Privacy Policy
Introduction
Welcome to Warrington’s Own Buses privacy policy.
If you are an individual:
This privacy notice applies to information held about you. It explains what information we collect about you, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it, and what steps we’ll take to make sure it stays private and secure.
Wherever we say “you” or “your” this means you as our customer.
If you are a business:
This privacy notice applies to information held about you and the individuals connected to your business by us as data controllers, as described below. It explains what information we collect about you and individuals who are connected to your business, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it, and what steps we’ll take to make sure it stays private and secure.
Wherever we say “you” or “your” this means you and any individuals connected to your business. An individual connected to your business could be any director, officer or employee of a company, partners or members of a partnership, any substantial owner, controlling person, or beneficial owner, your attorney or representative, agent or nominee, or any other persons or entities whom you have a relationship with that’s relevant to your relationship with us. Warrington’s Own Buses respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Warrington’s Own Buses collects and processes your personal data, including any data you may provide when you purchase a product and/or engage our services.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Warrington’s Own Buses is the trading name of Warrington Borough Transport Limited, which is part of a group of companies made up of different legal entities, as follows:
Warrington Borough Council
Warrington 2000+
Warrington 2000 (Regeneration) Ltd
Warrington Borough Transport Limited
Coachlines of Warrington Limited
This privacy policy is issued on behalf of the Warrington’s Own Buses Group so when we mention "Warrington’s Own Buses", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Warrington’s Own Buses Group responsible for processing your data. Warrington Borough Transport Limited is the controller and responsible for this website.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Warrington Borough Transport Limited
Email address: [email protected]
Postal address: Warrington’s Own Buses, Wilderspool Causeway, Warrington, WA4 6PT
Telephone number: 01925 634 296
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
CCTV data includes images collected of you either at our premises or in the vicinity of our vehicles.
Data that you have provided to us.
We do not knowingly collect any Special Categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
It is possible that we collect details about your race and ethnicity in the following circumstances:
When processing CCTV images.
When processing passports or other identification documents.
In relation to processing CCTV, this is necessary for reasons of substantial public interest in order to:
prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
assist in the personal safety of staff, visitors and other members of the public and to act as a deterrent against crime;
to support law enforcement bodies in the prevention, detection and prosecution of crime; and
assist in the defence of any civil litigation.
In relation to processing passports or other identification documents, this may be necessary in relation to travel bookings so that we can fulfil the product or service which you have purchased from us. In this instance, we would need to obtain your explicit consent for us to process such documentation.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
CCTV operations. We may record and store information about you from CCTV at any of our premises or attached to our vehicles.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Contact, Financial and Transaction Data from providers of technical, payment and delivery services .
Identity and Contact Data from data brokers or aggregators, and travel brokers and/or agents .
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order and carry out your instructions including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Carry out travel arrangements such as picking up and dropping off
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) Investigating and resolving complaints
(d) Recovering money which you owe
(a) Identity
(b) Contact
(c) Profile
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business including:
(a) troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
(b) undertaking risk management
(c) protecting our legal rights and complying with our legal obligations
(a) Identity
(b) Contact
(c) Technical
(d) CCTV
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
During these unprecedented times it is more important than ever to protect your health and safety whilst travelling on our services. Accordingly, your data may be shared with a public health authority, a contract tracing scheme or a contracted customers (including, but not limited to, Warrington & Vale Royal College, Cronton & Riverside College, Priestley College & Lymm High School). The Company will consider a request for information from these bodies and will only transfer personal data to the extent that it proportionate to do so in order to protect your own safety, that of other passengers and those that you may come into close contact with, including family members.
The data will only be shared where there is reasonable cause to do so as identified by government guidance (in force at the time) in order to prevent the spread of coronavirus and/or to notify in the event a positive case of Covid-19 has been identified on the bus you travelled on.
(a) Identity
(b) Contact
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
Subcontractors who we might engage to carry out some or all of the services we provide to you.
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Contracted customers such as schools and colleges for the purposes of complying with Covid Secure policies and track and trace.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
Some data we are required to maintain for a minimum period of time, for example:
CCTV video recordings on our premises are kept for four weeks, then they are deleted unless they are required for potential legal claims, in which case they will be kept for longer. CCTV on our vehicles expires after three weeks, but if it has been downloaded for potential legal claims, then it is kept for longer.
Customer invoices (comprising names, addresses, telephone numbers, email addresses, payment details) for a minimum of seven years for tax purposes, or longer where it is necessary for the establishment, exercise or defence or legal claims.
We collect the following customer information through our Tough & Go! Smart Cards:
The direct debit details are stored securely for twelve months, after which they are then shredded.
Other details such as login name, date of birth and address are kept indefinitely so that our customers can top up their smart cards forever and continue receiving services from us. If, at any point, a customer wants to stop using their smart card and wants us to delete their data, they can contact us and let us know.
ID documents are used in order to verify a customer’s identity as part of the application process. Once they have been used, the details are deleted.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us via [email protected] or 01925 634 296.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Welcome to Warrington’s Own Buses privacy policy.
If you are an individual:
This privacy notice applies to information held about you. It explains what information we collect about you, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it, and what steps we’ll take to make sure it stays private and secure.
Wherever we say “you” or “your” this means you as our customer.
If you are a business:
This privacy notice applies to information held about you and the individuals connected to your business by us as data controllers, as described below. It explains what information we collect about you and individuals who are connected to your business, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it, and what steps we’ll take to make sure it stays private and secure.
Wherever we say “you” or “your” this means you and any individuals connected to your business. An individual connected to your business could be any director, officer or employee of a company, partners or members of a partnership, any substantial owner, controlling person, or beneficial owner, your attorney or representative, agent or nominee, or any other persons or entities whom you have a relationship with that’s relevant to your relationship with us. Warrington’s Own Buses respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Warrington’s Own Buses collects and processes your personal data, including any data you may provide when you purchase a product and/or engage our services.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Warrington’s Own Buses is the trading name of Warrington Borough Transport Limited, which is part of a group of companies made up of different legal entities, as follows:
Warrington Borough Council
Warrington 2000+
Warrington 2000 (Regeneration) Ltd
Warrington Borough Transport Limited
Coachlines of Warrington Limited
This privacy policy is issued on behalf of the Warrington’s Own Buses Group so when we mention "Warrington’s Own Buses", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Warrington’s Own Buses Group responsible for processing your data. Warrington Borough Transport Limited is the controller and responsible for this website.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Warrington Borough Transport Limited
Email address: [email protected]
Postal address: Warrington’s Own Buses, Wilderspool Causeway, Warrington, WA4 6PT
Telephone number: 01925 634 296
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
CCTV data includes images collected of you either at our premises or in the vicinity of our vehicles.
Data that you have provided to us.
We do not knowingly collect any Special Categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
It is possible that we collect details about your race and ethnicity in the following circumstances:
When processing CCTV images.
When processing passports or other identification documents.
In relation to processing CCTV, this is necessary for reasons of substantial public interest in order to:
prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
assist in the personal safety of staff, visitors and other members of the public and to act as a deterrent against crime;
to support law enforcement bodies in the prevention, detection and prosecution of crime; and
assist in the defence of any civil litigation.
In relation to processing passports or other identification documents, this may be necessary in relation to travel bookings so that we can fulfil the product or service which you have purchased from us. In this instance, we would need to obtain your explicit consent for us to process such documentation.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
CCTV operations. We may record and store information about you from CCTV at any of our premises or attached to our vehicles.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Contact, Financial and Transaction Data from providers of technical, payment and delivery services .
Identity and Contact Data from data brokers or aggregators, and travel brokers and/or agents .
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order and carry out your instructions including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Carry out travel arrangements such as picking up and dropping off
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) Investigating and resolving complaints
(d) Recovering money which you owe
(a) Identity
(b) Contact
(c) Profile
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business including:
(a) troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
(b) undertaking risk management
(c) protecting our legal rights and complying with our legal obligations
(a) Identity
(b) Contact
(c) Technical
(d) CCTV
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
During these unprecedented times it is more important than ever to protect your health and safety whilst travelling on our services. Accordingly, your data may be shared with a public health authority, a contract tracing scheme or a contracted customers (including, but not limited to, Warrington & Vale Royal College, Cronton & Riverside College, Priestley College & Lymm High School). The Company will consider a request for information from these bodies and will only transfer personal data to the extent that it proportionate to do so in order to protect your own safety, that of other passengers and those that you may come into close contact with, including family members.
The data will only be shared where there is reasonable cause to do so as identified by government guidance (in force at the time) in order to prevent the spread of coronavirus and/or to notify in the event a positive case of Covid-19 has been identified on the bus you travelled on.
(a) Identity
(b) Contact
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
Subcontractors who we might engage to carry out some or all of the services we provide to you.
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Contracted customers such as schools and colleges for the purposes of complying with Covid Secure policies and track and trace.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
Some data we are required to maintain for a minimum period of time, for example:
CCTV video recordings on our premises are kept for four weeks, then they are deleted unless they are required for potential legal claims, in which case they will be kept for longer. CCTV on our vehicles expires after three weeks, but if it has been downloaded for potential legal claims, then it is kept for longer.
Customer invoices (comprising names, addresses, telephone numbers, email addresses, payment details) for a minimum of seven years for tax purposes, or longer where it is necessary for the establishment, exercise or defence or legal claims.
We collect the following customer information through our Tough & Go! Smart Cards:
The direct debit details are stored securely for twelve months, after which they are then shredded.
Other details such as login name, date of birth and address are kept indefinitely so that our customers can top up their smart cards forever and continue receiving services from us. If, at any point, a customer wants to stop using their smart card and wants us to delete their data, they can contact us and let us know.
ID documents are used in order to verify a customer’s identity as part of the application process. Once they have been used, the details are deleted.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us via [email protected] or 01925 634 296.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.