SPT takes the privacy of your personal data very seriously. We have set out in our Privacy Statement (below) what information we collect, how we collect it, what we do with it, who we share it with and why.
SPT is responsible for transport planning and delivering transport solutions across the SPT area in conjunction with our member councils and industry partners.
We operate the Glasgow Subway and a number of bus stations across the west of Scotland, support a range of socially necessary bus services, and administer ZoneCard and other tickets to help people connect their journeys. SPT also works with other organisations to provide free and discounted travel for those who are eligible.
We sometimes need to process your personal data so that we can provide you with these and other services.
This Privacy Statement sets out how SPT collects, uses and protects your personal data as well as your rights in respect of such personal data.
Data by which you may be identified will only be used in accordance with the specific Privacy Notice relating to the service(s) you are using (please see below).
- Personal Data which may include your name, address, date of birth, telephone number, e-mail address etc.
- Special Category Data which may include (but is not limited to) information about your race, religion, health or sexual orientation. SPT recognises the significance of special category personal data and will only process such data if certain conditions are met.
- Data you give us. For example, you may give us data about yourself when filling in forms or corresponding by phone, e-mail or otherwise when you apply to use SPT tickets and/or services, when you take part in SPT competitions/surveys or when you send SPT an enquiry or/ complaint.
- Data we collect about you. For example through cookies and similar technologies to when you use our website, including your IP address, browser type, internet service provider, web pages you visit etc.
- Data we receive from other sources. For example, we may receive your data from via third parties that SPT works with to provide our services, such as local authorities, contractors and other third parties involved in the delivery of those services, including bus operators.
Under privacy and data protection legislation, SPT is only allowed to use personal data if we have a proper reason or ‘legal basis’ to do so.
This will vary depending on the service(s) you are using, and will be set out in the specific Privacy Notices relating to those services.
There are a number of these ‘legal grounds’ we rely on, which include:
- Consent – where you have given SPT your permission for your personal data to be processed for a specific purpose.
- Contract – where the processing of your personal data is necessary for a contract you have with SPT, or you are looking to enter into with SPT.
- Public Task – where the processing of your personal data is necessary for SPT to perform its statutory and public functions as the RTP for the West of Scotland.
- Legal Obligation – where the processing of your personal data is required by law.
- Vital Interests – where the processing of your personal data is necessary to protect your vital interests or the vital interests of others in circumstances where we will not be able to seek your consent.
Special category data and data related to criminal offences is processed as part of our statutory functions.
In all cases we will process your personal data only when necessary and in accordance with privacy and data protection legislation.
Who we share your personal data with and why will vary depending on which service we are providing to you, however, this will be explained in the specific Privacy Notices relating to those services.
Where SPT engages third parties to process personal data on our behalf, they do so on the basis of clear written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measure to ensure the security of the data.
SPT will not sell your personal data to any third parties.
This will only happen where necessary, and details of any such processing will be set out in the specific Privacy Notice(s) relating to the service(s) you are using.
Your right to be informed
You have the right to be informed about the collection and use of your personal data.
Your right of access
You have the right to ask us for copies of your personal data (commonly known as a Subject Access Request (“SAR”)). For more information on making a SAR, please visit SPT’s Data Protection page.
Your right to rectification
You have the right to ask us to rectify data you think is inaccurate. You also have the right to ask us to complete data you think is incomplete.
Your right to erasure
You have the right to ask us to erase your personal data in certain circumstances.
Your right to restriction of processing
You have the right to ask us to limit the way your personal data is processed in certain circumstances.
Your right to data portability
You have the right to ask that your personal information be provided to you or another data controller in a structured, commonly used and machine-readable format, in certain circumstances.
Your right to object to processing
You have the right to object to the processing of your personal data in certain circumstances.
Your right relating to automated decision making
You have the right, in certain circumstances, to prevent the automated decision making or profiling of your personal data. SPT does not use automated decision making processes.
Your right to withdraw consent
If SPT has relied on consent as the legal ground for processing your data, you can withdraw this consent at any time.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
The Data Protection Officer for SPT:
Assistant Chief Executive
Strathclyde Partnership for Transport
131 St Vincent Street
Telephone: 0141 333 3298
Information Commissioner’s Office
Helpline number: 0303 123 1113
Web site: ico.org.uk/
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