Privacy notice - Transport hub services
This privacy notice covers the provision of transport for for eligible service users:
- of Adult Social Care transport, for older and disabled adults
- who are eligible for free school transport based on distance to their designated school
- where the parent or carer requests to pay for transport on a hired school transport vehicle as part of the vacant seat scheme.
- of the SEN Post 16 Scheme provided by Children’s Services.
East Sussex County Council takes data protection seriously. Please be assured that your information will be used appropriately in line with data protection legislation, will be stored securely and will not be processed unless the requirements for fair and lawful processing can be met.
What information is being used?
- Date of birth
- Child’s pupil reference
- Parent’s name (in the case of children)
- Parent’s address (in the case of children)
- Parent’s telephone number (optional) (in the case of children)
- Parent’s email address (in the case of children)
- Looked after Child Status (if applicable)
- Proof of disability (Disabled applications only) and relevant EHCP information to assist travel (for children)
- Physical and Mental Health (to determine transport/resource need)
- Financial data (where paying or reimbursement)
- Location Data
- Photograph (when required for photo card travel passes)
How will your information be used?
It will be used to determine eligibility for the scheme and enable East Sussex County Council to allocate transport effectively and appropriately.
We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing. Your information is never sold for direct marketing purposes.
Our staff are trained to handle your information correctly and protect your confidentiality and privacy.
Your information is not processed outside of the European Economic Area.
What is the legal basis for processing your information?
Free School Transport for eligible pupils is provided under Section 508B and Schedule 35B of the Education Act 1996 as inserted by Part 6 of the Education and Inspections Act 2006 and administered by the County Council under Article 6(1)(e) GDPR. In line with article 9(2)(a) GDPR your consent will be sought for any sensitive (health) data.
The Vacant Seat Scheme is a paid for service and administered with your consent under Article 6(1)(a).
Payments are administered for pupils eligible for the SEN Post-16 Scheme and mileage allowances. Also where a charge is necessary for replacement of passes.
Smart cards allow details of where and when your pass has been used to be recorded anonymously. The Council may reidentify you from this data in the following circumstances:
Analysing usage for carrying out renewals (Article 6(1)(e) GDPR)
Identifying fraudulent use (Sch. 8 Para. 8(1)(b)(ii) Data Protection Act 2018)
Safeguarding vulnerable individuals (Sch. 8 Para. 4(1) Data Protection Act 2018).
Location data is also used to administer scheduling, mapping and routing of transport to be able to deliver services.
How long will your information be kept for?
Please see the Records Retention and Disposal Schedule for the Council.
Sharing your information
East Sussex County Council will share your information with trusted partner organisations to process your data on our behalf.
Our client management database is hosted and supported by Trapeze (UK) Ltd and enables us to provide the services you need.
Some personal information will be shared with our partner organisation, QRoutes Ltd, to assist scheduling and mapping routes for transport.
Where a photocard is required, your details will also be shared with our partner organisation, Euclid Ltd, who produce, and issue passes on the Council’s behalf.
The minimal amount of data to ensure a suitable transport service will be shared securely with transport providers (coach, taxi and minibus companies).
The Council has a duty to protect the public funds it administers. To prevent and assist in the detection of fraud, the information you provide on any forms may be shared with other public bodies responsible for auditing or administering public funds, including checks on credit reference agencies and taking part in the National Audit Office’s National Fraud Initiative.
The County Council will share information regarding the times and locations that passes have been used in the event that the police are carrying out safeguarding investigations relating to persons they believe to be vulnerable.
Any sharing of personal data is always done:
- on case-by-case basis
- using the minimum personal data necessary
- with the appropriate security controls in place
- in line with legislation.
Information is only shared with those agencies and bodies who have a "need to know" or where you have consented to the sharing of your personal data to such persons.
We may use the information we hold about you to assist in the detection and prevention of crime or fraud. We may also share this information with other bodies that inspect and manage public funds.
Under data protection legislation, you have the right:
- to be informed why, where and how we use your information
- to ask for access to your information
- to ask for your information to be corrected if it is inaccurate or incomplete
- to ask for your information to be deleted or removed where there is no need for us to continue processing it
- to ask us to restrict the use of your information
- to ask us to copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information
- to object to how your information is used
- to challenge any decisions made without human intervention (automated decision making)
Please visit data subject rights for further details.
How to find out more or complain
Should you have any further queries on the uses of your information, please speak directly to our service:
Phone: 01273 335075
Email: Transport Hub
You can also contact the Information Commissioner's Office (ICO) for further information or to make a complaint:
Information Commissioner's Office
Cheshire SK9 5AF
Phone: 0303 123 1113 (local rate)