Privacy Policy
How DriverWell collects, uses, and protects your personal data
Last updated: 22 September 2026
1. Introduction
DriverWell ("we", "us", "our") is a wellbeing and practical-support platform for people across the transport industry. Harling Yorkshire Limited t/a DriverWell is responsible for deciding how and why personal data is used. Our privacy programme is designed around the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, with open governance actions recorded where technical or supplier evidence is still being completed.
This Privacy Policy explains what data we collect, why we collect it, how we use it, and your rights regarding your personal information.
Data Controller
Harling Yorkshire Limited t/a DriverWell
1 Wheelgate, Malton, North Yorkshire, England, YO17 7HT
Website: driverwell.co.uk
Privacy contact: peter@www.driverwell.co.uk
2. Data We Collect
We collect the minimum amount of personal data necessary to provide our services. We do not sell your data to third parties.
Account Information
- Name (as provided by your login provider)
- Email address
- Login method and identity-provider account reference returned through Manus OAuth
- Account creation date
Legal basis: Contract performance (Art. 6(1)(b) UK GDPR)
Health & Wellbeing Data
- Mood check-in entries (mood score, alertness, stress level, optional notes)
- Fatigue logs (driving/rest minutes)
- Private nutrition log entries
- Private diabetes reading-log entries, limited to the reading and time you choose to enter
- Personal readiness checklist answers
- RoadMate messages where you choose to discuss health or wellbeing
Former wellness-score, respiratory, broader glucose, sleep-questionnaire and browser self-check result tools are unavailable. The new private diabetes reading log is limited to a reading and time that a signed-in person chooses to enter. It has no scoring, interpretation, alerts, reports or employer access. Historical records created before review holds remain subject to the retention schedule and authenticated erasure process.
Intended legal basis: consent under Article 6(1)(a) and explicit consent under Article 9(2)(a) UK GDPR. Recorded health-data consent is enforced on the remediated mood, fatigue, RoadMate, nutrition-log, personal-readiness and private diabetes-log writes. The diabetes log also requires a separate, recorded choice and supports individual deletion or deletion of all log entries with withdrawal of that separate choice. Historical records and the wider legacy route inventory remain part of the DPIA review, so DriverWell does not claim that every past health-data path has completed assurance.
Community & Communication Data
- Forum posts and replies (using your chosen display name, not your real name)
- AI chat conversations with RoadMate
- Push notification preferences
Legal basis depends on the function. Community delivery uses contract or legitimate interests; RoadMate content may include health information and is included in the explicit-consent and DPIA review.
Contact & Support Requests
- Name, email address, subject or selected support topic, and any message you choose to send
- BCTA member support requests are received by DriverWell only. They are not sent to BCTA, an employer or a fleet operator
The BCTA member contact form is for help finding DriverWell information and tools. It is not continuously monitored, is not an urgent-support or clinical route, and asks people not to include medical, health or other sensitive personal details.
Legal basis: legitimate interests in responding to a voluntary contact or support-navigation request. We ask people not to provide special-category information through this form.
Learning & Course Evaluation Data
- Module progress, active-learning time and internal assessment result
- Your private development action, if you choose to save one
- Course ratings and optional written feedback
- Learning-support, reasonable-adjustment, complaint or assessment-review requests
- Your separate choice about contributing start and completion status to cohort-protected employer aggregates
Legal basis: Contract performance for saved learning records and requested support; legitimate interests for proportionate course quality evaluation; explicit consent under Articles 6(1)(a) and 9(2)(a) where you choose to include health or disability information in a reasonable-adjustment request.
Testimonial & Story Submissions
- Story content (text, video links, or uploaded videos)
- Your name, role/title, and company type
- Video files (MP4, WebM, MOV) uploaded to secure cloud storage
- YouTube and TikTok links (if you choose to share)
- Submission timestamp and approval status
Legal basis: Explicit consent (Art. 6(1)(a) UK GDPR)
Influencer Partnership Data
- Name and bio/description
- Profile picture (uploaded or from social media)
- Social media platforms (TikTok, YouTube, Instagram, Facebook)
- Platform profile URLs and follower counts
- Tier level (Bronze, Silver, Gold)
- Active/inactive status
Legal basis: Explicit consent (Art. 6(1)(a)) + Legitimate interest (Art. 6(1)(f)) for public profile display
Technical Data
- The public support core does not create a DriverWell page-view session identifier, load a platform analytics script or send public search words to DriverWell
- If you opt into aggregate site-use measurement, DriverWell stores daily total counters and a small fixed set of non-sensitive public-page counters, not a raw page-view history
- The aggregate counter does not accept account or employer links, session IDs, device fingerprints, page titles, referrers, query strings, search words, free text, wellbeing activity, health information, self-check results, crisis activity, RoadMate content or payment data
- Standard request and device metadata that may be processed by the browser, hosting platform and security logs
- Push notification subscription endpoint (if you opt in)
Legal basis: consent for the optional aggregate measurement choice; legitimate interests may apply to strictly necessary security and service logs, subject to the documented balancing and supplier review. Public support use should not be described as anonymous in an absolute technical sense because hosting and network providers may process connection metadata.
Security Incident Reports
- Random report reference, concern category, summary, description and relevant page or time you choose to provide
- Optional contact email, stored only where you ask DriverWell to contact you about the report
- A non-reversible source fingerprint used for database-backed rate limiting
- Restricted status, severity, data assessment, investigation notes, resolution and event history
Legal basis: legitimate interests for proportionate service security and legal obligation where personal-data breach recording or notification duties apply. Reporters are asked not to include unnecessary health information.
3. How We Use Your Data
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Provide mood tracking and wellbeing features | Health & wellbeing data | Consent, including explicit consent where health information is processed; enforcement evidence is being validated |
| Provide a private manual diabetes reading log | A reading and the time the signed-in user chooses to enter | Explicit consent for this separate log, alongside the health and wellbeing data-processing choice. The log has no scoring, interpretation, report or employer access |
| Display your check-in streaks and achievements | Mood entry timestamps | Contract |
| Enable peer support forum | Display name, post content | Legitimate interest |
| Provide AI chat support (RoadMate) | Chat messages | Consent, including explicit consent where message content includes health information; enforcement evidence is being validated |
| Save your Road Transport learning record and private development action | Course progress, active-learning time, internal result and optional reflection | Contract |
| Evaluate and improve controlled learning activities | Course ratings and optional feedback | Legitimate interest |
| Respond to a learner-support, adjustment, complaint or assessment-review request | Request category and message; health or disability information only where you explicitly consent | Contract, legitimate interest and explicit consent for special-category data |
| Send check-in reminders (if opted in) | Push subscription | Consent |
| Understand aggregate public-site use | Daily consented site totals and a small allowlist of non-sensitive public-page totals | Consent. No raw page-view event, account link, employer link, session ID, device identifier, referrer, search term, wellbeing activity or health data is accepted for this purpose |
| Receive and investigate a security concern or possible personal-data incident | Report detail, optional contact information, source fingerprint, status, risk assessment, restricted investigation notes and response history | Legitimate interests for service security and legal obligation where breach duties apply. A public receipt returns only the random reference, status and dates |
| Respond to a voluntary contact or support-navigation request | Name, email address, subject or selected topic, and optional message. BCTA member requests are available only to DriverWell administrators | Legitimate interests in responding to the requested contact. The BCTA member contact form is not for health or other special-category information |
| Employer fleet management (if linked) | Vehicle type, employer link | Consent |
| Record a user's optional telematics consent choice for a possible future connected-driving feature | Consent scope, version, date and withdrawal date. The reviewed consent flow does not store raw driving signals | Consent |
| Provide threshold-protected fleet engagement insights to authorised fleet operators | Aggregate statistics only, suppressed below a floor of 10 for engagement and usage and 20 for mood, fatigue or health. Individual wellbeing records are not included | Contract for the requested operator service; any supporting legitimate-interest purpose remains subject to a documented balancing assessment |
| Display your testimonial/story on the platform | Story content, name, role, video files | Consent |
| Display influencer profile on sponsors page | Name, bio, picture, platforms, follower counts | Consent + Legitimate interest |
| Process video testimonials for admin review | Video files, submission metadata | Consent |
4. Data Storage & Security
We apply proportionate technical and organisational measures and keep the supporting evidence under review:
- Browser connection: DriverWell's deployed service is provided over HTTPS
- Authentication: Individual sign-in is handled through Manus OAuth and a selected identity provider; DriverWell does not receive the password used with that provider
- Application access: Server procedures and administrative routes apply role and ownership checks according to the feature
- Minimal data collection: We only collect what is necessary to provide our services
- No third-party advertising: We do not share your data with advertisers
- Supplier evidence: Hosting location, encryption at rest, backup retention, support access and international-transfer safeguards are being verified with the relevant suppliers. We do not make a specific assurance until evidence is held
5. Data Retention
We retain personal data only while it is needed for the stated purpose, a valid legal requirement, a security or safeguarding need, or an active dispute. The table below distinguishes current controls from periods that still require implementation or professional confirmation.
| Data category | Current retention and deletion position |
|---|---|
| Account and core wellbeing records | Kept while the account is active. The earlier immediate deletion route was disabled after review showed that it did not cover every newer feature record, stored file, supplier copy or backup. An authenticated erasure request now starts a record-by-record review |
| Other user-linked wellbeing, sleep, nutrition, diabetes-reading, shift and productivity records | Kept while the account is active or until an applicable item or erasure request is completed. Private diabetes-reading entries have an individual deletion control and a separate delete-all-and-withdrawal control in the primary database. DriverWell is extending and testing the account-deletion process for newer tables |
| Road Transport learning progress and private development action | Kept while the learning record is active. Erasure and any limited transaction-record exception are reviewed when an account or data request is received |
| Course evaluation and learner-support records | Draft governance targets are up to 24 months for evaluation, up to 12 months after a support or review request is resolved, and 30 days after resolution for voluntary health or disability details. These are not yet automated purge periods and are under controller review |
| Consented aggregate site-use counters | Daily counters only, with no raw event records or identifier fields. They support aggregate platform trends. The retention schedule for these non-personal counters remains subject to controller review and is not presented as an indefinite retention commitment |
| Data-rights request register | Kept while the request is reviewed and completed. After completion, the administrator can remove the name, email and user link while retaining the reference, dates, decision and non-identifying action record. The review period for that minimum audit record is awaiting controller approval |
| Push and email preferences | Kept while the relevant subscription or account is active. The minimum suppression evidence may be retained where needed to respect an opt-out |
| Pending testimonial, story, supporter or influencer submissions | Reviewed manually and removed when no longer needed. No automatic 30-day or 90-day purge is currently claimed |
| Approved public profiles, stories and media | Kept only while the approved publication basis remains valid, then removed following withdrawal or the end of the agreed use |
| Fleet, partnership, callback and contact enquiries | Reviewed after the last meaningful contact and deleted when no contract, continuing request, dispute or legal need remains. A 12-month review target is being implemented and is not represented as an automatic purge |
| Stripe payment, subscription, donation and entitlement records | Kept only for payment delivery, accounting, tax, fraud prevention, chargeback, contract or dispute purposes. The exact statutory period and the split between necessary financial evidence and removable account metadata are pending professional confirmation |
| Security incident reports and response history | Kept while contact, investigation, notification, dispute or legal-hold purposes require it. After closure, an administrator can remove reporter email, account link, contact permission and source fingerprint while retaining the random reference and non-identifying incident history. The maximum review period and backup deletion timing remain under review |
| Crisis, safeguarding, general incident and appeal records | Reviewed case by case and at least annually while a documented safety, legal or dispute purpose remains. DriverWell does not apply a blanket seven-year health-data rule |
| Optional telematics consent record | The current consent interface stores the consent choice, version, scope and opt-out date. The reviewed router does not store raw driving signals. Connected signal ingestion is not treated as launched without a separate supplier, DPIA and deletion review |
| Uploaded files and generated reports | Removed when the linked record, consent, report or account no longer provides a valid purpose, subject to any documented legal hold. A complete stored-file deletion workflow is being implemented |
| Database backups and supplier copies | Deletion timing depends on the relevant supplier's backup and service retention. DriverWell is obtaining this evidence and will re-apply a deletion after restore where necessary and supported |
6. Your Rights Under UK GDPR
Under the UK GDPR, you have the following rights regarding your personal data:
Right of Access
Request a copy of personal data we hold about you. The self-service JSON extract covers the listed core categories; contact us for a complete access response.
Right to Erasure
Submit and track an authenticated erasure request. DriverWell reviews database records, stored files, supplier copies and any limited legal exception before confirming completion.
Right to Rectification
Request correction of inaccurate personal data. Contact us to update your information.
Right to Restrict Processing
Request that we limit how we use your data in certain circumstances.
Right to Data Portability
Receive applicable data in a structured, machine-readable format. A current self-service JSON extract is available, and you can contact us if additional categories are required.
Right to Object
Object to processing based on legitimate interest. Contact us to exercise this right.
Right to Withdraw Consent
You can withdraw optional aggregate measurement through browser-storage preferences. Signed-in users can withdraw the current health-and-wellbeing processing choice through Settings, and can delete all private diabetes-log entries while withdrawing that separate log choice. Withdrawal does not affect processing that took place before it, or a separate legal basis that applies.
To exercise any of these rights, email us at peter@www.driverwell.co.uk. We aim to respond within one month of receiving a valid request. If the law allows us more time because a request is complex or numerous, we will explain that within the first month.
7. Third-Party Services
We use external platform and service suppliers to operate DriverWell. The exact supplier role, contract, sub-processor, data-location and retention evidence is being reviewed in a controlled supplier register.
| Service | Purpose | Data Shared |
|---|---|---|
| Manus platform services | Hosting, deployment, OAuth, managed database access, object storage proxy, server-side API gateway and owner notifications | The account, feature, file, AI, notification and service-usage data needed for the selected DriverWell function |
| Selected identity provider through Manus OAuth | User authentication | Provider account identifier, name, email and login method returned after sign-in |
| Manus AI gateway and downstream model provider | RoadMate chat and controlled study-assistant functions | RoadMate message content, or published course module content for the study assistant. Provider retention, training-use and downstream terms are pending documentary verification |
| Sinch Mailjet | Transactional and authorised operational email | Recipient email, recipient name where used, subject and message content |
| Stripe | Card payments, subscriptions, donations and entitlement fulfilment | Customer or donor details supplied at checkout, company and product information, and internal user or fleet reference metadata |
| Browser or operating-system push service | Optional push notifications | Push endpoint, delivery keys, notification content and preferences |
| Twilio, only if SMS is configured and used | Optional reminders and operational alerts | Telephone number and the minimum reminder or alert content needed for that message |
We do not sell personal data, use advertising networks or load a platform analytics script on the public support journeys. When a visitor actively enables optional measurement, DriverWell uses its own daily aggregate counter. It does not store raw route events or accept an account link, employer link, session ID, device identifier, page title, referrer, search words, wellbeing activity or health information for Site Analytics.
A security report is stored in DriverWell's restricted register. The separate owner notification contains only the random reference and report category. It does not include the user-supplied summary, description or contact email.
When you follow a link to another website or service, that organisation's privacy and cookie information applies to your use of its service. Please read its information before providing personal data.
8. Children's Privacy
DriverWell is designed for transport workers aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If a possible minor account is identified, we will restrict it, verify the circumstances and handle the data under the controlled erasure and safeguarding process.
9. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify users of significant changes through the platform. Where a material change affects an optional or consent-led purpose, we will explain the change and ask for a new choice where that is required before using data for the changed purpose. The "last updated" date at the top of this page indicates when the policy was last revised.
10. Complaints
If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the UK's data protection authority:
Information Commissioner's Office (ICO)
Website: ico.org.uk
Helpline: 0303 123 1113
We encourage you to contact us first at peter@www.driverwell.co.uk so we can try to resolve your concern.
11. GDPR and ePrivacy approach
DriverWell is designed to support compliance with the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003. Compliance depends on both technical controls and maintained governance records, including consent, retention, supplier and risk-assessment evidence.
Cookie and Analytics Choice
The cookie preference control allows you to:
- Continue with essential storage only
- Choose whether optional aggregate site-use measurement is allowed
- Withdraw or modify the choice at any time
- View the browser-storage details, including the local daily-count marker
Lawful Basis for Processing
All processing of personal data is based on one of the following lawful bases under Article 6 UK GDPR:
- Consent: For health data, marketing communications and non-essential analytics where consent is required
- Contract: To provide the DriverWell platform and services
- Legitimate interests: For proportionate platform improvement and security where the relevant balancing assessment supports it
Special Category Data (Health Data)
DriverWell's intended Article 9 condition for user-entered health and wellbeing data is explicit consent under Article 9(2)(a) UK GDPR. The DPIA is validating that every collection, use, withdrawal and deletion route enforces and records that choice consistently. Until that evidence is complete, DriverWell does not describe the special-category consent control as fully implemented.
Data Retention
The current controls and open implementation work in section 5 apply. DriverWell does not apply a blanket seven-year health-data period. An authenticated erasure request is recorded and reviewed across current database features, stored files and relevant suppliers. Any limited legal, safety, security, transaction or dispute-handling exception must be documented by category.
12. Contact Us
For any questions about this Privacy Policy or your personal data, please contact:
Harling Yorkshire Limited t/a DriverWell
1 Wheelgate, Malton, North Yorkshire, England, YO17 7HT
Email: peter@www.driverwell.co.uk
Website: driverwell.co.uk