

Right to withdraw consent

If you have given us your consent to process your personal data for specified purposes, you have the right to withdraw this consent at any time.

Right not to be subject to automated decision-making

You have the right not to be subject to any decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you. The DP does not carry out any such automated decision-making or profiling.

Right to object

You have the right to object if the processing is based on our legitimate interest (defence of legal claims).

Right to lodge a complaint

You have the right to address your complaint to the DT at any time, or to file a complaint with the Office for Personal Data Protection, address: registered office at Pplk. Sochora 27, 170 00 Prague 7 or to request judicial protection.

How to exercise rights

To exercise your rights listed above, please contact our Data Protection Officer – see point 1 of this Policy or you can exercise these rights in person when visiting DT. To exercise your rights, you can use the forms prepared by us located at www. dpmhk.cz in the section Personal Data Protection - here you will find a more detailed explanation of the conditions for exercising the right for each right.

We are obliged to inform you free of charge of the measures taken without undue delay and in any case within one month of receipt of the request. That period may be extended by a further two months, if necessary, taking into account the complexity and number of requests. If we do not comply with your request, we will inform you immediately (at the latest within one month) of the reasons for the non-compliance.

In some cases defined by legislation, we are not obliged to comply with the request in whole or in part. This will be the case, in particular, where the request is manifestly unfounded or excessive, in particular because it is repeated. In such cases, we may: (i) impose a reasonable fee taking into account administrative costs or (ii) refuse to comply with the request.

If we receive a request but have reasonable doubts about the identity of the sender of the request, we may ask you to provide additional information necessary to confirm your identity.