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Risk App Policy



  1. The Data Controller is Moto Hospitality Limited (“Moto”), Toddington Service Area, Junction 11/12, M1 Southbound, Toddington, Bedfordshire, LU5 6HR.

  2. The following data, including personal data, will be processed in order to verify, manage, process, analyse and report on incidents and claims where: (i) Moto site visitors, including customers, contractors and colleagues  at a Moto site; and/or (ii) colleagues, while working off-site for Moto;  suffer an incident, such as personal injury (including food poisoning, food intolerance and/or foreign bodies found in food); and/or damage to, or theft of, property; and/or where environmental contamination occurs (e.g. a fuel spill from an HGV):

  • Name, role and email address of the Moto colleague reporting the incident.
  • Full name, postal address, email address and phone number of the affected individual,
  • Where the affected individual is a Moto colleague, their job title and length of service, and where they are a Moto supplier and/or contractor, the company/organisation they work for and their job title.
  • Details of the incident, including location, date, time and nature of the incident, and where relevant to the incident, the vehicle registration number.
  • Details in relation to any first aid administered immediately after the incident, including who administered it and what parts of the body were affected.
  • Details of symptoms and duration in relation to reported food complaints.
  • Details of potentially related health conditions, where an employee injury/incident has occurred.
  • Where property has been lost or damaged: (i) a description of the property and the approximate value; and (ii) if applicable, a description of the damage.
  • Where a security incident has occurred, (e.g. theft or assault) a description of the alleged offender may be included.
  • Witness statements and contact details from individuals who have witnessed incidents.
  • Photographs, including where these are supplied by customers to our customer services team.
  • Follow-up details in relation to the incident, such as: (i) whether and when a claim has been issued; (ii) whether and when the claim has been resolved; (iii) how the claim has been resolved; and/or (iv) details in relation to any HSE and/or RIDDOR reporting and any follow-up investigation.

    In addition, further personal data may be collected where it is relevant to the incident and/or any potential claim. The personal data may also be processed for such further purposes as are legally permissible and compatible with the above purposes, for example, to correspond with visitors, customers, contractors and/or colleagues, in connection with incidents and/or claims, for insurance purposes, and/or in connection with establishing, exercising or defending legal rights and/or claims.
  1. Moto processes this information (i) in compliance with legal requirements, as Moto has a duty to record, report and investigate certain accidents and incidents; and (ii) as it is in our legitimate interests, and in the legitimate interests of site visitors, customers, contractors and colleagues for Moto to monitor, investigate and promote health, safety and security both at Moto sites and also off-site for colleagues working remotely. It is also in Moto’s legitimate interests to collate information for reporting purposes, to improve risk management, and for the submission of and/or responses to insurers and/or in relation to legal claims.

    The additional processing conditions for processing special category data, such as health data, within the risk management application are: (i) where this is necessary for carrying out obligations and exercising rights conferred on Moto or the individual data subjects by law in relation to employment, social security and social protection law (e.g., where monitoring the health and welfare of Moto colleagues and/or where Moto is required by law to report on certain incidents); (ii) where processing is necessary in relation to legal claims (including to obtain advice, establish, exercise and/or defend legal claims); and (iii) where the processing is in the substantial public interest, e.g. for the purpose of preventing or detection unlawful acts.

  1. Moto will generally retain personal data in relation to:
  • personal injury, food-related incidents, damage to or loss of property and/or security incidents, where a claim is submitted, for 6 months after the claim has been settled;

  • personal injury, food-related incidents, and/or security incidents, where no claim is submitted, for (i) 4 years after the date of the incident/accident, in relation to adults; or (ii) where the incident/accident relates to someone under the age of 18, for up to 6 months after they reach 21 years;

  • damage to or loss of property, where no claim is submitted, for 4 years from the date of damage or loss;

  • industrial diseases and associated health information, as per statutory requirements;

    unless Moto needs to retain any data for longer, such as where there is any legal or regulatory requirement or where there are any on-going related circumstances or claims for which this information is required. In such cases, this data will be held for such appropriate periods as may apply in the circumstances.  
  1. We may share the data collected within this application where we are legally required or permitted to do so, for example with (i) our external advisers (including legal advisers) and/or insurers; (ii) Government and/or local authority bodies, (iii) the police and/or other law enforcement authorities, (iv) the HSE and other agencies and regulatory authorities. Such sharing may be for purposes such as law enforcement (including to prevent and detect crime), and/or in response to legal or regulatory requests and/or in order to pursue or respond to claims. Save as indicated, will not otherwise generally share with other third parties the details of our visitors, customers, contractors or colleagues which have been collected in this App.

  2. The information, including any personal data, within this App will be kept secure by appropriate organisational and technical means, including encryption, and it will be stored by Moto within the UK. 

  3. Individuals are entitled to request access to the personal data we hold about them, or to request that we rectify or erase their personal data or, in some circumstances, that we restrict our processing of such personal data. You should contact Moto at if you wish to exercise these rights.

  4. If you have any queries or complaints about the way in which your data is being processed, and/or you would like further information in relation to our data processing, please see the privacy notice on our website at or contact us at: You also have the right to contact the Information Commissioner’s Office.

  5. Moto may update this privacy notice at any time. The updated version will be available within this application and on the Moto website.