Privacy Policy
Privacy Notice
Introduction
Blackpool Transport Services regard your privacy as important; this notice governs the way in which your personal data is collected, what we use it for and who it will be shared with if this is appropriate. We only collect what personal data is necessary, keep it as long as necessary, and we will dispose of it in a secure manner. Some products or services collect and use data differently, this is detailed under each product area.
Personal data is any information that relates to an identifiable natural person. Examples of personal data include name and address.
Who is responsible for your data?
Blackpool Transport is the data controller for your personal data. Blackpool Transport’s Data Protection Officer is provided by Blackpool Council and can be contacted at [email protected] or in writing to Data Protection Officer, PO Box 4, Blackpool, FY1 1NA.
Your Rights
You have a number of rights related to the processing of your information, including the right to access information we hold about you, the right to erasure (the right to be forgotten) and the right to have inaccurate data corrected.
You can find out more about your rights on the information commissioner’s website or you can ask for information about these rights from the Data Protection Officer.
Complaints
If you are not happy with how Blackpool Transport has handled your personal information, you can complain to us to give us the opportunity to resolve this with you. You should contact the Data Protection Officer if you have a complaint.
Alternatively, you can complain to the Information Commissioner. Their contact details are: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 113 or by email to [email protected]
Website
Our Site may use "cookies" to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly. More detailed information about cookies used on our website is available here:[JC1]
Third-party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.
Advertising
Adverts appearing on our site may be delivered to Users by advertising partners, who may set cookies. These cookies allow the advert server to recognise your computer each time they send you an online advertisement to compile non-personal identification information about you or others who use your computer. This information allows advert networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This privacy policy does not cover the use of cookies by any advertisers.
Compliance with children's online privacy protection act
Protecting the privacy of the very young is especially important. We do not use children's data for marketing. When relying on ‘necessary for the performance of a contract, we consider the child’s competence to understand what they are agreeing to, and to enter into a contract.
Changes to this privacy policy
Blackpool Transport has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.
Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
Individual Privacy Notices[JC3]
Blackpool Transport App
Why do we collect your information?
The Blackpool Transport app has everything you need to get around on Blackpool Transport’s buses and trams. It allows you to plan your journey see live departures and times, have disruption updates and you can purchase your travel ticket. We need your information when you wish to purchase a ticket or receive a ticket as a gift.
What is our Lawful basis?
Article 6 (1)(b) ‘processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract;’
What types of information do we collect?
To purchase tickets BTS will need your debit / credit card details that include the card number, expiry, and secure card number as well as billing postcode and email address. Some tickets are gifted and do not require a payment method to be input and only require an email address.
Some tickets require age verification, this will require a photo of your face and a copy of your ID which contains your date of birth such as a driving licence or birth certificate. This will be machine-validated where possible.
Who will we share information with?
Blackpool Transport will not share your personal information unless disclosure is required by law.
How long will we keep your information?
Account and payment information is stored in accordance with financial regulations; this is currently six years from when the last payment transaction took place. Identification provided during the age verification process will be destroyed once validated, and photographs are erased once the account is closed, or age verification expired.
Closed Circuit Television and Audio Recording
Why do we collect your information?
When you travel with us CCTV data is automatically recorded on and around vehicles, additionally, audio is recorded on buses near the cab area. From time-to-time BTS Officers will board vehicles to deal with incidents and check ticket validity, these officers will have body-worn CCTV cameras which can be activated if the need arises. In addition to BTS Vehicles, all Blackpool Transport sites are covered by CCTV systems.
The purpose of Blackpool Transport operating a CCTV system is:
To provide a safe and secure environment for staff and customers to reduce the fear of physical abuse, intimidation, and crime, and assist in the identification, apprehension, and prosecution of offenders.
Protect BTS buildings and assets from theft, vandalism, or intrusion.
Assist in the prevention and detection of crime
To investigate incidents such as road traffic collisions, passenger injury events or complaints.
The incident lead monitoring of the quality of services provided by BTS.
What is our Lawful basis?
Article 6 (1) (f) - Legitimate Interests
What types of information do we collect?
CCTV captures images of people and their activity; these include passengers on BTS services and employees during their work duties.
Who will we share information with?
Images will not be shared with any other organisations or parties unless there is a clear lawful basis or an applicable exemption from the DPA2018 to do so and these are set out in a written request.
For example, regulatory bodies and enforcement agencies such as the Office of Rail and Road, Health and Safety Executive Road and the Office of the Traffic Commissioner may request CCTV for the purposes of investigating incidents involving vehicles, employees or members of the public.
How long will we keep your information?
CCTV data is automatically overwritten within 35 days or less dependent on system limitations if no incidents occur within that period.
CCTV, which is accessed on an incident-led basis, is stored securely for up to a period of three years.
Contactless Payments
Why do we collect your information?
We need this information to process your contactless payments for travel on our passenger services or if you request a refund.
What is our Lawful basis?
Article 6 (1)(b) ‘processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract;’
What types of information do we collect?
When you tap your payment card to board our services, Littlepay process your payment on our behalf using end-to-end encryption which is PCI DSS compliant. Data transmitted includes your payment card's personal account number “PAN”, payment card type and expiry.
Card information is securely stored, and access is limited to authorised Blackpool Transport employees, only the BAN and PAN number is made available. If you request a refund, we will need to confirm these numbers with you. You will never be asked to provide your PIN number or secure card number printed on the back of your card.
Who will we share information with?
Blackpool Transport will not share your personal information unless disclosure is required by law.
How long will we keep your information?
Payment information is stored in accordance with financial regulations; this is currently six years from when the payment transaction took place.
Private Hire
Why do we collect your information?
Blackpool Transport vehicles can be hired for private events such as conferences, school trips, excursions, sporting events and weddings.
If you book with us, we will need your contact information in case we need to contact you in relation to your booking. Payment information is also needed to facilitate payment for services requested.
What is our Lawful basis?
Article 6 (1)(b) ‘processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract.
What types of information do we collect?
We need your contact information and payment details to provide the service requested
Who will we share information with?
Blackpool Transport will not share your personal information unless disclosure is required by law or in the event of an incident.
How long will we keep your information?
Payment information is stored in accordance with financial regulations; this is currently six years from when the payment transaction took place.
Heritage Tour bookings/Online Shop/Real Drive experience
Why do we collect your information?
The Heritage Trams Service operates tours, an online shop and a `real drive` experience.
Therefore, we will need your personal information to send you goods, and tickets and take payment for these goods and services.
What is our Lawful basis?
Article 6 (1)(b) ‘processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract;’
What types of information do we collect?
For these services, we will need to collect the following: your name, phone number, email, postal address and debit or credit card information. For real drive experiences, you will need to complete a medical declaration due to the legal requirements of driving a tram.
Who will we share your information with?
Blackpool Transport will not share your personal information unless disclosure is required by law or in the event of an incident.
How long will we keep your information?
Card information is stored in accordance with financial regulations; this is currently six years from when the payment transaction took place. All other personal details will be destroyed in line with the destruction of financial information.
Photography / Videography
Why do we collect your information?
Blackpool Transport sometimes use images of employees or members of the public for promotional purposes. They can be used on direct marketing material, press releases, websites, internal & external documentation, social media, and other media outlets. If we wish to use your image your consent will be requested before use.
What is our Lawful basis?
Article 6 (1)(b) ‘processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract;’
What types of information do we collect?
Through a consent form, we collect your name, email, or telephone number. If you are under 18 consent from a parent or guardian will be required.
Who will we share information with?
Blackpool Transport will not share your personal information listed on the form unless consent to use your name has been given. Your image may be shared with third-party organisations to fulfil the required communications.
How long will we keep your information?
If you wish to withdraw consent for use of your image, you can contact the Marketing Department by email [email protected] to inform us. When we receive your notification, we will cease to use your image, but we may not always be able to immediately delete or recall use where this has already been published. We will retain images for a period of six years unless the image is in use in a current publication.
Direct marketing
Why do we collect your information?
We request your email address in order for us to send you direct marketing related to Blackpool Transport Services. We can collect this from you voluntarily through the Blackpool Transport website or via the Blackpool Transport on-board WiFi.
Legal basis
You have given us your consent[JC4]
What types of information do we collect?
We collect your name and email address alongside consent to send you marketing information.
Who will we share information with?
Your email address will be stored within a Mailchimp account which is managed by ‘We Are Buzz’. Information will not be shared or sold to third parties.[JC5]
Your email address will be stored within an email distribution database. Information will not be shared or sold to third parties.[JC6] [JC7]
How long will we keep your information?
Your personal information will be held until you opt-out of marketing emails. You can unsubscribe using the link in the footer of any email you receive from us, or by contacting us at [email protected].[JC8]
Customer Experience
Why do we collect your information?
You may wish to contact us directly via telephone, email, live chat or social media to enquire about our services, request a refund, raise an issue or make a suggestion. Freshdesk is employed to collate information securely from communication channels to enable an effective response.
What types of information do we collect?
We collect the information necessary to satisfy your enquiry which may include your name, address, email address, phone number, date of birth and payment details. Other information may be requested from you dependent on the nature of the enquiry.
Legal basis
Article 6 (1)(b) ‘processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract;’
Who will we share information with?
Blackpool Transport will not share your personal information unless disclosure is required by law or in the event of an incident.[JC9]
How long will we keep your information?
Your information will be held for six years from the date of enquiry.
Recruitment
Why do we collect your information?
We collect and process your data for the purpose of keeping records of the recruitment process, assessing the candidate’s suitability for employment including the right to work and processing the outcome of the recruitment process.[JC10]
We may process information about your ethnic origin, disability, sexual orientation, health or religion or belief, this is for equal opportunities monitoring. Our processing of these types of data will be carried out to ensure you or us can meet our obligations or exercise our rights under law related to employment or (only where applicable) to enable us to establish, exercise or defend legal claims.
What types of information do we collect?
We collect your name, date of birth, phone number, address, email address, previous employment history, qualifications, disability, emergency contact information, equal opportunities monitoring information, your entitlement to work in the UK and any other information you provide to us on the application form or as part of the recruitment process.
Legal basis
Contract: the processing is necessary for the performance of a contract
Blackpool Transport are allowed to ask for this information as we have a duty to ensure your right to work in the UK and to comply with safeguarding requirements such as DBS checks, qualification checks and reference checks.
We will process special category data under Article 9(b) of the GDPR, ‘employment, social security and social protection’.
Who will we share information with?
Information will not be shared with any third parties except for reference requests or regulators if required to do so to comply with the law.
How long will we keep your information?
If unsuccessful your application is held on file for a period of twelve months. If successful, your application will be held alongside your employment records and comply with internal retention schedules.
Incident Forms
Why do we collect your information?
In the event of an incident, Blackpool Transport has a statutory duty to investigate and record all incidents. Information collected will be used to investigate and record incidents on our internal system. This may include members of the public, contractors, suppliers and employees.
What types of information do we collect?
We collect your name, date of birth, address, nature of injury or damage to possession and photographic evidence.
Legal basis
Legal obligation: the processing is necessary for us to comply with the law
Who will we share information with?
Blackpool Transport may need to share information with the Health & Safety Executive, Legal Services, insurers, Police or regulatory bodies.
How long will we keep your information?
Information is held for a period of six years from the date of the incident.