SCC TDM Privacy Statement
DATA PRIVACY NOTICE
SYSTRA Limited (“SYSTRA”)
Your personal data – what is it?
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 in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”).
What Does This Policy Cover?
Please note that we have no control over how your data is collected, stored, or used by any third party elements outside of the project including websites and applications. We advise you to check the privacy policies of any such websites or applications before providing any data to them.
Who are we?
SYSTRA has been appointed by Somerset County Council (SCC) as lead supplier in relation to two Lots associated with their Travel Demand Management programme, Business and Community.
To give you some background, the Council is calling the project ‘The Bridgwater Way’ and the programme is focussed on helping to keep Bridgwater moving as the town goes through a period of significant growth and investment. By providing information, advice and tools people can choose the best time to travel and routes to use, and help reduce the need to travel in the first place. In particular it will help people and businesses avoid times when the roads are busiest. It includes investment in new roads and improvements to existing roads and junctions, as well as miles of new and improved routes for pedestrians and cyclists. It also offers active travel initiatives to make getting to work or school easier and safer.
In respect of this activity, for the purposes of the GDPR, SYSTRA Limited is both the Data Controller and a Data Processor. This means SYSTRA decides how your personal data is processed and for what purposes.
In undertaking this commission SYSTRA will be working with four project partners, who are sub-contracted to SYSTRA; BetterPoints, Go Travel Solutions (with two products, SmartGo and LocalGo), Living Streets and Sustrans; and in addition to this ITP who are undertaking an independent project monitoring and evaluation role on behalf of SCC.
SYSTRA along with project partners and ITP are all Data Processors which means that they are all responsible for collecting and processing your personal data.
Furthermore in registering and signing up to either the BetterPoints Platform or Go Travel Solutions (SmartGo or LocalGo) you will be subject to their own GDPR policies and procedures as they will act as the Data Controller for their respective platforms.
Our project partners each have their own privacy statement for the project that will cover any data they collect as part of the project.
How do we process your personal data?
SYSTRA complies with its 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.
You could partake in the project, with SYSTRA and partners collecting your personal data via the following channels:
- Taking part in Social Market Research, managed by SYSTRA and delivered by Protel Fieldwork Ltd
- Registering for the BetterPoints platform;
- Registering for the SmartGo online platform;
- Registering for the LocalGo online platform;
- Contact forms used on the TBW and SmartGo websites;
- Paper or electronic sign up forms used at events/roadshows delivered by SYSTRA’s partners;
- Emailing SYSTRA or one of our partners to register for an activity;
- Baseline and Monitoring Surveys, with the data shared with ITP (*); and
- Further follow up monitoring delivered directly by ITP(*).
- (*) ITP has been commissioned by SCC in a project monitoring and evaluation / assurance role.
Where you sign up for an offering within the programme and express interest in another service offering we will request your specific consent to pass on your contact details.
There are multiple user journeys into and through the project programme as can be seen below in the example of the Business Lot work:
SYSTRA and partner uses your personal data for the following purposes: -
- For providing communications related to the project such as mailshots, newsletters and project updates;
- Contact details for any challenge / survey incentives;
- Contact details for involvement in further research, e.g. focus groups;
- Passing details on to partner organisations and their services when individuals expresses an interest;
- Contact details for follow up monitoring, via ITP, this could included a sample of participants who:
- Choose to take part in the programme; and
- Choose not to take any further part in any activities.
Your data will be processed for the purposes of project monitoring. SYSTRA will report the findings of the project to Somerset County Council. No personal identifiers will be used in the report.
You can contact SYSTRA Limited (contact details below) for any questions about how your personal data is processed and for what purposes.
What Data Do We Collect?
SYSTRA and partners may collect the following personal data:
- Contact details including email address and phone number.
What is the legal basis for processing your personal data?
We wish to rely on your consent as the legal basis for processing your personal data. If we do not receive that consent from you at point of contact, you will not be added into the relevant element of the programme and / or your data won’t be shared with one of the partners for their services.
Sharing your personal data
Your personal data will be treated as strictly confidential and will not be shared with Somerset County Council, ITP, Project Partners or any other third party without prior consent. This will be undertaken in a secure manner and only where required to provide you with services as part of the project. This includes processing of paper survey responses where SYSTRA or project partners may collect paper responses from a business on behalf of ITP; they will be stored safely and securely in advance of being posted securely to ITP. To prevent unauthorised access or disclosure, we have put in place procedures to safeguard and secure the information we collect.
How long do we keep your personal data and keep it secure?
We will keep your personal data for no longer than is reasonably necessary and we will only retain your personal data for the duration of our commission with Somerset County Council on this project. Data will be reviewed after a 2 year period.
The TDM programme will last for a period of up to ten years and the suppliers delivering the services on behalf of SCC may change within this period. You will be notified should such changes occur.
In signing up to any of the following platforms, where you will complete a separate registration and provide relevant consents in the process of doing so you will be agreeing to the specific policies they have in place and will be considered a user of that platform in addition to being a participant in TBW. Your registration will move into the general national schemes of these providers beyond the lifespan of the TBW project. Please review the policies and procedures of these platforms for further details:
- BetterPoints platform;
- SmartGo online platform;
- LocalGo online platform;
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: -
- The right to request a copy of your personal data which SYSTRA and partners holds about you;
- The right to request that SYSTRA and partners correct 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 and partners to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right to request that SYSTRA and partners provide you with your personal data and where possible, to transmit that data directly to another data controller of your request, (known as the right to data portability).
- 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 lodge a complaint with the Information Commissioners Office.
Transfer of Data Abroad
Automated Decision Making
We do not use your personal data for any automated decision making and we do not instruct any providers to carry out such processing on your personal data.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by us (where such data is held). Unless your request is manifestly unfounded or is excessive, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact us for more details UK_compliance@systra.com
To exercise all relevant rights, queries or complaints please contact SYSTRA’s UK Compliance Team at UK_compliance@systra.com
If you have any concerns or questions you can also contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-u... or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
If you would like:
- Any more information about the project or our use of your data;
- To request to see the personal data held on you; or
- To request to withdraw your personal data.
Please contact the SYSTRA project manager, David Alderson firstname.lastname@example.org