
Concessionary Card Privacy Statement
About the Concessionary Travel Card Scheme Each local authority in Wales is responsible for providing concessionary travel cards to individuals eligible to receive them. The way these cards are provid...
Each local authority in Wales is responsible for providing concessionary travel cards to individuals eligible to receive them. The way these cards are provided is changing.
Until September 2019, each local authority is solely responsible for processing applications for concessionary travel cards. When you apply, your information is entered into a database, which is administered nationally by Welsh Government and Transport for Wales.
From September, the administration of concessionary travel cards will also be carried out on an all-Wales basis by Transport for Wales, which is owned by Welsh Government and has responsibility for transport matters in Wales. A new, national system will allow applications to be made online.
Your local council, Welsh Government and Transport for Wales each have responsibilities to ensure that your information is used appropriately and kept secure. This privacy notice sets out how we will collect information about you when you apply for a concessionary travel card and each time you use your card.
Transport for Wales respects your privacy and is committed to protecting information about you (we call this your personal information or your personal data). This privacy policy informs you how we look after your personal data when you apply for a concessionary travel card and when you use your concessionary travel card and tells you about your privacy rights and how the law protects you.
Transport for Wales may update this policy from time to time. We will let you know if there are any significant changes which affect you. This policy is effective from 1st June 2019.
Transport for Wales, local authorities and Welsh Government are each responsible for the personal data they collect from or about you. In this notice, the terms "TfW", "we", "us" or "our" refer to Transport for Wales. Where there different are responsibilities for local authorities or Welsh Government, we will tell you.
Each local authority, Transport for Wales and Welsh Government have appointed a data protection officer (DPO) who is the individual responsible for overseeing questions in relation to this privacy policy in each organisation. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the TfW DPO in the first instance using the details set out below.
The contact details of the DPOs for your local authority and for Welsh Government can be found on their websites.
Postal address: Data Protection Officer, Transport for Wales, South Gate House, Wood Street, Cardiff, CF10 1EW
E-mail: contact@tfw.gov.wales
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.
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).
If you apply for a concessionary travel card, the following different kinds of personal data about you may be collected, used and stored:
Depending on when you apply, this information may be collected by your local authority or directly by Transport for Wales.
If you apply for a concessionary travel card online via www.tfw.wales/travelcards, TfW will also collect other information about you. Please refer to our privacy statement at http://tfw.gov.wales/privacy-statement for more details.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose, including planning transport and budgeting. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Different methods are used to collect data from and about you including through:
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:
Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
The following terms are used in the table below:
Purpose/Activity | Types of data | Lawful basis |
---|---|---|
To process your application for a Concessionary Travel Card |
(a) Identity (b) Contact (c) Marketing and Communications |
Necessary for the performance of our public task (to administer the concessionary travel card scheme on behalf of transport authorities) |
To send email/text updates or communicate updates related to your Concessionary Travel Card or application by phone |
(a) Identity (b) Contact (c) Marketing and Communications |
(a) Necessary for the performance of our public task (to administer the concessionary travel card scheme on behalf of transport authorities) (b) Necessary for our legitimate interests (to keep in touch with our customers and provide updates) |
To contact you about your application to resolve queries |
(b) Contact |
(a) Necessary for the performance of our public task (to administer the concessionary travel card scheme on behalf of transport authorities) (b) Necessary for our legitimate interests (to provide excellent customer service and contact customers where they have raised queries) |
To contact you about usage of your Concessionary Travel Card |
(a) Identity (b) Contact |
Necessary for the performance of our public task (to administer the concessionary travel card scheme on behalf of transport authorities) |
To reimburse operators for Concessionary Travel and protect against operator fraud |
(a) Card number (b) Journey details |
(a) Necessary for the performance of our public task (to administer the concessionary travel card scheme on behalf of transport authorities) (b) Necessary to comply with our legal obligations to prevent fraud |
To administer the Concessionary Travel scheme, including analysis of use and potential modifications to the scheme, and counter fraud initiatives |
(b) Contact |
(a) Necessary for the performance of our public task (to administer the concessionary travel card scheme on behalf of transport authorities) (b) Necessary to comply with our legal obligations (to prevent fraud and misuse of the scheme) |
To communicate changes to Concessionary Travel scheme terms and conditions |
(b) Contact |
Necessary for the performance of our public task (to administer the concessionary travel card scheme on behalf of transport authorities) |
To validate your identity and conduct checks to verify your continued eligibility for Concessionary Travel |
(a) Identity (b) Contact |
(a) Necessary for the performance of our public task (to administer the concessionary travel card scheme on behalf of transport authorities) (b) Necessary to comply with our legal obligations (to prevent fraud and misuse of the scheme) |
To make suggestions and recommendations to you about services or news stories that may be of interest to you, both for bus services and wider TfW services such as rail |
(a) Identity (b) Contact (c) Technical (d) Profile and marketing preferences |
Necessary for our legitimate interests (to develop our services) |
We will get your express opt-in consent before we share your personal data with any company outside TfW, Welsh Government and local government for marketing purposes.
You can ask us or third parties to stop sending you marketing messages or email updates at any time by following the opt-out links on any marketing message sent to you through the TfW website (concessionary travel cards section) or by contacting us at any time by email at contact@tfw.wales.
We may have to share your personal data with the parties set out below for the purposes set out in the table above:
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.
Some of our external third party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
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 may refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.