WHAT IS THE PURPOSE OF THIS DOCUMENT?
North Coast Community Transport is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are providing this privacy notice because you are applying to use our community transport services. It makes you aware of how and why your personal data will be used, namely for the purposes of providing community transport services, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation – also known as GDPR.
DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application for community transport services, we will collect, store, and use the following categories of personal information about you:
• The information you have provided to us in this application form and any covering letter.
• Any updated information you provide to us in the future.
We may also collect, store and use the following types of more sensitive personal information:
• Information about your physical and mental health, including any medical condition.
• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about you from the following sources:
• You, as an existing or potential member.
• From third parties (such as family members or carers).
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
• Consider your application for community transport services.
• Provide you with community transport services if your application is successful.
• Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether we can provide community transport services to you and, if your application is successful, to provide those services to you, as it would be beneficial for our business to do so.
We also need to process your personal information to decide whether to enter into a contract for the provision of community transport services with you.
Having received your application form, we will process that information to decide whether you qualify to receive our community transport services. If we do agree to provide you with community transport services, then we will use the personal information to provide you with those services.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application, we will not be able to process your application successfully. For example, if you do not provide us with the information we need to assess your entitlement to community transport services, we will not be able to take your application further.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
We will use your particularly sensitive personal information in the following ways:
• We will use information about your health and disability status to consider what vehicle to use to provide our community transport services to you. We may also use this information to assist the emergency services in the event that you require medical attention whilst using our services.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity and diversity monitoring and reporting.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application and providing you with community transport services:
• Organisations you ask us to share your data with;
• Providers of software and/or services that we use to provide community transport services (such as the electronic storage of your application form and details such as your name and address).
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Unless you request us not to do so, we will share the information in the section headed “Equality Information” with the Government department that provides our funding. This information will be shared for equal opportunity and/or diversity monitoring and reporting and will only include the information set out in that section.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and the Information Commissioner’s Office of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will generally retain your personal information for a period of 6 years after we cease to provide you with community transport services.
We retain your personal information for that period so that we can:
• Keep our records up to date.
• Respond to any questions, claims or complaints and to resolve disputes.
• Comply with our legal obligations.
• Prevent abuse.
• Ensure that we are able to fulfil our legal and contractual duties.
For very good reasons, we may keep your data for longer than the period stated above, such as if you were involved in an accident whilst using our services. If we cannot delete your data for legal, regulatory, or technical reasons, we will make sure that your privacy is protected and only use it for those purposes.
After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Manager in writing.
RIGHT TO WITHDRAW CONSENT
When you submit your application to us, you provided consent to us processing your personal information for the purposes of assessing your application and to provide you with community transport services. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your application and we will no longer supply you with community transport services and, subject to our retention policy, we will dispose of your personal data securely.
DATA PRIVACY MANAGER
We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Manager. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
We may change this Privacy Notice at any time and from time to time. All updates and amendments are effective immediately upon notice, which we may give by any means.