1. Who we are
SWX Locate is a vehicle tracking service operated by SWXLDN Limited, a company registered in England and Wales under company number 15353199.
We design, own and operate the tracking platform, and our engineers fit and support the tracking units.
| Data protection contact | hello@swxlocate.co.uk |
| Post | SWX Locate, Unit 22 Silverwing Industrial Estate, Imperial Way, Croydon, CR0 4RR |
| Telephone | 0330 043 3677 |
2. When we are a controller and when we are a processor
This distinction matters, because it determines who is responsible for what.
We are the controller
For personal data about our own enquirers, customers, suppliers and website visitors — we decide why and how it is processed.
We are a processor
For the tracking data belonging to our business customers. When a company fits SWX Locate to its vehicles, that company is the controller: it decides that its drivers will be tracked, why, and on what lawful basis. We process that data on its documented instructions under a written contract.
If you are a driver with a question about why your employer tracks you, your employer is the right place to start. We will always help where we can, but we cannot make decisions about their data on their behalf.
3. What we collect
| Enquiries | Name, company, email address, telephone number, and whatever you tell us about your fleet. |
| Customers | Contact details, site addresses, vehicle and unit records, correspondence, and billing and payment information. |
| Website | IP address, browser and device type, pages viewed, and referring page. See section 13. |
| Tracking platform | See section 4. |
| Vehicle records | See section 5. |
4. Vehicle tracking data
Where a tracking unit is fitted to a vehicle, the platform records:
- Position, speed, heading and time, at regular intervals while the vehicle is in use
- Journey start and end points, stop locations and stop durations
- Ignition status, and where the unit supports it, harsh braking, acceleration, cornering and idling events
- Odometer or calculated mileage
- Driver identity, where the customer has assigned drivers to vehicles or uses driver identification
- Unit diagnostics such as signal strength and battery voltage
Vehicle location is personal data whenever it can be connected to an identifiable person, which in practice is almost always the case in a small fleet. It is treated as personal data throughout this notice.
Accounts can be configured so that tracking is suppressed outside defined working hours, or on defined vehicles, for privacy reasons. We recommend this wherever a vehicle is taken home or used privately. Customers should ask us to set this up.
5. DVSA and DVLA vehicle record lookups
Our dashboard can retrieve vehicle information from two government sources using a vehicle registration number:
- MOT test history from the Driver and Vehicle Standards Agency — test dates and results, expiry dates, recorded mileage, failure reasons and advisory notes.
- Vehicle details from the Driver and Vehicle Licensing Agency Vehicle Enquiry Service — tax and MOT status, registration and manufacture dates, and technical details such as engine capacity and fuel type.
We access these services as an authorised user under their published terms. Where information obtained from these sources is combined with other data we hold, so that a living individual can be identified, we accept responsibility as a controller for that combined data and process it in line with this notice.
We are not affiliated with, endorsed by or sponsored by DVSA or DVLA. Vehicle record information is provided as retrieved and we cannot correct errors in a government record — those need to be raised with the agency concerned.
6. Lawful bases
| Responding to enquiries | Legitimate interests — responding to someone who has contacted us about our services. |
| Providing our services | Performance of a contract, or steps taken at your request before entering one. |
| Invoicing, accounting and tax | Legal obligation. |
| Service and safety notices | Legitimate interests — keeping installed units working and reporting correctly. |
| Marketing by email | Consent, or the soft opt-in for existing customers. You can withdraw at any time. |
| Website analytics | Consent, where non-essential cookies are used. |
| Tracking data | Determined by our customer as controller, usually legitimate interests, with a balancing assessment they are responsible for carrying out. |
8. International transfers
Our tracking platform runs on servers we own and operate, located in Germany within the European Economic Area. The UK Government has made a finding of adequacy in respect of the EEA, so no additional transfer mechanism is required for personal data held there.
Where a supplier processes personal data outside the UK or EEA, we ensure an appropriate safeguard is in place — an adequacy decision, or the UK International Data Transfer Agreement or Addendum.
9. How long we keep personal data
| Unsuccessful enquiries | 24 months from last contact. |
| Customer records | For the life of the relationship, then 6 years for contractual and tax purposes. |
| Invoices and accounting | 6 years after the end of the accounting period. |
| Tracking position history | As set by the customer's plan, up to 12 months by default, then deleted. Customers can request a shorter period. |
| Vehicle record lookups | Cached briefly to avoid repeat queries, refreshed on lookup, and deleted with the vehicle record. |
| Website logs | 12 months. |
When an account closes we delete tracking data within 90 days unless the customer asks us to do so sooner, or we are required to retain it.
10. Security
Access to the platform requires an individual account, and permissions are set so users only see the vehicles relevant to them. Data is encrypted in transit. Servers are patched and monitored, backups are taken and access is limited to staff who need it. We keep records of who accessed what.
If a personal data breach occurs, we will notify affected controllers without undue delay, and report to the Information Commissioner's Office within 72 hours where the breach is reportable.
11. Your rights
Under UK data protection law you have the right to be informed, to access a copy of your data, to have inaccurate data corrected, to have data erased in some circumstances, to restrict processing, to data portability, and to object to processing based on legitimate interests. Where processing is based on consent, you can withdraw it at any time.
To exercise a right, contact us using the details in section 1. We will respond within one month. There is no charge unless a request is manifestly unfounded or excessive.
If your request relates to tracking data held on behalf of your employer, we will pass it to them promptly, as they are the controller.
12. Information for drivers
If your employer has fitted SWX Locate to a vehicle you drive, this section is for you.
- The system records where the vehicle is, how fast it is moving and when it starts and stops. Depending on configuration, it may also record braking, acceleration and idling.
- Your employer decides who can see that information and what it is used for. They should have given you a privacy notice of their own explaining this.
- Your employer should have carried out a legitimate interests assessment, and in most cases a data protection impact assessment, before switching tracking on.
- Where a vehicle is used privately, tracking can be suppressed outside working hours. If that matters to you, raise it with your employer — they can ask us to configure it.
- You have the rights set out in section 11. Address them to your employer first.
Employers: we provide a template driver privacy notice and a legitimate interests assessment to help you meet these obligations. They are a starting point drafted for general use, not legal advice, and you should have them reviewed before you rely on them.
14. Complaints
If you are unhappy with how we have handled your personal data, please contact us first — most things are resolved quickly. You also have the right to complain to the Information Commissioner's Office at ico.org.uk, by telephone on 0303 123 1113, or at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
15. Changes to this notice
We review this notice periodically and will update the version and date at the top when we change it. Where a change materially affects how we use your personal data, we will tell you directly.