Privacy Policy

Foster Hartley Limited – Transport Management App

Last updated: December 2025

1. Introduction

Foster Hartley Limited ("we", "us", or "our") operates the Foster Hartley Transport Management mobile application (the "App"). This Privacy Policy explains how we collect, use, store, disclose, and protect personal data when you use the App, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

The App is intended solely for professional drivers and fleet management personnel engaged by Foster Hartley Limited. Use of the App is part of your professional duties. Please read this Privacy Policy carefully. If you do not agree with its terms, you must not use the App.

By accessing or using the App, you acknowledge that you have read and understood this Privacy Policy and that your personal data will be processed as described below.

2. Information We Collect

We collect and process only the personal data that is necessary for the operation of the App, fleet management, employment administration, and compliance with legal and regulatory obligations.

2.1 Personal and Employment Information

We may collect the following information directly from you or from your employment records:

Full name and contact details (including email address and telephone number)
Home address and next-of-kin details
Profile photograph
Professional qualifications and credentials, including driving licence category (D or D1), Driver CPC certification details, and expiry dates
Employment-related information, including contract start date, rota start date, and allocated work locations
Digital signatures provided in connection with employment documents, declarations, or acknowledgements

2.2 Location Data

The App collects precise location data where this is necessary for operational and compliance purposes, including:

GPS location data at clock-in and clock-out to verify attendance at allocated sites
Location data captured during vehicle walkaround checks and inspections
Location pinning when recording fuel log entries
Movement and positional data during walkaround inspections to support compliance monitoring

Location data is collected only during active use of relevant App functions and is not used for continuous personal tracking outside those functions.

2.3 Device, Motion, and Sensor Data

To ensure vehicle safety compliance and integrity of inspections, the App may collect:

Motion and movement data (such as accelerometer and compass data) during walkaround checks
Time and duration data relating to safety inspections
Limited device information necessary for App functionality, security, and fraud prevention

Important notice: Walkaround inspection timing and movement data may be disclosed to the Driver and Vehicle Standards Agency (DVSA) upon lawful request to demonstrate compliance with vehicle safety inspection requirements.

2.4 Camera, Photographs, and Video

The App requires access to the device camera in order to capture live media for compliance and audit purposes, including:

Live photographs of vehicle oil dipstick checks during walkaround inspections
Live photographs or video of identified vehicle defects
Live photographs of vehicles at fuel stations
Live photographs of fuel receipts
Random photo or video verification responses during walkaround inspection questions

All photographs and videos must be captured live through the App. Uploading existing images or videos from device storage is not permitted. This measure is implemented to ensure authenticity, accuracy, and regulatory compliance.

2.5 Work, Duty, and Operational Data

We collect operational data necessary for transport management, payroll, and regulatory compliance, including:

Clock-in and clock-out records
Duty start and end times
Vehicle selection and allocation records
Vehicle registration numbers and mileage readings (start and end)
Driving hours, other duty hours, and rest or break periods
Walkaround check results and vehicle defect reports
Service Unit (SU) transport data, including routes, locations, directions, and passenger counts
Fuel log data, including cost, quantity (litres), and fuel card usage
Working rotas and schedule information
Holiday requests, sickness absence, and other leave records
Driver CPC module completion records and training history

3. How We Use Your Information

We use personal data for the following purposes, where necessary and proportionate:

To provide, operate, and maintain the core functionality of the App
To verify driver identity, qualifications, and employment status
To comply with DVSA requirements, transport safety standards, and operator licence obligations
To manage work schedules, rotas, and duty assignments
To monitor working time and generate duty records for legal compliance
To allocate vehicles and manage fleet operations
To record, verify, and audit vehicle safety inspections
To monitor fuel usage and associated costs
To manage vehicle maintenance through defect reporting
To administer holiday requests, sickness absence, and other leave
To maintain training records and Driver CPC compliance
To facilitate operational communication between drivers and management
To calculate working hours and remuneration for payroll purposes
To provide access to the App's knowledge library and AI-powered search functionality

4. Disclosure of Personal Data

We may share personal data only where necessary and lawful, as set out below.

4.1 Regulatory Authorities

We may disclose walkaround inspection records, including timing, movement data, images, and inspection outcomes, to the Driver and Vehicle Standards Agency (DVSA) or other competent authorities where required or permitted by law.

4.2 Internal Access

Personal data is accessible only to authorised employees and contractors of Foster Hartley Limited, including administrators, managers, and mechanics, where access is necessary to perform their roles (for example, managing schedules, approving changes, processing defect reports, and overseeing fleet compliance).

4.3 Legal and Statutory Disclosure

We may disclose personal data where required to do so by law, court order, or in response to valid requests from public authorities or regulators.

4.4 Service Providers

We may share personal data with trusted third-party service providers who support the operation of the App, such as cloud hosting, secure data storage, and technical support services. All such providers are subject to contractual obligations to process data only on our instructions and to maintain appropriate security measures.

5. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Employment-related records, including duty logs, vehicle inspection records, and compliance documentation, are retained in accordance with UK employment law, operator licensing requirements, and transport regulations. Following termination of employment, certain records will be retained for statutory or regulatory purposes and securely deleted thereafter.

6. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure. These measures include encrypted data transmission, secure authentication processes, and role-based access controls.

While we take reasonable steps to safeguard personal data, no electronic transmission or storage system can be guaranteed to be completely secure.

7. Your Data Protection Rights

Under UK GDPR, you have the following rights, subject to legal limitations:

Right of access: to request a copy of your personal data
Right to rectification: to request correction of inaccurate or incomplete data (note that profile amendments within the App may require administrative approval)
Right to erasure: to request deletion of your personal data, where no legal retention obligation applies
Right to restrict processing: to request limitation of how your data is processed
Right to data portability: to request transfer of your data to another organisation
Right to object: to object to certain types of processing, where applicable

Requests to exercise these rights should be submitted using the contact details set out below.

8. App Permissions

The App requires the following permissions in order to function correctly:

Precise location: to verify attendance at allocated sites, support inspections, and record fuel locations
Camera: to capture live images and videos for inspections, defect reporting, fuel logging, and compliance checks
Motion sensors: to verify movement during walkaround inspections
Storage: to temporarily store captured media prior to secure upload
Internet access: to synchronise data with company systems and receive updates
Notifications: to provide alerts regarding outstanding tasks, messages, and system updates

Permissions are used only for their stated purposes.

9. Children's Privacy

The App is intended solely for use by individuals aged 18 or over. We do not knowingly collect personal data relating to children. If you believe that a minor has provided personal data through the App, please contact us immediately.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be published within the App and the "Last updated" date will be revised accordingly. Continued use of the App after an update constitutes acceptance of the revised Privacy Policy.

11. Contact Details

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:

Foster Hartley Limited

Email: [email protected]

Telephone: 0333 188 7066

Address: Foster Hartley Limited, c/o Hamilton Black Accountant, Trust House, 5 New Augustus Street, Bradford, England, BD1 5LL

12. Legal Basis for Processing

We process personal data on the following lawful bases under UK GDPR:

Contract (Article 6(1)(b)): where processing is necessary for the performance of your employment contract or to take steps at your request prior to entering into such a contract.
Legal obligation (Article 6(1)(c)): where processing is required to comply with DVSA requirements, operator licensing conditions, road traffic legislation, and UK employment law.
Legitimate interests (Article 6(1)(f)): where processing is necessary for the legitimate interests of Foster Hartley Limited in managing fleet operations, ensuring driver and public safety, preventing fraud or misuse of systems, and demonstrating ongoing regulatory compliance, provided that such interests are not overridden by your rights and freedoms.

Where special category data is processed (for example, limited health-related absence information), such processing is carried out only where necessary and permitted under Schedule 1 of the Data Protection Act 2018.

13. Regulatory and Traffic Commissioner Compliance Statement

This App forms part of Foster Hartley Limited's operator licence compliance systems. Data collected through the App is used to demonstrate effective management control, continuous compliance, and adherence to undertakings given to the Traffic Commissioner.

In particular:

Walkaround check data, inspection duration, movement verification, images, and defect reports are used to evidence that daily safety inspections are carried out properly, thoroughly, and in accordance with DVSA guidance.
Duty, driving time, and break records are used to demonstrate compliance with drivers' hours, working time, and rest requirements.
Vehicle allocation, mileage, and defect data are used to support preventative maintenance systems and timely rectification of defects.

Records generated by the App may be produced to the Traffic Commissioner, DVSA, or other competent authorities as part of audits, investigations, public inquiries, or compliance reviews.

14. Employee Privacy Notice (Summary)

This summary is provided for convenience and does not replace the full Privacy Policy above.

Who we are

Foster Hartley Limited is the data controller responsible for your personal data.

Why we collect your data

We collect and use your data to manage transport operations, comply with DVSA and operator licence requirements, ensure vehicle and public safety, administer your employment, and pay you correctly.

What data we collect

This includes identity and contact details, driving qualifications, work schedules, duty and driving hours, vehicle inspection records, location data during work activities, photographs and videos taken during inspections, and payroll-related information.

How your data is used

Your data is used to allocate work, record duties, evidence safety checks, manage vehicles, monitor compliance, process pay and leave, and respond to regulatory requests.

Who your data is shared with

Your data may be shared internally with authorised staff and externally with regulators such as DVSA where required by law. We also use approved service providers who support our systems under strict confidentiality obligations.

How long we keep your data

We keep your data only for as long as required by law or regulatory guidance. Some records must be retained after employment ends.

Your rights

You have rights to access your data, request corrections, object to certain processing, and request deletion where legally permitted.

Contact

For questions or to exercise your rights, contact: [email protected]

By using the Foster Hartley Limited Transport Management App, you acknowledge that you have read, understood, and accepted this Privacy Policy and Employee Privacy Notice.