Registered Address

Bbright’s registered address is:

Zone 2 Sion Park, Stansted Road, Hertfordshire CM23 5PU United Kingdom


1. Purpose

Bbright is a registered trading name of The Logistics Organisation Ltd.

The Logistics Organisation Ltd (hereafter referred to as TLO) is committed to being transparent about how it collects and uses the personal data of its workforce and customers and to meeting its data protection  obligations. This policy sets out TLO’s commitment to data protection, and individual rights and obligations in relation to personal data.

TLO is authorised and regulated by the Financial Conduct Authority as a credit broker and not a lender. Credit facilities are offered from a panel of lenders.

This policy applies to the personal data of job and/or service applicants, employees, sub-contractors, suppliers, service providers, and customers.

The Directors of TLO have appointed Mr Keith Page as the person with responsibility for data protection compliance within TLO (he can be contacted at Questions about this policy, or requests for further information, should be directed to him.

2. Definitions

“Personal data” is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.

3. Data Protections Principles

TLO are committed to processing personal data in accordance with the data protection principles and ensure it:

TLO tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.

Where TLO processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.

TLO will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the employment, worker, contractor or volunteer relationship, or apprenticeship or internship is held in the individual’s personnel file (in hard copy or electronic format, or both), and on HR systems. The periods for which TLO holds HR-related personal data are contained in its privacy notices to individuals.

TLO keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

We will not share data except with highly regulated partners that the customer enters in a commercial agreement with, such as Stripe, the Lender or the specific manufacturer for the purpose of registering product warranty.

4. Individual Rights

As a data subject, individuals have a number of rights in relation to their personal data.

Subject Access Requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, TLO will tell him/her:

TLO will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

(If the individual wants additional copies, TLO reserves the right to charge a fee, which will be based on the administrative cost to the TLO of providing the additional copies).

To make a subject access request, the individual should send the request to: . In some cases, TLO may need ask for proof of identification before the request can be processed. They will inform the individual if it needs to verify his/her identity and the documents it requires.

TLO will normally respond to a request within a period of one month from the date it is received. In some cases, such as where they have to processes large amounts of the individual’s data, it may respond within three months of the date the request is received but will write to the individual within one month of receiving the original request to tell him/her if this is the case.

If a subject access request is manifestly unfounded or excessive, TLO is not obliged to comply with it. Alternatively, they can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which TLO has already responded. If an individual submits a request that is unfounded or excessive, TLO will notify him/her that this is the case and whether or not it will respond to it.

      The right to complain: If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, contact the Data Protection Officer (see section 7.2 for contact details). If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office: 0303 123 1113.

5. Other Rights

Individuals have a number of other rights in relation to their personal data. They can require TLO to:

To ask TLO to take any of these steps, the individual should send the request to:

6. Data Security

TLO takes the security of personal data seriously. They have internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Where TLO engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and practical measures to ensure the security of data.

7. Impact Assessments

Although unlikely, some of the processing that TLO carries out may result in risks to privacy. Where processing would result in a high risk to individual’s rights and freedoms, the TLO will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

8. Data Breaches

If TLO discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. They will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

9. Individual Responsibilities

Individuals are responsible for helping TLO keep their personal data up to date. Individuals should let them know if data provided to them changes; for example, if an individual moves to a new house or changes his/her bank details.

Individuals may have access to the personal data of other individuals [and of our customers and clients] in the course of their [employment, contract, volunteer period, internship or apprenticeship]. Where this is the case, TLO relies on individuals to help meet its data protection obligations to staff [and to customers and clients].

Individuals who have access to personal data are required:

Further details about the TLO security procedures can be found in its data security policy.

Failing to observe these requirements may amount to a disciplinary offence, from an employee perspective, which will be dealt with under TLO disciplinary procedure. Significant or deliberate

breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

In the case of a contractor, service provider or supplier, TLO reserve the right to consider the withdrawal of the relevant services and potential further law enforcement reporting procedure.

10. Training

TLO will provide training to all individuals about their data protection responsibilities as part of the induction process and at regular intervals thereafter.

Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.