FoxConnect Privacy Policy

Passengers of FoxConnect (Leicestershire) DRT Service 

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1. Who does this privacy notice apply to, and what is it about? 

This privacy notice applies to you if you are or were a passenger of FoxConnect Demand Responsive Transport (DRT) service organised by Leicestershire County Council. 

This privacy notice explains: 

• what personal data we process about you; 
• how we process your personal data; 
• your rights in respect of your personal data; and 
• what to do if you have any questions or complaints about our processing of your personal data. 
  

We take your privacy very seriously and are committed to abiding by the applicable data protection laws which protect your privacy. 

This privacy notice may change from time to time and the most up-to-date version will be available on the Leicestershire DRT passenger app for this service. It is your responsibility to read this privacy notice and check the Leicestershire DRT passenger app for the current version. 

For clarity, if you are or were a passenger of Demand Responsive Transport (DRT) service organised by Leicestershire County Council, Leicestershire County Council will also be processing your personal data as an independent data controller and you should refer to their privacy notice for: 

• what personal data they process about you; 
• how they process your personal data; 
• your rights in respect of your personal data; and 
• what to do if you have any questions or complaints about their processing of your personal data. 
  

2. Who is the controller of your personal data? 

Woods Coaches Limited is the controller of your personal data, for the purposes of this privacy notice. Woods Coaches Limited is a member of the National Express UK group of companies. 

Our representative for the purposes of this privacy notice is the National Express UK Data Protection Officer, who can be contacted using the contact details provided at the end of this notice. 

3. What personal data do we collect about you, and how? 

We process the following types of personal data about you: 

• your name and preferred salutation, where this is provided to us by Leicestershire County Council for the purposes noted below; 
• your gender and ethnic background, where this is apparent from our drivers meeting you when providing the Leicestershire DRT service and is for the purposes noted below; 
• your travel behaviour when using the DRT service, including pick-up and drop-off points (location data) and the times of pick-up and drop-off, to the extent these would identify you, when our drivers observe this when providing the Leicestershire DRT service and is for the purposes noted below; 
• if you raise a complaint or claim against us which Leicestershire County Council direct us to resolve or you otherwise communicate with us, your contact information, including telephone number and email address where these are provided; 
• if you are disabled or have special needs, information about your disability, special needs or mobility requirements; 
• your image where it is captured by CCTV or other visual recording equipment on our vehicles used to provide our passenger travel services; 
• your voice, where this is captured by CCTV or any other audio recording equipment on our vehicles used to provide our passenger travel services and/or where captured in recorded telephone conversations with you; and 
• any other personal data that you provide to us when you communicate with us. 
  

We process your personal data in a variety of ways, including: 

by:

• our drivers meeting you in person when they welcome you on board our vehicles and when, on our behalf, they are seeking to ensure your health & safety while travelling on, boarding or alighting the Leicestershire DRT service; 
• us making visual and/or audio recordings on the vehicles we use to safely and securely provide the Leicestershire DRT service to you; and 
• our recording telephone conversations with you when you contact us; and 
  

by you:

• providing your personal data to us when communicating with us in any manner, for example, when you:
• speak to one of our contact centre representatives; and 
• contact us by letter, email, text message, telephone call or on social media. 
  

4. What do we do with your personal data and on what basis? 

We use your personal data for the following purposes and describe below the legal basis on which we process your personal data:

‍Purpose 

• To comply with the laws and regulations that apply to us as the operator (but not organiser) of the Leicestershire DRT service 
• To safely and securely provide the Leicestershire DRT service to you in accordance with applicable laws and regulations, including: 
  - to seek to protect and promote your health & safety; and 
  - to seek to detect, investigate, prevent and report crime and anti-social behaviour. 
• To manage how we work with other companies that help us safely and securely provide the Leicestershire DRT transport service to you 
• To manage our relationship with you, including to respond to any complaints you have about our provision of the Leicestershire DRT service and to manage any claims you bring against us for such provision, including by enforcing and defend our legal rights 

Legal basis 

• Fulfilling our legal duty 
• Legitimate interest 

Explanation 

• Enabling us to safely and securely provide the DRT service, including seeking to protect your health and safety and detect and prevent crime and anti-social behaviour and seeking 
• Being effective about how we manage our relationship with you 
• Preserving our legal position 

5. What if we have obtained your consent to use your personal data? 

Where we process your personal data on the basis of your consent, you may withdraw that consent at any time (but, as noted in paragraph 4 above, we do not currently rely on your consent as the lawful basis for processing any of your personal data). 

6. What are our obligations to process, and your obligations to provide, personal data? 

We have no legal obligation to process personal data about you, but we need to process some personal data in order to comply with our legal and regulatory obligations to safely and securely provide the Leicestershire DRT service to you and to deal with any complaints you have about our provision of this service or legal claims you bring against us in connection with our provision of this service. 

You have no legal obligation to provide your personal data to us, but we may not be able to provide the Leicestershire DRT service to you or deal with your complaints or claims if you do not provide us with your personal data. 

7. Who will we share your personal data with? 

We may share your personal data with: 

• other National Express Group companies, where they assist us in safely and securely providing the Leicestershire DRT service to you or in dealing with your complaints and claims in relation to it; 
• our suppliers, sub-contractors and other business partners, where they assist us in safely and securely providing the Leicestershire DRT service to you or in dealing with your complaints and claims in relation to it; 
• our legal and professional advisors; 
• government bodies and regulatory authorities, including the Driver and Vehicle Standards Agency, the Police and other driving standards enforcement and crime prevention and detection agencies in the UK, as well as the UK Information Commissioner’s Office; 
• the Traffic Commissioners, the courts and other dispute resolution arbitrators and mediators, other parties to legal proceedings and passenger transport watchdogs; 
• other companies that take on any part of our business as a result of a restructure, merger or transfer of that part of our business. 
  

8. Do we transfer your personal data outside of the UK? 

There may be occasions where it is necessary to transfer your personal data to a country outside of the United Kingdom (“UK”). It is possible that the country concerned may not be deemed to provide a similar level of protection for individuals’ rights in relation to their personal data as in the UK. 

Where we transfer your personal data to other National Express Group companies and/or third parties who process your personal data on our behalf in countries outside the UK, we ensure a similar degree of protection is afforded to it by implementing one of the following safeguards: 

• we transfer to a country that has been deemed to provide an adequate level of protection for personal data; or 
• where the country has not been deemed to provide an adequate level of protection for personal data, we will have entered into contracts approved for use in the UK which give personal data the same protection as it has in the UK. 
  

Please contact the National Express UK Data Protection Officer if you want further information on the specific mechanism used by us when transferring your personal data out of the UK. 

9. For how long will we process your personal data? 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal requirements in respect of our relationship with you. 

Where we process your personal data: 

• to fulfil a legal obligation, we will process such personal data for so long as necessary to fulfil that obligation; or 
• to deal with any complaints or claims you make or bring against us, we will process such personal data until we have finally resolved such complaints or claims (having regard to the nature of any potential claims and the limitation of liability periods that apply to them). 
  

Where we process your personal data based on: 

• our legitimate interest, we will process such personal data for so long as necessary to achieve that legitimate interest, which will typically be for 6 years after we collect your personal data or the last time we use your personal data (or longer in relation to any legal claims that might arise having regard to the nature of any potential claims and the limitation of liability periods that apply to them).
  

We may also retain your personal data for longer if we cannot delete it for legal, regulatory or technical reasons. 

10. What rights do you have in relation to your personal data? 

You have a number of rights under data protection laws in relation to your personal data. These include the right, subject to exceptions, to: 

• request access your personal data; 
• request rectification or erasure of your personal data; 
• request restrictions on the processing of your personal data; and 
• object to our processing of your personal data. 
  

You also have the right in some circumstances to receive a copy of your personal data in a portable format. This right is limited to personal data you have provided to us and is processed on the basis of a contract with us and/or your consent (but, as noted in paragraph 4 above, we do not currently process your personal data on these bases). This right does not cover personal data that we process on other grounds. 

If you wish to exercise any of these rights where they apply, please contact the National Express UK Data Protection Officer. 

11. What should you do if you have any questions or complaints? 

If you have any questions or complaints about how we process your personal data, or otherwise about the matters set out in this privacy notice, please contact the National Express UK Data Protection Officer at: 

• Address: Data Protection Officer, National Express, National Express House, Birmingham Coach Station, Mill Lane, Digbeth, Birmingham B5 6DD 
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  or 
• Email address: data.protection@nationalexpress.com 
  

You also have the right to complain at any time to the UK Information Commissioner's Office about how we use your personal data and can contact them on their helpline: 0303 123 1113 or website at https://ico.org.uk/