Privacy notice
How PCN Flow handles personal data, in plain English.
Last updated: [Date]
Who we are
PCN Flow is run by [Company name] (company number [Company number], [Registered address]). We are registered with the Information Commissioner's Office, number [ICO number].
We play two roles. For the people who use PCN Flow at a hire company (name, work email, sign-in details) we decide how the data is used, so we are the controller. For the hirers and vehicles in a hire company's PCNs, the hire company decides what we do with the data and we work on its behalf, so we are the processor. The data processing summary covers that second role.
What we process
- Hire company users: name, work email, a hashed password, two-factor settings, and sign-in records (time and result of each attempt).
- Hirers and their hire: name, address, vehicle registration, hire dates and the hire agreement the hire company uploads. If the agreement shows a date of birth or driving licence details, those are part of the document. We do not send them to an issuer unless its form requires them.
- Penalty charge notices: the notice itself and what is read from it (issuer, reference, registration, contravention date, place and amount), and the replies issuers send back.
- Messages to us: what you write when you ask for support or email us.
Why we use it
To read each notice, find the hire that covers it, and ask the issuer to pass the penalty to the hirer (a representation transferring liability), then tell the hirer. We also use it to run the service: keep accounts secure, answer support requests, keep backups and fix faults. Our lawful basis is performing our contract with the hire company and our legitimate interest in running a secure service. For hirers, the hire company's own legal basis is that it must name the hirer to the issuer to avoid being held liable for the penalty.
Who it goes to
- The issuing authority (council, Transport for London, private operator and so on), only what is needed to transfer liability.
- The hirer, to tell them that the penalty has been passed to them.
- Our service providers, listed below. They process data only to provide their part of the service.
| Provider | What for | Where |
|---|---|---|
| Hetzner | Hosts the app and its database. | Europe [confirm datacentre] |
| Cloudflare | R2 storage for uploaded files and backups; the network connection to the app. | [confirm R2 location] |
| Postmark | Sends and receives email (representations, hirer notices, replies, system mail). | United States |
| Anthropic | Reads uploaded notices and hire agreements. | United States |
| Stannp | Prints and posts letters, when a company switches posting on. | United Kingdom |
| Resend | A backup email service, used only if we switch to it. | United States |
We do not sell personal data and we do not use advertising or tracking tools.
Reading documents with AI
Notices and hire agreements are read by Anthropic's AI service, which receives the document and returns the details we ask for. Under Anthropic's commercial terms, content sent through its API is not used to train its models. A person at the hire company checks the details before anything is sent.
Where it is kept
The app and its database run on a Hetzner server. Files and backups are in Cloudflare R2. Some providers, such as Anthropic and Postmark, process data in the United States. Where data leaves the UK we rely on the safeguards in those providers' terms, such as the UK addendum to the standard contractual clauses or the UK-US data bridge.
How long we keep it
- Hire company records (PCNs, hirers, agreements, documents): while the hire company has an account, and for [retention period] after it closes.
- Backups: 30 days.
- Expired sign-in sessions and sign-in attempts: 30 days.
- Support messages: [retention period].
Your rights
You can ask to see your data, correct it, delete it, restrict or object to how it is used, or have it moved. If you are a hirer, ask the hire company that sent your notice first; we will help them answer. You can also ask us directly at [email protected]. If you are unhappy with our answer you can complain to the Information Commissioner's Office at ico.org.uk.