Privacy notice - English National Concessionary Travel Scheme
Overview
This privacy notice covers applications and change notifications for the English National Concessionary Travel Scheme (ENCTS), which includes older person’s and disabled person’s bus passes.
East Sussex County Council takes data protection seriously. Please be assured that your information will be used appropriately in line with data protection legislation, will be stored securely and will not be processed unless the requirements for fair and lawful processing can be met.
What information is being used?
- name
- address
- date of birth
- gender
- telephone number (optional)
- email address (optional)
- photograph
- National Insurance number (optional)
- proof of age (older person applications only)
- proof of disability (disabled applications only)
- location data (anonymous, unless in the circumstances set out in the legal basis)
- financial data
How will your information be used?
It will be used to determine eligibility for the scheme and enable East Sussex County Council (the Council) to provide a concessionary bus pass for use on local bus services throughout East Sussex and England.
We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing. Your information is never sold for direct marketing purposes.
Our staff are trained to handle your information correctly and protect your confidentiality and privacy.
Your information is processed in the UK or in a country with an adequacy agreement with the UK.
What is the legal basis for processing your information?
We will explicitly seek your consent to process your personal data (article 6(1)(a) GDPR) and sensitive (health) data (article 9(2)(b) GDPR. Submission of the application form and supporting evidence is required in order to apply. Consent to process this information will be given when you apply. Once an application is made, the Council has statutory authority to process the data under the Concessionary Bus Travel Act 2007 and associated to the concessions as defined within the Transport Act 2000 (Article 6(1)(e)). Your financial data will be processed with your consent to administer the purchase of replacement passes.
Smart cards allow details of where and when your pass has been used to be recorded anonymously. The Council may identify you from this data in the following circumstances:
- Analysing usage for carrying out renewals (Article 6(1)(e) GDPR)
- Identifying fraudulent use (Sch. 8 Para. 8(1)(b)(ii) Data Protection Act 2018)
- Safeguarding vulnerable individuals (Sch. 8 Para. 4(1) Data Protection Act 2018)
How long will your information be kept for?
Please see the Records Retention and Disposal Schedule for the Council.
Sharing your information
Any sharing of personal data is always done:
- on case-by-case basis
- using the minimum personal data necessary
- with the appropriate security controls in place
- in line with legislation.
Information is only shared with those agencies and bodies who have a "need to know" or where you have consented to the sharing of your personal data to such persons.
We may use the information we hold about you to assist in the detection and prevention of crime or fraud. We may also share this information with other bodies that inspect and manage public funds.
Your rights
Under data protection legislation, you have the right:
- to be informed why, where and how we use your information
- to ask for access to your information
- to ask for your information to be corrected if it is inaccurate or incomplete
- to ask for your information to be deleted or removed where there is no need for us to continue processing it
- to ask us to restrict the use of your information
- to ask us to copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information
- to object to how your information is used
- to challenge any decisions made without human intervention (automated decision making)
Please visit data subject rights for further details.
How to find out more or complain
Should you have any further queries on the uses of your information, please speak directly to our service:
Transport Hub
Tel: 01273 335075
Email: Systems pts
To complain about the use of your information, please contact our Customer Services Team or our Data Protection Officer.
Further information on making a complaint.
You can also contact the Information Commissioner's Office (ICO) for further information or to make a complaint:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Phone: 0303 123 1113 (local rate)