We'll also tell you how and why we collect your personal information, the partner companies we may share this with, your rights and choices when it comes to these details, as well as the steps we take to keep it secure and confidential.
The purpose of this policy is to ensure that the Pentagon Investments Limited, Group of Companies (The Group) and its staff comply with the provisions of the Data Protection Act 1998 and the new General Data Protection Regulations when processing personal data.
This policy and our practices will ensure that trustworthy business relationships are built and the reputation of the Group as a business and an employer is maintained. The Group aim to be lawful, fair and transparent with personal data and any severe infringement will be treated seriously by the Group and may be considered under disciplinary procedures.
We would like you to use, enjoy and benefit from our products and services without having to compromise your privacy in any way.
Who is collecting the data
Pentagon Investments Limited is the parent company for Lawrence Vehicles Ltd, Mertrux Limited, Pentagon Vehicle Rentals Limited and Meadow Group Services Limited. Personal information is collected in line with the needs of the business.
What data is being collected?
We collect information about you and/or your vehicle when you engage with our website, enquire about our products or services, or with our manufacturing partners. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.
We will give you the option to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might.
We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products and services that you request from us. For example, our Manufacturing partners who provide documentation relating your vehicle.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, we may collect identifying information (not personal information such as your email address) using cookies. Cookies are required as part of this website's operation, and we use traffic log cookies to identify which pages are being used. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. If you indicate that you do not wish to accept cookies from this website, but you continue to use the website, only those cookies that are essential to the operation of the website will be downloaded. If you prefer not to allow the use of any cookies, you can change the configuration of your browser to either warn you when you receive a cookie, or to automatically reject them. You may find, however, that disabling cookies means certain areas of the website do not function correctly.
What is the legal basis for processing your data? (Why we process your personal information)
We will fairly process your data under the following legal basis.
- Contractual necessity
- Compliance with legal obligations
- Vital interest
- Legitimate interests
If you provide us with your information for processing under Consent, it could be used for; supplying brochures, mailers including information about our products and services, prospecting, quotations for products and services, test drives and surveys. You may withdraw your consent at any time, see contact us at the bottom of this policy.
If we have a contract with you, processing is necessary in relation to the contract which you have entered into with us such as but not limited to, Vehicle Sales Quotation, Order/s, taking payment, establish a credit account, Service and Maintenance contracts / extended warranty and to chase payment. We will complete our obligations under this contract to the best of our ability and use you data in an appropriate way.
If there are any urgent safety or product recall notices, we will contact you when we reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
We will comply with our legal obligations which include but is not limited to, sharing data with the DVSA, DVLA, Police, HMRC and other government bodies where appropriate to protect ourselves, our employees and customers.
We will use your personal data when it is necessary for us to pursue our legitimate interests for our business which are vehicle sales, parts sales, repair and maintenance of vehicles.
- We will maintain our records/systems with personal data and vehicle information to know and understand the history of the relationship.
- We will contact existing customers that purchased a product or service or from us with duty of care reminders (for example service reminders/MOT)
- We will inform our current vehicle customers of our new products within the lifecycle of their current vehicle.
- We will share your personal data with our finance house partners to undertake credit checks with the aim to finance a vehicle purchase.
- Whenever you voluntarily disclose personal information online, for example on message boards, through email, or in chat areas, we may use this information for analytical and marketing purposes.
- We may correspond and communicate with you, for efficiency, accuracy or other improvements to our processes to support your data including customer satisfaction surveys.
- We will recruit (for employment purposes) and process your application fairly.
- For marketing activities (other than where we rely on your consent) send targeted marketing messages via social media and other third party platforms. We will send event invites appropriately.
- We will record parts sales data for Warranty and service history purposes.
- We will administer our websites.
- We will aim for prevention of fraud and other criminal activities.
- We continue to provide purchased goods or services to you such as our loyalty program unless we are instructed otherwise.
If you exercise your rights and ask us not to contact you, we will keep a record of this to comply with your request.
When you telephone us we may record the conversation to ensure the security of any transaction discussed; to help us to review our quality of service, dispute and complaint handling purposes and to assist in the training and development of our employees.
How long will we store your data?
Your personal information will be kept to comply with our obligations under the law and in relation to the interests of our business. Once your relationship with us has ended, (for example, contract expires, warranty ended, we learn that you no longer own a vehicle) we will not keep this information for longer than is necessary.
Where we have obtained your personal information following a request for information, test drive, brochure, quotation or any other information on any of our products or services, we will process your data to allow us an opportunity to form a relationship with you.
Will your data be shared with any third parties?
We work closely with third party service providers to bring you a range of products and services that are complimentary to those that we provide. Where external companies are used to process personal data on behalf of the Group (such as payroll bureaus, pension companies etc), responsibility for the security and appropriate use of that data remains with the Group
Where a third-party data processor is used:
- a data processor will be chosen which provides sufficient guarantees about its security measures to protect the your personal data;
- reasonable steps must be taken that such security measures are in place;
- a written contract establishing what personal data will be processed and for what purpose must be set out;
- a data processing agreement, available from the Human Resources Department / the Group, must be signed by both parties.
When we use third party service providers, we will only disclose to them any personal information that is necessary for them to provide their service. We have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
The use of your personal information is necessary for the legitimate interests of the company in operating and improving its services, analysing the use, and ensuring security. We collect little personal information and we use it in ways that are compatible with your individual rights and freedoms.
Where necessary or required we share information with:
- business associates
- goods/service providers
- financial organisations
- government offices
- educators and examining bodies
- credit reference agencies
- debt collection and tracing agencies
Or if any of the following conditions arise:
- If required or permitted to do so by law;
- If required to do so by any court, the Financial Conduct Authority or any other applicable regulatory, compliance, governmental or law enforcement agency;
- If necessary in connection with legal proceedings or potential legal proceedings;
What Individual rights do you have?
You already have certain rights under existing data protection legislation, including a right to request a copy of the personal information we hold on you, if you request it in writing. Under GDPR you will have the following rights:
- Right to be informed: the right to be informed about the collection and use of personal data.
- Right of Access: the right to access their personal data in writing, see below.
- Right to Rectification: the right to inaccurate or incomplete data are erased or rectified.
- Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete; If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date.
- Right to erase: the right to request that we delete or remove your personal information from our systems; You have the right to object how we use your information. May 2018
- Right to restrict our use of your information: the right to 'block' us from using your personal information or limit the way in which we can use it;
- Right to data portability: the right to request that we move, copy or transfer your personal information;
- Right to object: the right to object to our use of your personal information for marketing including where we use it for our legitimate interests. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we're continuing to process your personal information.
We will use reasonable efforts consistent with our legal duty to provide you with your rights in accordance with data protection legislation.
Subject Access Requests
If you are an employee of the Group, you have the right to submit a Subject Access Request. This request will, where reasonably possible, be responded to in 30 days. Any individual wishing to exercise this right should do so in writing and it will be free of charge. If we feel the request is unreasonable, manifestly unfounded or excessive, we may set a charge or refuse the request.
Individuals will not be entitled to access information to which any of the exemptions in the Act applies. However, only those specific pieces of information to which the exemption applies will be withheld and determining the application of exemptions will be made by the HR director. If we have removed your data from our systems after you have asked us to remove it or it has expired under our own terms, this will affect future subject access requests.
How can you contact us if you are concerned?
If you think that we have misused your data, would like to withdraw your consent, correct your data and/or you have a complaint, please contact us and we will be happy to assist. You have the right to be removed from our marketing at any point, please just let us know.
If you wish for us to update your information that is inaccurate, please let us know and we will gladly oblige. Our contact details are, the Human Resources Department at;
|Pentagon Investments Limited
|Meadow Group Services Limited. ICO Ref no. Z7318121
|Lawrence Vehicles Limited T/A Lancashire DAF ICO ref no. Z6390836 Also trading as Lothian DAF Lancashire Truck and Trailer Lothian Truck and Trailer
||firstname.lastname@example.org email@example.com firstname.lastname@example.org email@example.com
|Pentagon Vehicle Rentals Ltd ICO ref no. Z4646724
|Mertrux Ltd ICO Ref no. Z5350144
If you're not satisfied with the way any complaint you make in relation to your personal information is handled by us then you may be able to refer your complaint to the relevant data protection regulator. In the UK, this is the Information Commissioner's Office. Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Telephone number 0303 123 1113.
Anti – Slavery and Human Trafficking Policy / Statement
Pentagon Investments Limited and group
Meadow Group Services Limited
Pentagon Vehicle Rentals Limited
Anti - Slavery and Human Trafficking Policy / Statement
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps the Company is taking to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
Introduction from Ian Marshall, Group Managing Director
Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking. The Company has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.
The Company also expects the same high standards from its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.
Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.
Group Managing Director
Mertrux Limited is a franchised Mercedes-Benz Commercial Vehicle Dealer and retails and repairs the Mercedes Benz Van and Truck range. In addition, the group retails commercial vehicle parts and accessories as part of the Mercedes Benz UK network. Mertrux has its head office in Derby and branches in Derby, Leicester, Mansfield and Nottingham.
The group employs approximately 190 people over 4 sites.
Our Supply Chains
Our supply chain includes the sourcing of vehicles, bodies, ancillary equipment and parts relating to the sale and repair of new commercial vehicles.
The automotive supply chain is one of the most complicated of any industry. There are often six to ten levels of suppliers between an automaker and the source of raw materials that enter the manufacturing process. The breadth, depth and interconnectedness of the automotive supply chain make it challenging to effectively manage business and sustainability issues. Respecting human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility. As customers, however, we play an active role in supplier development and have adopted various means to clearly communicate our expectations to our suppliers.
Our Policy on Human Slavery and Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in any part of business or in our supply chains. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to prevent slavery and human trafficking taking place anywhere in our supply chains.
Due Diligence Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk –
• We employ a Human Resources Team who vet all applicants thoroughly and work closely with any agencies and 3rd parties who provide us with potential labour.
• Where possible we build long standing relationships with our suppliers and make clear our expectations of business behaviour.
• With regards to national or international supply chains, our point of contact is preferably with a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes.
• We expect each entity in the chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the chain, ultimately to component manufacturers.
• We have in place systems to encourage the reporting of concerns and the protection of whistle blowers. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
• We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
We applaud the work being done to reduce forced labour and human trafficking in the UK. We are communicating to our staff our policy and awareness training will take place to complement and reinforce this. Training in this area will be provided to key personnel within the business.
Supplier Adherence to our Values
We expect all those in our supply chain and contractors comply with our values.
The Directors and Senior Managers are responsible for compliance in their respective departments and for their supplier relationships.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Managers/Directors have been briefed on the subject.
Our Effectiveness in Combating Slavery and Human Trafficking:
We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
• Use of labour monitoring and HR/Payroll systems
• Authorised Suppliers listing to be maintained and audited.
• All Managers will be briefed on issues around third party labour exploitation.
• Ensure that labour sourcing, recruitment and placement processes are under the control of trusted staff members and are not open to corruption.
• Encourage workers to report cases of hidden third party labour exploitation and investigate and act on reports appropriately.
Group Human Resources Director
Approved by the Board of Directors on 21/06/2018
Group Tax Strategy
Pentagon Investments Limited and subsidiary companies
This document has been approved by the Board of Directors of Pentagon Investments Limited. It is published in accordance with Schedule 19 to the Finance Act 2016 and sets out the Group’s approach to conducting its tax affairs in a responsible manner. It is guidance for all Group employees.
Tax is defined as all financial charges or levies applied by a tax authority in any jurisdiction and covers both direct and indirect taxes.
Risk management and governance
The Group strives to pay the right amount of tax in a timely manner.
The Group seeks advice and assistance from external professional advisors where necessary. This includes assistance on the production of returns, all of which are reviewed and approved prior to submission. Where appropriate the Group employ appropriately skilled and experienced staff to manage and process tax matters. Training is provided and advice sought from third parties where necessary.
Tax planning and attitude to risk
The Group operates in an open and fair manner. We endeavour to provide a good service to our customers, to look after our staff and to generate a profit. When submitting tax returns and computations we aim to make them fair, accurate and timely and to respond to any queries in a timely fashion.
We utilise third party professional advisors to assist and provide guidance when tax planning. We use incentives, reliefs and exemptions in line with and in the spirit of tax legislation and pay our taxes in accordance with all laws and regulations. We do not use tax aggressive tax avoidance schemes.
Relationship with HMRC
We endeavour to be transparent in all our dealings with HMRC and to respond to any requests in a friendly, timely and professional manner