Privacy Notice for Drivers using Mentor by eDriving

Privacy Notice for drivers using Mentor by eDriving

*Your Company means your employer or the company that you provide driving or delivery services to.

General introduction

Welcome to your Company* Global Driver Safety Program, which supports the fundamental objective of “Drivers around the world returning home safely at the end of each day to their loved ones and communities”.

Please read this Privacy Notice carefully because it outlines how your personal information will be processed by eDriving in the provision of services to support the Global Driver Safety Program. This site is owned and operated by eDriving LLC. Your Company has engaged eDriving LLC to provide individual tools including eLearning and coaching to people who drive for work, to support their progress towards becoming safer drivers, via Mentor by eDrivingsm Application (Mentor Application/App).  The Driver Global Safety Program is fully supported by your Company’s management as part of their efforts to improve the safety of drivers.

Please click on the sections below for more information about how eDriving protects your personal information and privacy.

Mentor App

The Mentor Application supplements your Company’s current systems and processes, to protect the safety and well-being of drivers by providing a comprehensive and sustainable digital driver safety management system, to ensure that best practice elements and efficiencies are applied on a consistent basis. The Mentor Application is a behaviour-based telematics solution designed to help drivers become more aware of their at-risk driving behaviours and then change those habits. Mentor will be implemented in compliance with all applicable laws and your Company’s policies.

Data Controller and Authorised Data Processors

  • Your Company is the Controller of your personal information and decides what information we can process.
  • Mentor by eDriving App: eDriving is the Data Processor and are authorised to process your data ONLY as described in this notice and only on the instructions of your Company

What personal information do we collect about you?

For the purpose of this Privacy Notice, the term ‘personal information’ includes:

Information collected by Mentor by eDriving App

  1. Your work contact information – name, country, email address, business location.
  2. eLearning module completion date(s)
  3. FICO Safe Driving Score and other related driving behavior data and analytics gathered from Mentor by eDrivingsm. The Mentor app measures the following ABCDS events for all shifts/trips:
    • Harsh Acceleration, Braking and Cornering (ABC events)
    • Distraction events (defined by phone movement or interaction whilst driving) (D events)
    • Speed versus posted Speed Limit (where available) and a general overspeed event whereby a driver exceeds 79.9mph/128.6kph (S events)
    • The above information is processed to derive an overall shift/trip Risk Rating from Very Low Risk (★★★★★) to Very High Risk (★) after every shift/trip, and a rolling 7-day average of shift/trip risk scores.
    • Location data – not shared with anyone except you, the driver. Shift/trip data is deleted after 12 months.

Mentor will provide you with feedback after every shift/trip and will provide a Risk Score for shifts/ trips designated as “Driver” on a rolling 7-day average, including:

  • Accumulated Hours/Kms/Miles Driven & Number of shifts/trips
  • Driver Safety Score versus Benchmark Scores which consist of the scores from your “Team”, “Organization,” and “Top 10% of drivers”
  • Detailed breakdown of all recorded events for past 30 shifts/trips with access to map showing location and breakdown of recorded events (Driver view only)
  • Coaching playlist with short eLearning training modules (can also be taken online)
  • Multi-week trending charts of Scores

How do we obtain your personal information?

Mentor by eDriving App

Your Company will share your personal information with eDriving on a need-to-know basis, and to the extent necessary to comply with all laws and regulations, for the purposes of:

  • providing Mentor service and registering you to use it
  • monitoring the use of the service
  • providing you, your Company, and eDriving with information relating to driver risk
  • to identify improvements and changes that can be made to lower the risk of driving and improve safety
  • identifying which drivers have successfully completed all required assigned elements.

We will only use your personal information for:

  • The purposes we describe in the General Introduction in this Privacy Notice, or for purposes which are reasonably compatible to the ones described. We cannot, and will not, use it for other purposes without your permission, unless we have a legal obligation to do so and only upon instruction from your Company.
  • Responding to and dealing with your queries or requests related to the e Driving application.
  • To internally analyze trends and insights – only when data has been fully anonymized and irreversibly stripped of all identifiers.

The Mentor platform enables your Company to assess driver safety performance as well as identify training needs. In addition to you (the driver), limited people in your Company may be authorized to access your “nongeolocation” Mentor performance, such as average risk ratings, number of shifts/trips while driving for work, 7-day score vs benchmark, aggregated categories, coaching completion status and % of shifts/trips as driver.  Your company will not have access to your trips or location information.

How long do we keep your personal information?

Mentor by eDriving Application

Except for shift/trip data, your personal information will be stored only for as long as (i) is required by the contractual terms of your Company’s agreement with eDriving and in line with their data retention policy; or (ii) required by applicable law. We will also keep your personal information where we need to do so in connection with legal action or an investigation involving your Company. Shift/trip data is deleted after 12 months.

How do we protect your personal information?

We want to make sure your personal information is not shared with or used by those not allowed to see it. We use a variety of security measures and technologies to help protect your personal information.  We carefully choose service providers to work with, and check they have security measures and technologies in place to protect your personal information. We do not allow our service providers and suppliers to use your personal information for their own purposes.

We take all reasonable steps to protect personal information and to prevent such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, in accordance with legal requirements, including:

  • All Personal Data is encrypted in transit and at rest (minimum 256-bit encryption)
  • Access to Driver HQ and Company MIS is via HTTPS only
  • eDriving Data centres are in the EU and have:
    • multiple levels of physical security including CCTV, restricted access, locked cabinets
    • strict employee procedures regarding data protection (staff vetting, training)
    • dedicated ‘High Availability’ servers unique to eDriving
    • 24/7 Monitoring and intrusion detection in place
    • regular scheduled security testing
    • ISO/IEC 27001 certification in Information Security which is regularly audited (both internally and by 3rd parties).

Your responsibilities

Mentor by eDriving Application

Your participation in this program ensures your full understanding of your Company’s driver safety policies and requirements. As an authorized driver, you are entrusted to drive in a safe and responsible manner in accordance with all applicable local laws and Company policies.

You will download the Mentor app securely from the Apple or Android App Stores onto your corporate or privately-owned mobile phone. The Mentor app must ALWAYS remain loaded on the mobile phone on which the Mentor app is permitted to operate.  The location services must be ON for the app to function. The App only begins collecting driving information when the raw sensors detect driving motion.

It is your responsibility to comply with all applicable laws (including traffic laws) while using the Mentor app.

If your Monthly FICO® Safe Driving Score falls below 710 and/or you are involved in a collision, regardless of blame, you may start to have a regular (monthly) Road Safety Review with your Company until your score returns to greater than 710 for 3 consecutive months.

You must designate shifts/trips that are “Personal” or “Passenger” in the Mentor app to exclude them from your FICO Safe Driving Score.

Changes to this privacy policy

This Privacy Notice may change from time to time.  This notice was last updated on 29 October 2021.

On what legal basis do we use your personal information?

Data privacy law sets out the legal basis for which a company may collect and use your personal information. Please read the section below that is relevant to your country or region.

Risk reduction strategies and risk improvements – no personal information used; anonymous only

The Mentor Application will also be used to facilitate research on the effectiveness of the Global Driver Safety Program, and to develop and improve risk reduction strategies. The information used for research purposes will be anonymized by eDriving before it is entrusted to any other entity or used in connection with any research-related purpose.  This means it will be de-identified – fully and irreversibly stripped of all identifiers that can be attributed back to a specific individual. The research-related purposes for which such data may be used are limited to improving drivers’ safety and the effectiveness of the Global Driver Safety Program and will not be used for any other purpose.  Your data will not be sold, shared, or entrusted to any organization, in anonymized or identifiable form, for any purpose not specifically addressed in this notice. Organizations used for such research will be limited to authorized vendors and governmental agencies that are involved in occupational safety research.

Mentor by eDriving Application

  • To comply with your Company’s legal obligations: Every organization has a duty to protect the health, safety and welfare of their drivers and other people who might be affected by their business. Your Company must do whatever is reasonably practicable to achieve this. Processing your personal information for the purposes of providing driver safety education helps achieve the legal obligations in this respect.
  • Your Company has a legitimate interest to process the data:Your Company will use your personal information to ensure we provide the necessary guidance and training to drivers, in the interests of their personal safety and safety of others, and to appropriately manage risk within the business.

The countries to which your personal information may be sent or processed

eDriving will process your personal information in the UK and EU.  In some cases, US citizen driver data is stored in the US only.  Check with your Company for details.  Your pseudonymized personal information will be processed in the US. This means that your personal information will be removed, and the data will be assigned a random ID.  This is to allow for FICO Safe Driving Score scoring in an unidentifiable format.

eDriving has implemented appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws. These measures include data transfer agreements implementing standard data protection clauses and additional measures.

Your rights – EU, EEA, Andorra, Monaco, San Marino, Switzerland, UK

Your rights regarding your personal information

You have rights we need to make you aware of. The rights available to you depend on our reason for processing your personal information and the local law in your jurisdiction. Depending on this you may have the right to:

  • Ask us for copies of your personal information. There are some exceptions, which means you may not always receive all the information we process;
  • Ask us to correct information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
  • Ask us to delete your personal information;
  • Ask us to restrict the processing of your information;
  • Object to our processing of your personal information;
  • Ask that we transfer information you have given us from one organisation to another, or to give it to you.

For your protection, and to protect the privacy of others, we may need to verify your identity before completing what you have asked us to do.

If you would like to exercise your rights or have questions regarding the processing of your personal information, or you require additional information, please contact the eDriving privacy team via privacy@edriving.com or send us a request via our secure web form. For your protection, and to protect the privacy of others, we may need to verify your identity before completing what you have asked us to do

You have the right to lodge a complaint with your local data protection authority if you feel we have not addressed your request in accordance with applicable data protection law.

In the EU/EEA, to find your local authority, you can check the list on the European Data Protection Board website.
In the UK, you can contact the Information Commissioner’s Office. Home | ICO
In Andorra, you can contact the Andorran data protection Authority. Home | APDA
In Monaco, you can contact the Commission de Contrôle des Informations Nominatives. Accueil (ccin.mc)
In San Marino, you can contact the Guarantor for the Protection of Personal Data. Autorità Garante per la Protezione dei Dati Personali (garanteprivacy.sm)
In Switzerland, you can contact the Federal Data Protection and Information Commissioner FDPIC

Your rights – Canada, USA

Your rights regarding your personal information

You have rights we need to make you aware of. The rights available to you depend on our reason for processing your personal information and the local law in your jurisdiction. Depending on this you may have the right to:

  • Ask us for copies of your personal information. There are some exceptions, which means you may not always receive all the information we process;
  • Ask us to correct information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
  • Ask us to delete your personal information;
  • Ask us to restrict the processing of your information;
  • Object to our processing of your personal information;
  • Ask that we transfer information you have given us from one organization to another, or to give it to you.

For your protection, and to protect the privacy of others, we may need to verify your identity before completing what you have asked us to do.

If you would like to exercise your rights or have questions regarding the processing of your personal information, or you require additional information, please contact the eDriving privacy team via privacy@edriving.com or send us a request via our secure web form. For your protection, and to protect the privacy of others, we may need to verify your identity before completing what you have asked us to do

You have the right to lodge a complaint with your local data protection authority if you feel we have not addressed your request in accordance with applicable data protection law.  Regardless of whether your State or Province has a privacy law, eDriving provides you with the rights listed above.

In Canada, you can contact the Office of the Privacy Commissioner in Canada
In California, US, you can contact the Office of the Attorney General. State of California – Department of Justice – Office of the Attorney General

Contact eDriving

If you have questions or requests about the data protection aspect of processing of your personal information for Mentor by eDriving, you can contact eDriving via privacy@edriving.com or send us a request via our secure web form or at the following addresses:

eDriving LLC
211 Bayberry Drive,
Suites 1 D, E & F
Cape May Court House, New Jersey, 08210.
UNITED STATES OF AMERICA
eDriving Limited
Pennine Business Park
9 Longbow Close
Huddersfield, HD2 1GQ,
England,
UNITED KINGDOM
eDriving Europe Limited
1F North Valley Business Centre
Mallow Road
Cork
T23 KH58
IRELAND

Safe Driving!