Fleet Data Processing Addendum

Fleet Data Processing Addendum

This Fleet Data Processing Addendum ("Fleet DPA") forms part of the MotR Fleet Terms and sets out the controller and processor roles for processing personal data in connection with MotR Fleet. It is a draft for completion and legal review.

Controller and processor allocation

Where MotR processes tracking or driver data solely on the documented instructions of a Fleet customer, MotR acts as processor and the Fleet customer acts as controller for that processing.

Where MotR determines its own purposes and means for processing, MotR acts as controller. This includes: account administration; billing; fraud and security; legal compliance; customer support records; service administration; and MotR's own necessary business records.

MotR does not claim processor status for any processing where it in fact determines the purposes and means. Where the allocation is mixed for a particular activity, the parties will document which elements are controller activity and which are processor activity.

Processor obligations (where MotR acts as processor)

MotR will: process personal data only on the Fleet customer's documented instructions (unless required by law); ensure confidentiality of personnel with access; implement appropriate technical and organisational measures; assist the Fleet customer with data subject requests and breach notification where applicable; and delete or return personal data on termination as instructed.

Subprocessors

MotR may use subprocessors (such as a telematics platform and hosting provider) to provide the service. A list of subprocessors is maintained in the internal Subprocessor Register. MotR will give notice of material changes to subprocessors.

International transfers

Where personal data is transferred outside the UK, appropriate safeguards (such as UK Addendum to the EU SCCs or the UK-US Data Bridge) will be used.

Audit

The Fleet customer may, subject to confidentiality and reasonable notice, audit MotR's compliance with this DPA where reasonably necessary.

This Fleet DPA is a draft for completion and solicitor review before use.

MotR is a trading name of HELPYR LTD (company number 17109208), registered office: Gladstone Road, Chester, CH1 4BY, United Kingdom. For questions about this document, contact contact@motr.uk.