Privacy Policy

Privacy Notice

Transport UK Group 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 premises, contact us, use our services, or Wi-Fi

• How we will collect and use that information
• How we keep information secure
• How you can contact us if you wish to exercise any of your rights in relation to the information or make a complaint

This Privacy Policy covers Transport UK Group Limited, Transport UK Holdings Limited, Transport UK Consulting Limited and Transport UK (Operations) Limited (together “Transport UK Group”).

If you want to change the way in which we use your data or if you have a question about how your personal information is used, contact the Data Controller via: privacy@transport-uk.com  Find out more under 'Your rights' below.

Contents

• Information we may collect from you
• How we use your information
• Sharing or disclosure of your information
• Types of information we collect
• Where we store your personal information
• Information security
• Your rights

Information we may collect from you

We may collect and process information about you when you:

• Procure our services
• Use our website, apps or WiFi
• Buy a service from us or make a sales enquiry
• Sign up to receive updates or marketing

We collect information such as your contact details and we may require additional details for some services. 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 the Data Protection Law (DPL). Depending on how you contact us, use our services, the consent you have given, our legitimate interests, or legal obligations we may have, this will include:

To provide you with the service - things like carrying out our obligations arising from any contracts - 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 - this is based on our legitimate interests, to provide public transport associated services. Sometimes it is part of our contract or our other legal obligations.

To run our services and improve them - we believe in investing in our services, not just to benefit passengers or customers but also the wider community, environment, and economy. There are lots of activities we do to achieve this, some are administrative and to 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 contracts, with the Department for Transport or Regulators.

For your safety and security.

• For fraud and crime prevention
• To enhance your experience of our website, as described in our cookie policy

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, the Secretary of State, the Department for Transport or other public or governmental clients or bodies within the public transport sector in the United Kingdom.

Our Legitimate Interests

Running our business and Group businesses, in a safe and socially and environmentally responsible manner, efficiently, to provide or support 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. 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 or support 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 comply with requests from the British Transport Police under an Information Sharing Protocol, ensuring that any disclosures are 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 in connection with the sale, merger, or acquisition of business assets. As the Public Transport industry is run on a system of franchises, we may be required to transfer certain data to a successor franchise, or the Secretary of State, this is so that they can take over and continue the running a railway service
• Where you have consented, to share with other members of the Transport UK Group of which we are a member, where Transport UK Group has any services, promotions and offers which we feel may interest you. 

You can find out more below about the information we collect and how we use, share or disclose it by contacting us at privacy@transport-uk.com.

Types of information we collect

Using our digital services

This section shows the information we collect when you use our website, Apps and WiFi services. Before providing us with your details, please read the following important information regarding:

• Collection of visitor information
• Hyperlinks
• Cookies; and
• JavaScript and Pixels

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 Transport UK Group on this website (the "Site") for operational purposes, for example account 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.

Transport UK Group gathers general information about users, for example, what services users access the most and which areas of the Transport UK Group site are most frequently visited. Such data is used in the aggregate to help us to understand how the Transport UK Group 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 Transport UK Group site and to auditors. These statistics are anonymous and contain no personal information and cannot be used to gather such information.

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 Transport UK Group 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 every website that collects personal data. This Privacy Policy applies solely to information collected by Transport UK Group.

Cookies

A cookie is a small data file which may be downloaded to your computer’s hard drive when you browse a website. Cookies help us to provide you with a good experience when you visit our site by remembering you, your browsing history, likes and dislikes, for when you visit us again in the future. They also allow us to improve the functionality of the website.

There are several types:

Functional Cookies

These functional or session cookies are used to provide services or to store your preferred settings ie they remember the choices you make, eg memorising and passing on the information that you enter during the login process to the My Account Area so that you do not have to enter the same data every time, saving your preferences, detecting abuse of our website.

Analytical Cookies

These cookies are used to analyse your visit to our website and help us to improve the customer experience through the way we organise our website. To do this we use Google Analytics which helps us to analyse the number of visitors and the duration of the visits. The information gathered allows us to make informed decisions about future functional developments to the website and also helps us when we need to solve possible technical problems on the website so to minimise inconvenience to our users. Please visit policies.google.com/technologies/ads for more information about Google Analytics.

Critical Cookies

These cookies are necessary to enable you to use our website and without these the website would not function, and we could not provide the service you need.

We always aim to show you up-to-date information, but may not be able to reflect these changes in our policy straight away.

Where we work with third parties to provide our service they may also set a cookie on your computer as part of the service provided.

Marketing 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 personalised offers. Third parties can follow your internet behaviour with tracking cookies. Transport UK Group uses a Tag Management System from Google to manage the choice of cookies. This way we can guarantee that no cookies are processed that you have not explicitly given permission for.

JavaScript and Pixels

In addition to cookies, we use JavaScript and Pixels. By using JavaScript in your browser, we can make our sites interactive and develop applications for the web.

A Pixel is a small graphic image on our site. 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. We use two types of Pixel; a Facebook Pixel, which analyses visits to our website from Facebook and Exchange Lab Pixel, which analyses visits to our website from our advertising across the internet.

Cookies from external parties

Some of the cookies are placed with the consent of Transport UK Group by third parties with the aim to bring certain products and services to your attention or to give you direct access to social media: Google Analytics, Google Optimise, Google Maps, Twitter, YouTube, LinkedIn, GoogleAdwords, Instagram, Facebook and HotJar . 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 Transport UK Group has no control whatsoever. You can learn more here:

• Facebook: for more information or to opt out
• Instagram: for more information or to opt out
• Linkedin: for more information or to opt out
• Twitter: for more information or to opt out
• Google Analytics: for more information or to opt out
• Google Ads: for more information or to opt-out

Visit the All About Cookies website to learn more.

Change your cookie consent settings

If you would like to change your cookie consent settings, you can do so here.

Privacy options

If you would prefer us not to set cookies on our Website, you can disable them by changing your internet browser settings. How to do this will depend on the browser you are using, but the following is a step-by-step guide to the most popular browsers:

Microsoft Internet Explorer:

1. Click on the "Tools" menu
2. Select "Internet Options"
3. Click on the "Privacy" tab
4. Select the desired setting

Google Chrome:

1. Click on the Customisation menu at the top right of the page
2. Select "Settings"
3. Select "Show Advanced Settings" and then "Content Settings"
4. Select the desired settings under the "Cookies" heading

Mozilla Firefox:

1. Click on the "Tools" menu
2. Click on "Options"
3. Select "Privacy"
4. Choose the desired options under the "Cookie" menu

For all other browsers, please follow the instructions provided by the relevant browser, usually located within the "Help", "Tools" or "Edit" facility.

If you only disable third party cookies, you will still be able to use this Website, but some of its content will not be as relevant to you. If you disable all cookies, this will result in our Website not working properly.

If you do choose to disable cookies, this choice will only apply to the device you are using at the time. If you want to stop cookies being set on other devices, you will need to follow the relevant steps on each device. Please note that disabling cookies does not delete cookies from your browser, you will need to do this from within your browser.

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. 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 (eg email) is at your own risk.

Sharing of information

We may share your personal information with third party service providers:

1. for improving your experience with them, and analysing the performance of their service to us;
2. for analysis and market research related services;
3. to carry out survey related activities with you;
4. to contact you about new features, services, products, and special offers ("Marketing Information") in line with any consent that you have provided.

Security

We take the security of your data very seriously. We employ physical, electronic and administrative security measures to protect the information that we collect about you from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. You acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of personal data, except to the extent we are required to accept such responsibility by the data protection laws.

Links to third party Internet site

The Website may contain links to other sites and sources of information. By clicking on these, you will leave the Website and this Privacy Policy will not apply to your use of any other sites.

Changes to this Privacy Policy

There may be changes in how we use your data. All such changes will be notified to you by updating this Privacy Policy and publishing it on our website.

Access to personal information

You are entitled to see the personal information we hold about you and may obtain these details by emailing us at privacy@transport-uk.com.  We are entitled by law to charge an administrative fee to meet our costs in providing you with such details and we may require proof of your identity before we supply the information to you.

Contacting us

If you have any questions about this Privacy Policy and would like contact us, please refer to the Contact Us on our Website.

Sharing data with third parties

We may share your correspondence with:

• British Transport Police under a data sharing agreement to prevent and detect crime
• We may also share information with our 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

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 privacy@transport-uk.com

We may need to ask for some further information, such as checking who you are, which will help us deal with your request more efficiently.

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 if 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/restrictions

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 emailing: privacy@transport-uk.com

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 service communications, so that they are more relevant to you, based on your location. We will try and ensure where possible the communications are compatible with the device you are using.

How we deal with right 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 decide 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 DPM 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 DPM; our DPO or contact the ICO.

We also have a complaints policy. If you are not happy with the way in which we deal with your data or have dealt with a rights request, then please us know. Our DPM are the first point of contact for dealing with Rights Requests and complaints and they are assisted by the Customer Services Team. If you are not satisfied with the way in which they have handled your complaint or rights request, then you can contact the DPO.

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: 03031 231 113 (local rate) or 01625 545 745 if you prefer to use a national rate number
• Fax: 01625 524 510
• Website: ico.org.uk/global/contact-us

How long we keep your 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 this 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 25/05/2023.

EU General Data Protection Regulation

For the purposes of the EU General Data Protection Regulation (GDPR), the data controller is:
Transport UK Group, 2nd floor St Andrews House, 18-20 St Andrew Street, London, EC4A3AG

Our Data Protection Manager (DPM) is:
GDPR Manager, Transport UK Group, 2nd floor St Andrews House, 18-20 St Andrew Street, London, EC4A3AG

Our nominated Data Protection Officer (DPO) is:
Edward Walker, Transport UK Group, 2nd floor St Andrews House, 18-20 St Andrew Street, London, EC4A3AG

More information about the EU GDPR 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.