Data controller details
The Company is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: [email protected]
Data protection principles
In relation to your personal data, we will:
• Process it fairly, lawfully and in a clear, transparent way.
• Collect your data only for reasons that we find proper for the course of your booking in ways that have been explained to you.
• Only use it in the way that we have told you about.
• Ensure it is correct and up to date.
• Keep your data for only as long as we need it.
• Process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.
Types of data we process
We hold many types of data about you, including;
• Your personal details including your name, address, email address, phone numbers
How we collect your data
We collect data about you in a variety of ways including over the website or via email. Further. Other details may be collected directly from you in the form of official documentation.
Personal data is kept in personnel files or within the Company’s customer and IT systems.
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
• In order to complete the booking form, recruitment, shopping, and donations process.
• In order to carry out legally required duties.
• In order for us to carry out our legitimate interests.
• To protect your interests and;
• Where something is done in the public interest.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data. We will seek your consent in retaining data to offer other services which we believe may be of interest to you. You are free to withhold your consent to this and there will be no consequences for withholding consent.
Special categories of data
Special categories of data are data relating to your / group members;
Although we may find out the below data as part of CT Passengers booking process, we do not record who this is regarding individually;
• Ethnic origin
• Religious beliefs
We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
• You have given explicit consent to the processing
• We must process the data in order to carry out our legal obligations
• We must process data for reasons of substantial public interest
• You have already made the data public.
We will use your special category data:
• For the purposes of equal opportunities monitoring
• To support our claim for BSOG (Bus Service Operator Grant)
• To determine reasonable adjustments to support passengers with disabilities
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
Criminal conviction data
We will only collect criminal conviction data and where the law permits us. We use criminal conviction data to satisfy our legal obligation to safeguard colleagues and service users.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out the requested action made by you. Whilst you are under no obligation to provide us with your data, we may not be able to satisfy the requirement of your requests.
Sharing your data
Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties with regard to payments. This includes, for example, the Finance team at site and those based at our National Office. For CT Passenger bookings, we will also share your details with our insurance provider to ensure you are covered at the time of the hire and to progress if a claim is required.
We do not share your data with bodies outside of the European Economic Area.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such including robust data management structures.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for. Retention periods can vary depending on why we need your data, as set out below:
Data type Retention limit
Booking Forms 3 years post the journey date
Financial Data – Name, address, organisation name, telephone number, email 7 financial years after the journey date
Insurance Data – Name, address, organisation name, telephone number, email, details of incident, witness statements Indefinitely
Marketing Data - Name, address, organisation name, telephone number, email, history of previous bookings No marketing consent received - 18 months post the journey date
Marketing consent received - Indefinitely – until consent revoked
Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are, the right:
• To be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice.
• Of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
• For any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.
• To have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
• To restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
• To portability. You may transfer the data that we hold on you for your own purposes.
• To object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests.
• To regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above or have any concerns as to how your data is processed, please contact [email protected]