Swiss Vans – Data Deletion Policy

Executive Summary

Swiss Vans is committed to protecting your privacy and handling your data responsibly. This data deletion policy outlines our approach to collecting, retaining, and deleting customer data in compliance with UK regulations, including those pertaining to financial transactions and anti-money laundering requirements. We collect personal, financial, and transactional data, which is retained for periods ranging from 3-7 years depending on the data type and regulatory requirements. Customers can request data deletion through our dedicated portal, though certain exemptions apply under UK law. All deletion processes are securely documented and executed in accordance with industry best practices.

1. Introduction

Swiss Vans recognizes the importance of protecting your personal data and your right to have your information deleted when it is no longer necessary for business or legal purposes. This policy outlines our approach to data deletion, in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and relevant anti-money laundering regulations.

2. Data We Collect

Swiss Vans collects and processes the following categories of personal data:

• Personal Identification Information: Name, address, contact details, identification documents
• Financial Information: Payment details, bank account information, credit checks
• Transaction Information: Vehicle purchase/lease history, service records, payment history
• Communication Records: Email correspondence, call recordings, customer service interactions
• Website Usage Data: Cookies, IP addresses, browsing behavior on our website
• Marketing Preferences: Opt-in/opt-out decisions, marketing communication history

3. Data Retention Periods

Swiss Vans adheres to the following retention periods, which are aligned with UK regulatory requirements:

Data Category	Retention Period	Regulatory Basis
Transaction records	7 years	The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
Financial information	7 years	Finance Act requirements
Vehicle purchase/lease agreements	7 years from end of agreement	Consumer Credit Act 1974
Customer identification records	5 years from end of business relationship	Anti-Money Laundering regulations
Marketing data	3 years from last interaction	UK GDPR
Website usage data	3 years	UK GDPR

4. Data Deletion Process

Our data deletion process follows these steps:

1. Identification: We identify all personal data related to the data subject across all systems
2. Assessment: We determine if any legal retention requirements apply
3. Deletion Method: We employ secure deletion methods appropriate to the storage medium:
   • Electronic data: Secure wiping using industry-standard algorithms
   • Physical documents: Secure shredding with certificate of destruction
4. Verification: We verify that deletion has been completed successfully
5. Documentation: We maintain records of deletion requests and actions taken

5. Requesting Data Deletion

Customers can request the deletion of their personal data through the following methods:

• Online: Submit a request through our secure customer portal at www.swissvans.co.uk/privacy
• Email: Send a request to dataprivacy@swissvans.co.uk
• Post: Write to Data Protection Officer, Swiss Vans Ltd, [Address]
• Telephone: Call our dedicated data protection line on [Phone Number]

We will respond to all deletion requests within 30 days, as required by the UK GDPR.

6. Exceptions to Data Deletion

In accordance with UK law, Swiss Vans may deny or delay a data deletion request in the following circumstances:

• Legal Obligation: Where we are required to retain data by law, including:
  • Anti-money laundering requirements (7 years)
  • Tax purposes (up to 7 years)
  • Vehicle safety recalls and related information
• Legitimate Business Interests: Including:
  • Defending legal claims
  • Fraud prevention
  • Vehicle warranty information
• Public Interest: Where data serves an important public interest, such as vehicle safety records

7. Compliance Measures

Swiss Vans maintains robust compliance measures, including:

• Regular Audits: Internal and external audits of our data deletion practices
• Staff Training: Regular training for all staff handling personal data
• Documented Procedures: Detailed procedures for handling data deletion requests
• Data Mapping: Comprehensive mapping of all data storage locations
• Automated Retention: Systems that flag data for review when retention periods expire

8. Third-Party Data Processors

When Swiss Vans engages third-party processors, we ensure that:

• Data processing agreements include clear provisions for data deletion
• Third parties provide confirmation of data deletion when requested
• Regular compliance checks are conducted with our data processors

9. Changes to This Policy

This policy will be reviewed annually and updated as necessary to reflect changes in our practices or regulatory requirements. The current version will always be available on our website.

10. Contact Information

If you have questions about our data deletion policy, please contact:

Data Protection Officer
Swiss Vans Ltd
[Address]
Email: dpo@swissvans.co.uk
Phone: [Phone Number]

Last Updated: August 2025