Clean Air Zone Survey Privacy Notice

Research Summary

Central government has directed Greater Manchester to introduce a charging Clean Air Zone [“CAZ”]. It is planned that this would cover local roads across the whole of Greater Manchester from spring 2022, operating 24 hours a day, seven days a week and non-compliant commercial vehicles (Light Goods Vehicles (LGVs), Heavy Goods Vehicles (HGVs), coaches, minibuses, taxis and Private Hire Vehicles (PHVs)) will pay a daily charge to travel on local roads in the Zone.

TfGM is undertaking the survey on behalf of the 10 Greater Manchester Local Authorities and has commissioned SYSTRA to consult with local organisations likely to be impacted by the proposed Greater Manchester CAZ through a survey. This survey is themed around predicted behaviour in light of the CAZ and available financial support for those with non-compliant vehicles, and expected impacts of these. This will provide a baseline understanding of likely response to the CAZ before it is implemented and will allow us to understand the impact of a Greater Manchester CAZ on you and your business income, in addition to how the Covid-19 pandemic has impacted you and your business.

This notice

  • We are providing you with this information so you know what data we are collecting from you as part of this research study; what we are going to do with it; and your rights over our use of your personal data.

Your personal data

  • Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”), and associated legislation including but not limited to the Data Protection Act 2018.

Who are we?

  • Transport for Greater Manchester (TfGM) is the Data Controller. This means TfGM has decided how your personal data is processed and for what purposes.
  • SYSTRA is a Data Processor. This means that they are responsible for collecting and processing your personal data on behalf of the Data Controller.
  • JTL Research is a Sub-Data Processor. This means that they are responsible for collecting and processing your personal data on behalf of SYSTRA. JTL Research collected your personal data from you when you were recruited to complete the survey.

What information is being collected?

The Survey will ask you questions in relation to the Greater Manchester Clean Air Zone to understand your views. The personal information we process and collect will be provided to us directly by yourself. Whilst it is not compulsory some personal data may be collected in the process of this survey. Personal data that may be collected includes:

  • Business name, Postcode, Age groups, and if you would like to enter the prize draw, your Name, Telephone and Email.
  • If recruited via JTL Research, your name, job title, email address, telephone number and organisation’s postcode, and information about your company’s fleet, sector, location and size will have been collected, to ensure you were in scope to complete the survey.
  • We may also collect some special category personal data within the survey. Special category data is data that is deemed more sensitive. For the purpose of this survey we may collect the following special category data: Physical or mental health information; Racial or ethnic group information; Religious believes or similar. We ask for this data so that we can check the impact of the proposals on different demographic groups and to show we reach a proportionate amount of the community.
  • If you wish to leave the survey and return later, you can enter your email address, and we will send you a link so you can return to the survey where you left. We may also send you a reminder email. This will only be sent if you chose to provide your email address.

How is it collected?

  • The survey is completed online via Snap Surveys. Snap Surveys is a secure software survey platform used for data collection and analysis which has the highest standards of data security achieving the ISO27001 accreditation.
  • If recruited, your personal data will be collected over the phone or online and information will be added to the Snap Surveys platform.

Why is it being collected?

TfGM has been asked to co-ordinate this survey on behalf of the 10 Greater Manchester Local Authorities and our lawful basis for processing under GDPR is:

  • GDPR Article 6(1)(e): the processing is necessary for the performance of its official tasks carried out in the public interest.

And for the more sensitive data:

  • GDPR Article 9(2)(g): the processing is necessary for reasons of substantial public interest for the purposes of equality of opportunity or treatment.
  • We also rely on your Consent to hold your name and contact details, which you can withdraw at any time.

How will it be used?

  • TfGM and SYSTRA comply with their obligations under the GDPR by: keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
  • All electronic survey information will be encrypted with a secure password. SYSTRA and TfGM will restrict access to your personal information.
  • Your data will be analysed anonymously with all other participant data. SYSTRA will report the findings of the research to TfGM. No individual will be made identifiable during reporting.

Who will it be shared with?

  • SYSTRA will only share your data with TfGM, and no other third party. TfGM may share demographic and postcode data with the relevant Local Authority but will not share any contact details provided. Reports from the survey will not contain any personal data.

How long do we keep your personal data?

  • We keep your personal data for no longer than reasonably necessary.
  • Contact details provided for the Prize Draw will be erased once the Prize Draw is complete.
  • Contact details held for re-contacting purposes will be deleted if there is no contact at each follow-up stage of the survey or else it will be kept until December 2027.
  • Otherwise to enable an ongoing evaluation of the CAZ and its impacts, your data will be kept until December 2027. After this, all personal data will be destroyed.

Direct Marketing

  • The Privacy and Electronic Communications Regulations (PECR) sit alongside data protection legislation. They govern how we can send direct marketing communication to you. They give you specific privacy rights in relation to electronic communications. These include marketing calls, emails, texts and faxes. Genuine market research does not count as direct marketing.
  • SYSTRA has received your contact details for the purpose of this survey from either Email Movers, Dun & Bradstreet, Experian, JTL Research or a membership organisation you are part of. Due diligence checks have been made and those who have been contacted have opted in to receiving market research. Should you wish to opt in to further research in relation to CAZ you can do so at the end of the survey.
  • Should you wish to opt out of receiving further information or market research in relation to the CAZ Survey you can do so by contacting the SYSTRA research manager, Eve Robertson: All Social and Market Research work is also completed in accordance with the Code of Conduct of the Market Research Society (and its associated guidelines) and the Ethical Guidelines of the Social Research Association.

Your rights and your personal data

You have the following rights with respect to your personal data:

  • The right to request a copy of your personal data which SYSTRA holds about you.
  • The right to request that SYSTRA corrects any personal data if it is found to be inaccurate or out of date.
  • The right to request your personal data is erased where it is no longer necessary for SYSTRA to retain such data.
  • The right to withdraw your consent to the processing at any time.
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
  • The right to object to the processing of personal data.
  • The right to lodge a complaint with the Information Commissioners Office.

Contact Details

  • Any more information about the research study, or our use of your data;
  • To request to see the personal data held on you; or
  • To request to withdraw your personal data.
  • Or exercise any other of the rights listed above

Please contact the SYSTRA research manager, Eve Robertson:
Should you wish to find out more about SYSTRA’s data protection processes or contact their Data
Protection Officer, please contact SYSTRA’s UK Compliance Team at

To find out more about TfGM’s compliance with data protection please click on the following links to review their data protection notices: You can also contact TfGM’s data protection team and Data Protection Officer at:

If you have any concerns or questions about data protection or your rights you can also contact the Information Commissioners Office on 0303 123 1113 or via email or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

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