Privacy Notice

Business Name: Jason O’Rourke
Trading/Vehicle Name: Paul the Campervan
Address: 11 Finch Drive, Sleaford, Lincolnshire, NG34 7US, United Kingdom

Effective Date: 1 January 2026

1. Introduction

This Privacy Notice explains how Jason O’Rourke, trading in connection with Paul the Campervan, collects, uses, stores and protects personal information when you make an enquiry, make a booking, hire the campervan, communicate with us, or otherwise interact with our campervan hire business.

We are committed to protecting your personal information and handling it fairly, lawfully and transparently.

This Privacy Notice applies to personal information relating to:

  • The Hirer;
  • Approved drivers;
  • Members of the travelling party;
  • Individuals who communicate with us about a booking;
  • Individuals whose information is provided to us in connection with a booking; and
  • Individuals who may be captured by the vehicle's external CCTV system.

For the purposes of applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Jason O’Rourke is the Data Controller for the personal information described in this Privacy Notice.

2. Information We Collect

Depending on the nature of your interaction with us, we may collect and process the following information.

Personal and contact information

This may include:

  • Full name;
  • Postal address;
  • Email address;
  • Telephone number;
  • Booking details;
  • Payment information;
  • Communication records; and
  • Information provided when making an enquiry or booking.

Driving licence and insurance information

Where required by our self-drive hire insurance policy, we may collect:

  • Driving licence details;
  • A copy of the photocard driving licence;
  • DVLA check code;
  • Driving entitlement information;
  • Details required to establish eligibility to drive the vehicle; and
  • Information required by our insurer.

Proof of address

We may collect two documents to verify your address where required by our insurance policy.

These may include documents such as:

  • Council tax bills;
  • Utility bills;
  • Bank statements;
  • Mortgage statements;
  • Payslips;
  • HMRC correspondence;
  • Credit card statements; and
  • Other acceptable documents specified in our Terms and Conditions.

We will only use such documents for legitimate purposes connected with verification, insurance, fraud prevention and the hire of the vehicle.

3. GPS Vehicle Tracking

Paul the Campervan is fitted with a GPS tracking device.

The tracking system may collect information including:

  • Vehicle location;
  • Vehicle movement;
  • Speed;
  • Journey information;
  • Ignition status;
  • Security-related information; and
  • Speed or other security-related alerts.

The tracking system may generate notifications where defined thresholds or security events occur.

GPS information may be processed for purposes including:

  • Vehicle security;
  • Theft prevention and recovery;
  • Insurance requirements;
  • Protecting the vehicle;
  • Investigating suspected misuse;
  • Investigating accidents or incidents;
  • Establishing the location of the vehicle where reasonably necessary;
  • Supporting insurance claims; and
  • Protecting our legal and commercial interests.

GPS tracking is not intended to provide continuous personal surveillance of the Hirer or travelling party. The purpose of the system is primarily to protect the vehicle, support insurance requirements and assist with legitimate security, safety and operational purposes.

Further information is provided in our Vehicle Tracking Policy.

4. External CCTV

External CCTV cameras are fitted to Paul the Campervan.

The CCTV system is provided primarily as a security and safety feature for the benefit of the Hirer and occupants.

The cameras are positioned to monitor the exterior of the campervan and may capture images of:

  • The area immediately surrounding the vehicle;
  • Other vehicles;
  • Property and structures;
  • Passers-by; and
  • Other individuals who come within the cameras' field of view.

Internal CCTV monitor

A CCTV monitor is provided inside the campervan for the Hirer's use.

The monitor allows the Hirer and occupants to view the external camera feeds and assist with monitoring the immediate surroundings of the vehicle, particularly when the vehicle is parked or occupied.

The monitor is provided as part of the vehicle's security and safety equipment.

No interior monitoring

The cameras do not monitor or record the interior of the campervan.

The CCTV system does not intentionally record activities taking place inside the living or sleeping areas of the campervan.

No audio recording

No audio is recorded by the CCTV system.

The system is used for visual security purposes only.

The ICO recognises that continuous audio recording is particularly intrusive and recommends that audio capabilities are disabled unless there is a specific and justified need.

5. When CCTV May Operate

The external CCTV system may operate while the vehicle is:

  • Stationary;
  • In use;
  • Parked;
  • Occupied; or
  • Left unattended,

where appropriate for security and vehicle protection purposes.

The system may therefore capture images of people or vehicles that enter the camera's field of view even where those individuals are not Hirers or members of the travelling party.

We do not use CCTV for the purpose of monitoring the private activities of Hirers or their travelling companions.

6. Purposes for Which CCTV Is Used

CCTV recordings may be accessed and used where reasonably necessary for purposes including:

  • Protecting the vehicle and its occupants against theft, damage or vandalism;
  • Assisting the Hirer in monitoring the immediate external surroundings of the vehicle;
  • Investigating accidents or incidents;
  • Investigating suspected misuse of the vehicle;
  • Supporting insurance claims;
  • Establishing facts relating to a dispute or incident;
  • Investigating or defending legal claims;
  • Preventing or detecting crime; and
  • Assisting the police, insurers or other competent authorities where legally required or permitted.

We will not use CCTV recordings for unrelated purposes that are incompatible with the purposes described in this Privacy Notice unless permitted by law.

7. Lawful Bases for Processing

We rely on one or more lawful bases under the UK GDPR depending on the nature and purpose of the processing.

Contract

We process personal information where this is necessary to enter into or perform the campervan hire agreement.

This includes:

  • Processing bookings;
  • Verifying driver eligibility;
  • Managing payments;
  • Communicating about the hire;
  • Providing the vehicle;
  • Managing the security deposit; and
  • Administering the hire agreement.

Legal obligation

We may process personal information where necessary to comply with a legal obligation.

This may include:

  • Complying with legal requirements;
  • Responding to lawful requests from authorities;
  • Dealing with traffic offences or penalties;
  • Meeting accounting and tax requirements; and
  • Complying with insurance or other legal requirements.

Legitimate interests

We may process personal information where necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms.

Our legitimate interests may include:

  • Protecting our vehicle and business;
  • Preventing and detecting theft, fraud and misuse;
  • Vehicle security;
  • Customer and occupant safety;
  • Insurance and claims management;
  • Managing disputes;
  • Recovering debts or charges;
  • Establishing, exercising or defending legal claims;
  • Managing traffic offences and penalties; and
  • Operating the campervan hire business effectively.

Where we rely on legitimate interests, we consider the necessity and proportionality of the processing and the potential impact on individuals.

Our use of vehicle tracking and external CCTV is supported by documented legitimate interests assessments where appropriate.

8. Privacy Notice and Booking Acceptance

Our Terms and Conditions require the Hirer to confirm that they have read and understood this Privacy Notice and our Vehicle Tracking Policy before a booking becomes confirmed.

This acknowledgment is intended to ensure that customers are provided with clear information about how their personal information is processed.

The acknowledgment does not mean that consent is the lawful basis for every processing activity described in this Privacy Notice.

Where applicable, processing is carried out under the lawful bases described in Section 7.

9. Information Sharing

We may share personal information where reasonably necessary and lawful with:

  • Our self-drive hire insurer;
  • Insurance brokers or claims handlers;
  • Breakdown and recovery providers;
  • Vehicle tracking service providers;
  • CCTV or vehicle security system providers;
  • Payment service providers;
  • Professional advisers;
  • IT and software service providers;
  • Legal representatives;
  • Government departments and regulatory authorities;
  • Police and law enforcement agencies; and
  • Courts or other competent authorities.

We will only share information where there is a lawful basis for doing so and only the information reasonably necessary for the relevant purpose.

We do not sell customer personal information.

10. Traffic Offences and Penalties

If a traffic offence, parking charge, toll, congestion charge, Low Emission Zone charge, Clean Air Zone charge, bus lane penalty or other charge is incurred during a hire period, we may process and disclose the Hirer's information where necessary to identify the responsible driver or deal with the relevant charge.

This may include providing information to:

  • Police forces;
  • Local authorities;
  • Parking operators;
  • Toll operators;
  • Enforcement agencies; or
  • Other organisations legally entitled to request the information.

We may also retain relevant booking and driver information to administer and defend any resulting claim or dispute.

11. CCTV and GPS Data Retention

We will not retain personal information for longer than reasonably necessary for the purpose for which it was collected.

CCTV

CCTV recordings will normally be retained only for the period specified in our Data Retention Schedule.

Where an incident, accident, insurance claim, legal dispute, investigation or law-enforcement request requires specific footage to be preserved, relevant recordings may be retained for longer where reasonably necessary.

The ICO states that there is no universal CCTV retention period; retention should be based on the purpose for which the footage is required and should be no longer than necessary.

GPS data

GPS and vehicle tracking information will be retained in accordance with our Data Retention Schedule and only for as long as reasonably necessary for the relevant purpose.

Where specific information is required for an insurance claim, dispute, investigation or legal matter, it may be retained for longer where reasonably necessary.

12. Security of Personal Information

We take reasonable technical and organisational measures to protect personal information against:

  • Unauthorised access;
  • Unauthorised disclosure;
  • Accidental loss;
  • Destruction;
  • Damage; and
  • Unauthorised alteration.

Access to personal information, GPS data and CCTV recordings is restricted to people who have a legitimate reason to access it.

CCTV recordings and vehicle tracking information will be protected using appropriate security measures.

The ICO recommends that surveillance recordings are securely stored and that access is limited to those who need it.

13. Data Breaches

If we become aware of a personal data breach, we will assess the breach and take appropriate action in accordance with our Data Breach Procedure.

Where required by law, we will notify the Information Commissioner's Office and/or affected individuals.

14. Your Data Protection Rights

Subject to applicable legal conditions and exemptions, you may have the following rights:

  • The right to be informed about how your personal information is used;
  • The right to access your personal information;
  • The right to request correction of inaccurate information;
  • The right to request deletion of personal information in certain circumstances;
  • The right to request restriction of processing in certain circumstances;
  • The right to object to processing based on legitimate interests;
  • The right to data portability where applicable; and
  • Rights relating to automated decision-making and profiling where applicable.

You may also have the right to object specifically to certain processing carried out on the basis of legitimate interests.

These rights are subject to legal conditions and exemptions.

15. CCTV Access Requests

If you believe that you have been captured by the external CCTV system, you may request access to your personal data.

When responding to a CCTV access request, we may need to consider the rights and privacy of other individuals who appear in the footage.

Where necessary, footage may be redacted or third-party images obscured before disclosure.

We may ask you to provide sufficient information to help us identify the relevant footage, such as:

  • Date;
  • Approximate time;
  • Location; and
  • Description of the circumstances.

16. Complaints

If you have concerns about how we process your personal information, please contact us first so that we can investigate and attempt to resolve the matter.

You also have the right to complain to the Information Commissioner's Office (ICO) if you believe your personal information has been processed unlawfully or that your data protection rights have not been respected.

Further information about the ICO and how to make a complaint is available from the ICO website.

Information Commissioner's Office (ICO)

17. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect:

  • Changes to our business;
  • Changes to our vehicle or security systems;
  • Changes to GPS tracking or CCTV;
  • Changes in legal or regulatory requirements; or
  • Changes to how we process personal information.

The latest version will be made available to customers and will show its effective date.

We will provide appropriate information about significant changes before introducing any new processing where required.

18. Contact Details

For questions about this Privacy Notice, your personal information, GPS tracking, CCTV or your data protection rights, please contact:

Jason O’Rourke
11 Finch Drive
Sleaford
Lincolnshire
NG34 7US
United Kingdom

Data Controller: Jason O’Rourke
Vehicle: Paul the Campervan

Privacy Notice Effective Date: 1 January 2026