INTRODUCTION
Abellio East Anglia Limited “AEA” is committed to protecting and respecting your privacy when you use our services.
This Privacy Policy explains:
- What personal data we collect from you when you use our website, apps, visit our stations, contact us, use our services, or WiFi;
- How we will collect and use that information;
- How we keep information secure; and
- How you can contact us if you wish to exercise any of your rights in relation to the information or make a complaint.
CONTENTS
- Information we may collect from you
- How we use your information
- Sharing or disclosure of your information
- Types of information we collect
- Website visits and purchases
- CCTV
- Ticket office purchases
- Revenue Protection and Penalty Fares
- Customer Relations database
- Station Help and Assistance Information Points
- Station and Train WiFi
- Personal data to aid recruitment for jobs in AEA
- Where we store your personal information
- Information Security
- Your rights
For the purposes of the General Data Protection Regulation Act 2018, the data controller is:
Abellio East Anglia Limited
11th Floor
One Stratford Place
Montfitchet Road
London
E20 1 EJ
Our Data Protection Manager contact details (DPM) are:
Email: [email protected]
Address:
The Hub
Finance Department
Colchester North Station
North Station Road
Colchester
CO1 1JS
Our nominated Group Data Protection Officer (DPO) is:
Data Protection Manager
Abellio UK HQ
36 Renfield St
5th Floor, The Culzean Building
Glasgow
G2 1LU
Email: [email protected]
More information about the General Data Protection Regulation and all related and subordinate legislation as amended or re-enacted from time to time can be found on the Information Commissioners website.
The Information Commissioner is our regulator for data protection matters.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process information about you when you:
- buy tickets;
- travel on our services;
- visit our stations or car parks;
- use our website, apps or Wi-Fi;
- buy a product from us or make a sales enquiry;
- contact customer relations;
- enter a competition; or
- sign up to receive updates or marketing.
- An accident or injury occurs at our stations or on our trains.
- Apply for a job/vacancy at AEA.
We collect information such as your contact details, ticket purchases, stations visited (for example for charging the correct fares on smart cards), payment and refund details. We may require additional details for some services, such as your age for age restricted tickets. This information is generally provided by you.
Sometimes we obtain details from third parties, for example if our Group structure changes or for legitimate business reasons.
HOW WE USE YOUR INFORMATION
We will only use the information you provide as permitted by Data Protection Law (DPL). Our reason(s) for using your data will vary depending on: how you contact us, use our services, the consent you have given, our legitimate interests, or legal obligations we may have. Reasons for use of your data include:
- To provide you with the service - things like carrying out our obligations arising from any contracts - selling tickets, making and taking payments. We mostly rely on the legal ground of contractual performance to process your data, but sometimes the data is also used for our legitimate interests of customer service, health and safety, improving our services and other legal obligations, like providing information to our regulators
- To provide you with details of our services, information about travelling and customer service - this is based on our legitimate interests, to run train and associated services. Sometimes it is part of our contract or our other legal obligations
- To provide you with details of promotions and offers which we feel may interest you; this is based on our legitimate interests to try and sell more train tickets when you have given consent for us to contact you and you have an absolute right to ask us to stop sending marketing emails/SMS
- To run our services and improve them - we believe in investing in our railway services, not just to benefit passengers but also the wider community, environment, and economy. There are lots of activities we do to achieve this, some are administrative and we also do things like monitoring passenger numbers, and popular stations, improving technology to help plan journeys - make money, run our services safely and be a good employer - we call these our legitimate interests. Some of these are also covered in our legal obligations, not just to customers, but under Franchise Contracts, the Department for Transport or Regulators. Some data is also shared to run interoperable services – in the Rail Industry this is overseen by the Rail Delivery Group - this is how you are able to use a ticket on a train and tube for example, or use a rail Discount card.
- For your safety and security.
- For fraud and crime prevention.
- To enhance your experience of our website, as described in our cookie policy.
- To run competitions
We are part of a Group of Companies and share administrative services and support. Your data may therefore be shared with other Group companies where appropriate. We are also required to pass certain customer data to successor franchisees, Secretary of State or Department for Transport.
Our Legitimate Interests
Running our business and Group businesses, in a safe and socially and environmentally responsible manner, efficiently, to provide sustainable and high quality, locally focused passenger transport services, improve and expand our services, be a leading employer in the transport sector, investing in and developing our staff, operating with financial discipline and reducing crime and fraud to provide shareholder value, provide and improve customer services.
SHARING OR DISCLOSURE OF YOUR INFORMATION
We will only share or disclose your information as set out in this Policy or in accordance with DPL and will obtain your consent where we are required to do so. We will only use third parties to process information where we are satisfied that they comply with these standards and can keep your data secure.
Due to the nature of the services we provide, we process a large range of data, in a manner of ways, across a number of solutions. Accordingly, it was deemed impractical to set out the details of all the third parties that we may share your data with below. You can find out more about the information we collect and how we use, share or disclose it below or by contacting us at [email protected] We may share or disclose information for the following reasons:
- We use data processors to provide or assist with some of our services, for example, the processing of bookings. Where we do so, they must agree to strict contractual terms and to keep your data secure;
- Where we share data across our Group Companies, this is only in accordance with a written data sharing agreement;
- To operate interoperable services - this includes use of some shared systems and processors, by the rail industry generally and overseen by the Rail Delivery Group;
- To respond to your complaints or administer requests you have made, either to us or another regulatory body such as the Department for Transport; Passenger Focus, London Travelwatch, the Rail Complaints Ombudsman or other Train Operating Companies (TOCs);
- To process payment card transactions;
- To comply with requests from the British Transport Police under an Information Sharing Protocol, ensuring that any disclosure is lawful;
- To comply with the police or other law enforcement agencies for the purposes of crime prevention or detection, these are dealt with on a case-by-case basis, under a specific Information Sharing Protocol, to ensure that any disclosure is lawful;
- To comply with other legal obligations for example, relating to crime and taxation purposes or regulatory activity;
- To protect our legitimate business interests, as outlined above;
- Where required because of the sale, merger, or acquisition of business assets. As the Railway Industry is run on a system of franchises, we are required to transfer our customer data to a successor franchise, or the Secretary of State, this is so that they can take over and continue the running of the railway service;
- In respect of information provided to us for marketing purposes only (including freely given consent), to the Department for Transport and/or any successor operator of the rail franchise in order that they may contact you for marketing purposes in the event that we cease to operate this rail franchise;
- If you have agreed (via freely given consent) to receive information for competition, promotion, survey or research purposes, we may share your contact details with a limited number of parties, but only for the reasons you have agreed to in the terms and conditions of the purpose; and
- Where you have consented, to share with other members of the Abellio Group UK (“Abellio”), of which we are a member, where Abellio has any services, promotions and offers which we feel may interest you. Details of other members of Abellio can be found here.
TYPES OF INFORMATION WE COLLECT
CCTV
Camera systems we operate
Our CCTV is used to capture, record and monitor images of what takes place at our stations and car parks and on our trains, in real time. In limited circumstances, we use body worn cameras which make audio visual recordings.
Depending on the type of camera, images are recorded on video tape (analogue) or as digital information. Cameras can be fixed or set to scan an area. In some circumstances, they can be operated remotely by controllers.
Why we operate CCTV cameras
We operate CCTV for the following purposes:
- Health and safety of employees, passengers and other members of the public;
- Crowd management; and
- Prevention and detection of crime and anti-social behaviour.
Camera locations
We operate cameras at the stations and car parks we manage and on some of the trains that we run.
We operate cameras at some of the stations and car parks across our network, for a full list of stations and car parks and operators please visit the Greater Anglia website.
Network Rail and other TOCs operate the cameras at some stations that our services stop at. These are shown below:
- London Liverpool Street
- Peterborough
- Stratford
- Kings Lynn
- Seven Kings
- Gidea Park
- Harold Wood
- Romford
- Brentwood
- Edmonton Green
- Hackney Downs
We operate CCTV on some of the trains that we run.
Length of time CCTV footage is kept
CCTV footage at stations and on train is generally held for a maximum of 12 months from the time of recording.
Recordings from body worn cameras are generally held for 28 days, unless required for legitimate business reasons.
How to access your CCTV personal data
You can request copies of images or footage of yourself by making a Subject Access Request to [email protected]
Disclosing CCTV/personal data to the police
At our discretion, we may disclose CCTV/personal data in response to valid requests from the police and other statutory law enforcement agencies.
Before we authorise any disclosure, the police have to demonstrate that the CCTV/personal data is necessary to assist them in the prevention or detection of a specific crime, or in the apprehension or prosecution of an offender.
Requests from the police are dealt with on a case-by-case basis to ensure that any such disclosure is lawful in accordance with the DPL.
Sharing CCTV footage with other third parties
Some of our CCTV infrastructure is shared with the British Transport Police, Local Authorities, Network Rail, and Car Park operators under formal data sharing agreement.
In certain agreed circumstances, they may take control of a limited number of cameras and use them for activities such as the prevention and detection of crime and anti-social behaviour, policing major events and crowd control. AEA is not responsible for the CCTV when it is in the control of a third party.
We may also disclose personal data to third parties, if required to by law or it is necessary for a legitimate purpose such as defending or bringing legal action. DPL allows us to do this where the request is supported by:
- evidence of the relevant legislation
- a court order
- satisfactory evidence and assurances of the legitimate interest.
Legitimate interest would include requests such as defending or making a legal claim, such as to insurers following a vehicle collision in a carpark. When we are not required to provide CCTV, we will take into account the circumstances and any potential harm to individuals, we may also charge a fee and seek indemnity for any use beyond which it is requested.
External guidelines and best practice
AEA operates its CCTV systems in compliance with the CCTV Code of Practice issued by the Information Commissioner’s Office (ICO) in 2017. The Code describes best practice standards which should be followed by organisations operating devices which view or record images of individuals. It also covers other information derived from those images that relates to individuals (for example vehicle registration marks).
WEBSITE VISITS AND PURCHASES
This section shows the information we collect when you use our website. Before providing us with your details, please read the following important information regarding:
- Collection of visitor information;
- Hyperlinks;
- Cookies; and
- Session Cookies.
- Other storage technologies
Collection of visitor information
We will only use the information that we collect about you lawfully, in accordance with the DPL.
The details you provide about yourself and any other information which identifies you (‘Personal Information’) is held by AEA on this website (the "Site") for operational purposes, for example member registration or processing payments. We may also use your Personal Information to personalise your experience on the Site by informing you of new products or services that we may think are of interest to you.
AEA gathers general information about users, for example, what services users access the most and which areas of the AEA site are most frequently visited. Such data is used in the aggregate to help us to understand how the AEA site is used. We gather this information so that we can continue to improve and develop our services to the benefit of our users. We may make this aggregated information available to users of the AEA site and to auditors. These statistics are anonymous and contain no personal information and cannot be used to gather such information.
When you register with AEA, set up a travel alert, enter a competition, or buy a ticket, we ask for personal information such as your name, contact details, and other details. Once you register with AEA and accept our Terms & Conditions, you are not anonymous to us. We may use information that you provide to alert you to our own products and services. We may contact you regarding site changes or changes to the AEA products or services that you use.
If you buy a ticket online with AEA, we will record your personal details and send you a confirmation email. Your personal data will be used principally to communicate with you with reference to your request.
You may opt-in to receive newsletters, exclusive discounts, special offers and other marketing emails from AEA. You may unsubscribe at any time by clicking the unsubscribe button at the bottom of the email. Please note changes to your subscription preferences can take up to 14 days to take effect.
Alternatively write to our Customer Relations Team:
Customer Relations:
FREEPOST RSCZ-UXZJ-EHHE
Greater Anglia Contact Centre
Norwich Railway Station
Station Approach
Norwich
NR1 1EF.
Hyperlinks
We may provide hyperlinks from the site to third party websites. No liability is accepted for the contents of any site operated by a third party which may be accessed via links from the site. These links are provided for your convenience only and do not imply that AEA approves or recommends the content of such sites. We encourage our users to be aware when they leave our site to read the privacy statements of each and every website that collects personal data. This Privacy Policy applies solely to information collected by AEA
Cookies
Our website uses cookies to help us to provide you with a good experience when you browse our website and also allows us to improve our website.
So what is a cookie?
A "cookie" is a small text file that is placed on your equipment when you visit a website (equipment like computer, phone, and tablet).
There are several types of cookies:
Functional cookies
The functional or session cookies are used to provide services or to store your preferred settings. For example for:
- remembering the products you purchase during online shopping;
- memorizing and passing on the information that you enter during the log-in process or that you leave behind on the various web pages during the ordering process, so that you do not have to enter the same data every time;
- saving your preferences;
- detecting abuse of our websites.
Analytical cookies
These cookies are used to analyze your visit to our websites. For example, we analyze the number of visitors visiting our websites, the duration of the visits, the order of the pages visited and whether the pages of a website need to be adjusted. With the help of the collected information we can organize our websites more user-friendly. Furthermore, these cookies are used to solve possible technical problems on the websites.
Marketing and tracking cookies
Only if you have given us permission in advance will we use tracking cookies for commercial purposes. These cookies, often placed by third parties, help us to be able to offer you personalized offers. Third parties can follow your internet behavior with tracking cookies.
Other techniques
In addition to cookies, AEA also uses Javascripts and web beacons. By using Javascript in your browser we can make our sites interactive and develop applications for the web. A web beacon is a small graphic image on our sites. By means of this image, we can, for example, determine how many visitors saw the page at which times. These techniques can also be used for marketing and tracking purposes.
Cookies from external parties
Some of the cookies are placed with the consent of AEA by third parties with the aim to bring certain products and services to your attention or to give you direct access to social media. For the cookies that these external parties place, the information they collect with them and the purpose for which that information is used, we refer to the privacy statements of these parties on their own websites. These statements can change regularly and AEA has no control whatsoever.
Would you like to know more about cookies? Go to https://www.allaboutcookies.org/
Access to our database containing personal information on registered users of the site is restricted. In order to increase security we ask you to input a password when you register as a user of the site. Please keep this password secret. In addition, we encrypt your financial information using SSL (Secure Sockets Layer) technology so that no one else can access your credit card details as they travel through the Internet. SSL is certified by Verisign and is recognised as a secure way to pay on-line. As you may be aware, no data transmission over the Internet can be entirely secure. As a result, while we will always use reasonable endeavours to protect the personal information you provide to us, we cannot guarantee the security of your information and the use of our facilities (e.g. e-mail) is at your own risk. If you have any questions about paying for your ticket through the Site, please contact Customer Relations.
Advertising
Our website is supported by advertising.
Advertising cookies, often placed by third parties, are used to track visitors across different websites. This helps us offer relevant and engaging advertisements during your visit to our website. Our advertising technology is provided by Google and you can choose to opt-out of interest based advertising using Google’s Ads Settings (https://www.google.com/settings/u/0/ads/authenticated). You can also control interest based advertising and learn more by visiting Your Online Choices (https://www.youronlinechoices.com/uk/your-ad-choices) and About Ads (http://optout.aboutads.info).
Customer data is also collected and shared as hashed data in a privacy-friendly way with third-parties (such as Google). This sharing is to measure the performance of advertisements issued by our company.
TICKET OFFICE PURCHASES – SEASON TICKET RECORDS
Personal details we hold
When you buy a season ticket valid for one month or more, we keep a record of this on a database. We keep the following details:
- Name, address and photo card number;
- Phone number, email and date of birth if you provide them;
- The origin, destination and start and end date of season tickets you have purchased, along with any duplicate, replacement or refund of these; and
- The method of payment used, but not any payment card details.
How we use your personal data
We use this information for Contractual obligations, Customer Relations and administration, customer research, marketing and fraud prevention.
We will only send you information about offers and promotions if you chose to receive it and you can change your marketing preferences at any time. We will not pass your personal information to any other organisation outside of our Group of Companies (and Successor franchise or Secretary of State for Transport) for marketing purposes without your prior consent.
Why we retain your information
We retain your information to allow us to contact you i.e. season ticket is lost and to aid the renewal process once the season ticket is close to expiring.
Length of time records are kept
Records are kept for kept for the duration of the franchise.
Sharing data with third parties
If you have agreed to receive information for survey or research purposes, we may share your contact details with a limited number of parties, but only for the reasons you have agreed to.
REVENUE PROTECTION AND PENALTY FARES
Personal details we hold
We may collect a range of personal detail during revenue protection activity. This may include name, address, proof of ID, journey details, payment details, personal descriptions and other information you provide to support an appeal. This data is processed by AEA and held in archive by ITEL (3rd Party).
How we use your personal data
We only use this information for the administration of the Penalty Fares scheme, collection of unpaid fares, fraud prevention and the prosecution of travel offences.
Why we retain your information
We retain your information to undertake analysis to identify any patterns in the data and to minimise future fraudulent activities.
Length of time records are kept
Records are kept for a maximum of 12 months.
Sharing data with third parties
We may share your correspondence with:
- British Transport Police under a data sharing agreement to prevent and detect crime.
- The ITEL if you appeal a Penalty Notice issued to you.
- Passenger Focus if you have asked them to act on your behalf under a complaint handling procedure. Requests from ombudsmen are dealt with on a case-by-case basis to ensure that any such disclosure is lawful in accordance with DPL.
- We may also share information with other TOCs for fraud prevention. We will only do this where there is a formal data sharing agreement in place, or where an ad hoc request is received this will be dealt with on a case-by-case basis to ensure that any such disclosure is lawful in accordance with DPL.
Collection of data at station gate lines
AEA may collect data from customers at station gate lines. The data collected is the ticket number of the ticket presented and will then be matched against the season ticket database.
The data is collected to counter fraudulent behaviour from customers with regard to ticketless travel.
CUSTOMER RELATIONS DATABASE
We collect your information and comments when you contact us by letter, email, web form, phone or social media.
Personal details we hold
We may hold your name, address, date of birth, email address, phone number, social media name, ticket details, photocard image, our correspondence with you, the compensation claims you have made and payment made by us, proof of journey or other supporting information you may provide.
To ensure that we carry have an accurate record of dealings between us (and for training purposes) we may, in certain circumstances, record or monitor telephone calls, however you will always be told when this happens.
How we use your personal data
This information is used for administration of correspondence or processing claims you have made, such as delay repay as well as for fraud prevention purposes. We also use it to respond to complaints.
Why we retain your information
We retain your information to ensure that all claims are processed properly, to undertake analysis in order to minimise potential fraud and identify themes and patterns in the data.
Length of time records are kept
Records are kept for the length of the franchise in a restricted access site to allow analysis and identify themes and patterns.
Sharing data with third parties
We are required to provide details of your complaint to another TOC if it relates to their services instead of ours. We may share your correspondence with Passenger Focus or London Travel Watch or the Ombudsman, if you have asked them to act on your behalf under a complaint handling procedure.
We may also share information with other TOCs for the purpose of fraud prevention. We will only do this where there is a formal data sharing agreement in place, or where an ad hoc request is received this will be dealt with on a case-by-case basis to ensure that any such disclosure is lawful in accordance with DPL.
STATION HELP AND ASSISTANCE INFORMATION POINTS
On our stations, we maintain Customer Help and Assistance Points. Depending on the service requested these are linked directly to our Control Centre or to National Rail Enquiries.
Calls for Information or Assistance made to National Rail Enquiries are recorded and monitored, but no advance notice is given as this could result in a delay in the providing assistance.
STATION & TRAIN WIFI
When using our station or train WiFi service we collect device MAC addresses, timestamps and accounting which is stored for a limited amount of time in order to authenticate devices to the WiFi service. This data will be retained for a period of 14 days after such time it will be deleted.
CHILDREN’S DATA
We do not routinely process children’s data, however in the rare instances that we do we may be required to gain consent from a parent or guardian to process the child’s data.
Where we chose to rely on consent as the legal basis for processing children’s personal data, consent may be required from a person holding ‘parental responsibility’ (note that under the GDPR the UK could chose to implement a lower age boundary than 16 in defining a “child” in law, as long as it is not below 13).
The children’s consent must be freely given, specific, informed and unambiguous.
The AEA business sells scholar tickets (discounted season tickets) to allow children to travel to certain schools. The details taken are the child’s name, school (to ensure that school is within the AEA network) and photocard number. The payment and invoice address details are provided by the parents when the ticket is ordered.
PARKING - National Car Parks “NCP”
NCP in conjunction with AEA operate car parks at AEA stations. Season ticket passes are available to customers and employees of AEA, in such cases the customer/employee will need to supply their name, address and car registration numbers to ensure that they are not charged for using the car park.
RECRUITMENT
For the purpose of gaining employment your data will be processed by Greater Anglia for but not limited to assessments, interviews, medical and reference checks.
The data is retained on the following basis: Unsuccessful candidates – 6 months
Successful candidates – 6 years after leaving employment
SAFETY FORMS & CLAIMS
AEA process safety forms and potential claims were a customer or employee has had an accident/or reported accident whilst at a station or travelling on our trains. The data taken is the name, address and data of birth of the customer or employee concerned. For customers this data will be sent to our third party claims handler and is collected in order to manage the claim and will be held for three years and six months after the claim is resolved. For employees the data will be held indefinitely in order to manage any future claims that the employee could raise at a later date.
WHERE WE STORE YOUR PERSONAL INFORMATION
The information that we collect from you will only be stored in the European Economic Area (“EEA”) or, where it is necessary to disclose it to our processors located outside the EEA, other jurisdictions which are acceptable according to guidance provided by the Information Commissioner and/or where appropriate legal and security safeguards are in place. Please contact the Data Protection Manger (see page 2) if you wish to find out more about the safeguards.
INFORMATION SECURITY
We use a range of appropriate technical and organisational measures to safeguard access to and use of, your personal information and to ensure it retains its integrity and availability. These include structured access controls to systems, network protection, intrusion detection, physical access controls and staff training. We also consider anonymising or pseudonymising personal data where practical.
YOUR RIGHTS
Unless stated otherwise wwe will aim to satisfy your instruction, or inform you as to why we are unable to, without undue delay and within 30 days. If we anticipate that we will not meet with this timeframe we will let you know within 30 days and explain what the problem is.
OBJECT TO DIRECT MARKETING
To prevent marketing to you, you have the right to ask us not to process your personal information for marketing purposes. We will usually inform you before collecting your information if we intend to use or disclose it for such purposes. If you do not want us to use your information for marketing purposes either:
- indicate this by NOT ticking the box to be sent marketing emails (or offers);
- if you have an account with us, by logging in and changing your contact preferences;
- click the unsubscribe link on direct marketing emails; or
- contact us.
ASK FOR A COPY OF YOUR PERSONAL DATA
You are entitled to request a copy of the personal information we hold about you.
Please contact the Data Protection Manager, as follows:
Email:
Address:
The Hub
Finance Department
Colchester North Station
North Station Road
Colchester
CO1 1JS
We may need to ask for some further information, such as checking who you are.
Please refer to website for a copy of the Subject Access Report (SAR).
Please let us know in what format you wish to receive your information.
Sometimes we may hold information that we don’t have to provide, for example it would prejudice a police investigation or if the disclosure would cause harm to another person whose personal data is inseparable from your data.
In most cases we provide the copy of your data to you for free. We have set out some information about when it might not be free, or provided below.
RECTIFICATION / RESTRICTION
If you believe the information we hold about you is inaccurate or incomplete you can contact us and ask us to correct it. You may also request any data processing we are carrying out on your data is halted whilst a request for rectification, objection or a dispute over the lawfulness of processing is being considered. We will provide a response confirming the action we have taken or disagree with taking.
DELETION
This is also known as the “Right to be forgotten”; you can request deletion or removal of personal information in some circumstances, such as where there is no compelling reason for its continued processing. We will also take reasonable steps to notify third parties of your instruction and request that they act upon it, in a similar manner.
WITHDRAWAL OF CONSENT
If we relied on consent as the ground for processing your personal data, you can withdraw this consent at any time. It does not affect the processing carried out beforehand. You can withdraw consent by contacting Customer Relations:
FREEPOST RSCZ-UXZJ-EHHE
Greater Anglia Contact Centre
Norwich Railway Station
Station Approach
Norwich
NR1 1EF
Data Protection Manager:
Email: [email protected]
Address:
The Hub
Finance Department
Colchester North Station
North Station Road
Colchester
CO1 1JS
Where you have consented to receive direct marketing communications, you can withdraw your agreement at any time, as above or where available updating your preference centre or clicking on the appropriate link in the communication.
We will act upon such an instruction as soon as possible.
PORTABILITY
Where you have provided us with personal data and the reasons we are processing it are based on consent or our contract with you, and the processing is automated, you have a right to ask for that information be provided to you or another data controller in a structured, commonly used and machine-readable format. The right may be restricted if it is not practical for us to provide the information in this way or it adversely affects the rights of others.
INFORMATION ABOUT PROFILING AND AUTOMATED DECISION MAKING
We target some of our marketing and service communications so that they are more relevant to you, based on the type of ticket(s) you bought and your location/travel stations. We will try and ensure where possible the communications are compatible with the device you are using. We use automated decision making to calculate the validity and value of Delay Repay claims made through our website. You will receive a notification of the outcome of your claim. At this stage you are able to request that your claim is manually reviewed by a member of the Delay Repay team. If you remain dissatisfied you are able to escalate to our Customer Relations team.
HOW WE DEAL WITH RIGHTS REQUESTS
We are not able to charge you a fee for dealing with rights requests, unless they are manifestly unfounded or excessive or in circumstances where copies have been provided previously. We would always let you know if we thought this was the case, so that you can make a decision about what you wanted to do next.
There are various limitations and exemptions in relation to the exercise of rights in DPL - for example if it would affect another’s rights and freedoms or if we need to retain the information to make or defend a legal claim. We intend only to rely on limitations and exemptions where it is fair to do so and always bearing in mind that it is your personal data.
COMPLAINTS
The Data Protection Manager role has been established in a manner to remain independent of business decisions. If you wish to lodge a complaint against:
- the business, please contact our Data Protection Manager; or
- the Data Protection Manager, please contact the ICO.
Please don't send images of passports, credit or debit cards, or any other information that is personal to you. You'll be contacted if more information is needed.
If you are not happy with the way in which we deal with your data or have dealt with a rights request, then please let us know. Our Data Protection Manager is the first point of contact for dealing with Rights Requests and complaints and they are assisted by Customer Relations. If you are not satisfied with the way in which they have handled your complaint or rights request then you can contact the Group Data Protection Manager:
Data Protection Manager
Abellio UK HQ
36 Renfield St
5th Floor, The Culzean Building
Glasgow
G2 1LU
Email: [email protected]
If you are not satisfied with the response you can complain to the ICO. Their contact details are:
Head office Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Fax: 01625 524 510
https://ico.org.uk/global/contact-us/
HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
We’ll store your information for as long as we have to by law or regulatory requirement. If there’s no legal or regulatory requirement, we’ll only store it for as long as we need it. We’ll also keep some personal information for a reasonable period after your last contact with us – just in case you decide to use our services again. We, or one of our partners, may contact you about our services during this time if you haven’t opted out of receiving marketing communications from us.
We may also keep your personal data for the purposes of our legitimate interests in running our Group businesses, including anonymising or pseudonymising data for analysis.
CHANGES TO THIS PRIVACY POLICY
We may revise this Privacy Policy from time to time. The most current version of this policy will govern use of your information and will always be on our website. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.
This Policy was last updated on 12th September 2022
