This notice explains how and why Britannia Coaches Limited 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. Please check our website periodically for any changes to our privacy notice.
When we refer to “we” or “us” in this notice we are referring to Britannia Coaches Limited.
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
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:
– it is necessary to enter into, or perform, a contract with you; or
– if we are satisfied that we have a legitimate interest to record and retain this information for the purposes of delivering our services to you.
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:
– if we have your explicit consent; or
– for equalities or health monitoring purposes.
We use third-party software called Coach Manager from Distinctive systems to assist with our transport booking system. For more information, please see Distinctive systems privacy notice https://www.distinctive-systems.com/privacy
Home to School Transport Services
When schools or local authorities contract with us to provide Home-to-school Transport services, the school/local authorities will provide us with personal information about the children who will be using our services each day. This will include personal information (names, addresses and emergency contact details), and where necessary any special personal health information. 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 organisation to ensure that it has appropriate consents or authorisations for individuals 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.
We would like to keep in touch with you about the work that we do and the services we provide.
We will only send you marketing communications by email with your consent. We use a third party, Dotmailer, to deliver our e-communications. This company is a data processor for us and only processes personal information in line with our instructions. If you want more information, you can view Dotmailer’s privacy notice.
If you consent to receive email marketing communications from us, we will add your name and email contact details to our marketing database and we will share this information with Dotmailer in order to send the emails to you.
You can opt out of email marketing by clicking the ‘unsubscribe’ link in any of our emails or you can contact us at firstname.lastname@example.org or on 01304 228111 at any time to opt out, change or update your contact details or to update your communication preferences.
We may send marketing information by post if we are satisfied that we have a legitimate interest, for example, sending our newsletter to service users or sending special offers to client. You can contact us by email at email@example.com or by post at Britannia Coaches, Britannia House, Hollow Wood Road, Dover Kent CT17 0UB, or by telephone on 01304 228111, at any time to tell us that you no longer wish to receive marketing by post or to update your contact details.
From time to time, we may make marketing telephone calls to you but we never use automated calling systems. We will only contact you in this way if we are satisfied that we have a legitimate interest to do so and we will always check the telephone preference service and our own marketing preference records before we make any telephone marketing calls to you. You can contact us on 01304 228111 or by email to firstname.lastname@example.org at any time to tell us that you no longer wish to be contacted by telephone for marketing purposes.
Visitors to our website
We collect personal information that you provide when you fill in a form on our website. We will only collect and use your personal information in this way if:
– it is necessary to enter into, or perform, a contract with you (or to take steps, at your request, to enter into a contract with you); or
– if we are satisfied that we have a legitimate interest to record and retain this information for the purposes of responding to queries or complaints, or for internal quality monitoring.
When you make a payment to us via our website, we use a third-party Worldpay and Elavon to process the payment.
People who contact us via social media
If you send us a private or direct message via social media, we may share this information with other personnel within our organisation if we are satisfied that we have a legitimate interest to do so, for example, in order to respond to a specific query or to pass on information. We will not share any personal information that you provide in a message with any other organisations without your consent.
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.
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:
– where you have given us consent to share the information with the specific third party;
– where we use cloud software providers Dropbox and Distinctive Systems – Coach Manager bookings and reservation system to store information about our service users;
– where we use Dropbox to share information;
– if we are under a legal duty to disclose or share your personal information, for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime;
– in order to enforce any terms and conditions or agreements between us;
– to protect our rights, property and safety, or the rights, property and safety of others (this includes exchanging information with other companies, organisations, legal advisers and regulators for the purposes of fraud protection and credit risk reduction).
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.
We hold data electronically in our secure Distinctive Systems – Coach Manager booking system and on our on-site file servers, which are protected by both hardware and software firewalls.
We have off-site backup servers in secure locations.
We regularly back up all of the data we hold.
We store papers in lockable cabinets in our offices when not being actively used and we have a secure off-site storage facility for archived papers.
When necessary, we dispose of or delete your data securely.
We ensure that our employees, agents and contractors are aware of their privacy and data security obligations and we take reasonable steps to ensure that employees of third parties working on our behalf are aware of their privacy and data security obligations.
We limit access to your personal information to those employees, agents, contractors and other third parties who have a need to know.
The transmission of information via the internet is never completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your electronic information transmitted to us and any transmission is at your own risk.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Transferring your personal information outside the EEA
We may transfer the personal information you give us to countries outside the European Economic Area (EEA), specifically:
via Dotmailer and Dropbox cloud-based services
If we transfer your information outside of the EEA in this way, and the country in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. If you would like more information about the safeguards we put in place, please contact email@example.com
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
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.
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.
Ask us to correct any information that we hold about you which is incorrect, incomplete or inaccurate.
Ask us to erase your personal information from our files and systems where there is no good reason for us continuing to hold it.
Object to us using your personal information to further our legitimate interests (or those of a third party) or where we are using your personal information for direct marketing purposes.
Ask us to restrict or suspend the use of your personal information, for example, if you want us to establish its accuracy or our reasons for using it.
Ask us to transfer your personal information to another person or organisation.
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 firstname.lastname@example.org or telephone 01304 228111. 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 email@example.com or 01304 228111. 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
Ben Lawson, the Director, oversees compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Ben:
– by email to firstname.lastname@example.org
– by post at Britannia House, Hollow Wood Road, Dover Kent CT17 0UB
– by telephone on 01304 228111
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.
Published: 25/05/2018 By Britannia Coaches Limited