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Privacy Notice and Cookie Policy

This notice explains how and why Hillingdon Community Transport uses personal information from service users, organisations and other members of the public.

It is regularly reviewed and updated in line with the services we deliver and the suppliers that we use. The date that it was last modified is at the end of this notice. We recommend that you check our website periodically for any changes made to this privacy notice. If we make any significant changes that could affect you, we will send you notification.

When we refer to “we” or “us” in this notice we are referring to Hillingdon Community Transport (Charity Reg No 292513, Company limited by guarantee No 1903280).

In this notice, we use the term personal information to mean any information from which you can be identified. This might include your name, your home address, your email contact details, or your telephone number. Personal information does not include information where your identity has been removed (i.e. anonymous data).

We use the term special categories of personal information to mean information about your ethnic origin, your religious beliefs and/or your health.

Personal information we collect and use

1. Individual Transport Services

We provide a range of transport services to individuals. This section of our privacy notice explains how we collect and use personal information from people who use our services.

When you contact us about these services, we will collect some personal information from you (for example your name, address, email contact details, telephone number).

During the course of providing these services to you, we may also need to collect additional information about you and/or any other individuals you tell us about (for example emergency contact details, payment information and/or proof of ID).

We will only collect and use your personal information in this way if:

Depending on the nature of the services we provide to you, we may also ask you to give us special categories of personal information about you (for example, information about your health or ethnicity). We will collect and use this kind of information:

We use a third-party, Shaunsoft Community Transport Software, to supply and support our community transport booking system. For more information, please see Shaunsoft’s privacy notice.

2. Home to School Transport Services

When schools or local authorities contract with us to provide home to school transport services, the school/local authorities may provide us with personal information about the children who will be using our services each day. This will include personal information (names, addresses, dates of birth, and emergency contact details). Where relevant and necessary, we may also receive information about ethnic origin, medical needs, health conditions, mobility issues, language or communication requirements and/or disabilities. In this regard, we will be acting as a data processor on behalf of the school or local authority and it is the responsibility of the contracting body to ensure that it has appropriate consents or authorisations to transfer this information to us.

We will share this information with our drivers for the purposes of delivering the home to school transport services and we will keep this information on record to comply with safeguarding best practice (see ‘Data Retention’ below). We are satisfied that we have a legitimate interest to collect, use and retain this information for the purposes of delivering our home to school transport services.

3. Group Transport Services Members

If you register with us as a charity, community group or voluntary organisation in order to benefit from subsidised minibus services (with or without a driver), we will collect and record personal contact information for individual(s) at the organisation (such as name, address, email contact details and telephone number).

We will only collect and use personal information in this way if:

If we provide minibus services with a driver we may also obtain personal information about your passengers such as their name, address and telephone numbers for pick-up and drop-off purposes. In this regard, we will be acting as a data processor on behalf of the organisation and it is the responsibility of the organisation to ensure that it has appropriate consents or authorisations for individuals to transfer this information to us. We will not retain this passenger list information any longer than is necessary to fulfil the transport booking(s).

4. Training

When you register to take part in our training services we will collect your name, address, email contact details and telephone number. For certain training courses, you will also need to provide us with your date of birth, national insurance number, driving licence information. This information is necessary in order for us to enter into or perform our contract with you to provide the training. We will ask for your consent to collect information about any medical conditions that may affect your ability to drive.

We will share your details with the following third-parties when you undertake certain training courses with us:

5. Monitoring and Development

We use anonymised information to carry out research into the use of our services and our effectiveness. In some circumstances, we may share the results of this research with third parties such as organisations that fund our work but this information will always be anonymised so that it can no longer be associated with you.

6. Queries and complaints

If you send a query or complaint to us, we will use the personal information you provide to us (for example, your name and the name(s) of any other individuals involved) in order to process your query or complaint and respond to you. Where we consider it necessary or appropriate, we will share this information with third parties such as our insurers, the Information Commissioner’s Office, the Financial Conduct Authority, a relevant Local Authority, the Department of Transport and/or the Transport Commissioner.

7. Sharing personal information

We only ever use your personal data if we are satisfied that it is lawful and fair to do so. We will never sell your personal data or share it with third parties who might use it for their own commercial purposes.

We will only disclose your personal information to third parties if:

8. Data Security

We have appropriate security measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

9. Data retention

Our default retention period for personal data is 7 years from the date we receive the information unless otherwise specified by law. We keep children’s personal data for 7 years from the date of their 18th birthday and we keep personal data that may be required for safeguarding purposes for 35 years from the date of collection (as considered reasonable by High Court ruling 2015).

These retention periods may be extended or reduced if we deem it necessary, for example, to defend legal proceedings or if there is an on-going investigation relating to the information.

We review the personal data (and the categories of personal data) we hold on a regular basis to ensure the data we are holding is still required and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take steps to correct or delete the data.

Visitors to our Website

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Your rights

Under certain circumstances, by law, you have the right to:

If you want to access, correct or request restriction or erasure of your personal information, or to object to us using your personal data, or request that we transfer a copy of your personal information to another party, please contact hct@hillingdon.gov.uk or 01895 277773. We may ask you to put your request in writing to us.

If you have given your consent to us processing your personal information, you have the right to withdraw your consent at any time. To withdraw your consent, please contact hct@hillingdon.gov.uk or 01895 277773. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your data securely.

Queries and Complaints

Stephen Charlton, the General manager, oversees compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Steve:

Published: 24/05/2018 By Hillingdon Community Transport.