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Data Portability Procedure


1.          Scope


This procedure applies where a data subject exercises their right to data portability and applies to New Vehicle Solutions Ltd to receive their data in order to reuse or transfer it to other data controllers. 


Data subjects are entitled to ask:

·       For a copy of the personal data they have provided to New Vehicle Solutions Limited

·       For New Vehicle Solutions Limited to transmit the data to another data controller


Within the scope of this procedure is any personal data concerning the data subject that:

·       he/she has provided to the data controller knowingly and actively, or through observations of his/her activities by virtue of the service of New Vehicle Solutions Limited; and

·       has been processed through automated means; and

·       has been processed because of the data subject’s consent or a contract to which the data subject is a party.


This procedure will most commonly be used when transmitting data directly to another data controller.


This procedure also applies to circumstances when New Vehicle Solutions Limited is the receiving data controller.  This is, when personal data from another data controller is received due to the data subject exercising his or her right to data portability. See clause 4 below.


2.          Responsibilities


New Vehicle Solutions Limited is responsible for transmitting the data without hindrance and ensures that it is transmitted with the appropriate level of security. The firm will assess the specific risks linked with data portability and take appropriate risk mitigation measures.


The nominated person of the firm is responsible for the application and effective working of this procedure, and for reporting performance to the Board/Principals.


3.          Procedure


New Vehicle Solutions Limited informs data subjects of the existence of the new right to portability at the time where personal data is obtained.


Any request is immediately forwarded to the nominated person to ensure that the requested data is provided/transmitted within the timeframe noted below.


New Vehicle Solutions Limited will request that the data subject provide evidence of their identity in the form of current Passport or Driving License.


Where the data requested concerns a third party/parties, the nominated person reviews whether or not transmitting data to another data controller would cause harm to the rights and freedoms of other data subjects.


The data subject must make it clear that the personal data that is to be transmitted or provided for their own use.

The person responsible within the firm will maintain a record of requests for data and of its receipt, including dates.


New Vehicle Solutions Limited has set safeguards that ensure the personal data transmitted are only those that the data subject has requested to be transmitted.


The requested information is provided to the data subject in structured, commonly used and machine readable format that allows for the effective re-use of the data.


When transmitting data to another data controller, New Vehicle Solutions Limited will forward the data in an interoperable format. In the event that technical impediments prohibit direct transmission, the firm will explain these impediments to the data subject(s).


New Vehicle Solutions Limited provides the requested information within one month from the request date. If the request is complex, the firm can extend this period to (maximum) three months as long as they inform the data subject of the reasons for the delay via email within one month of the original request. The request does not affect the original retention period that applies to the data that has been transmitted.


4.          Receiving personal data


New Vehicle Solutions Ltd does not by default accept and process personal data received from another data controller following a personal data request nor does it retain all the data received.


New Vehicle Solutions Ltd only accepts and retains data that is necessary and relevant to the service being provided. If data received contains third-party data, the firm will keep the data under the sole control of the requested user.  This data is only managed for their needs and not for other purposes of the firm.


New Vehicle Solutions Ltd provides data subject(s) with information about the personal data relevant for the performance of their services, limiting risks posed to third parties and unnecessary duplication of personal data.

(Data Portability Procedure Last Updated 23/03/2020)

NVS Van Insurance