We work in line with the General Data Protection Regulations 2016 and the Data Protection Act 2018.
This policy describes how we collect, use and look after the information you provide us with when you use Transreport services.
Our website contains links to other websites, which may well have different privacy and security policies to us. Please remember, we don’t have any control over these websites, so we can’t take responsibility for any information you give them.
Transreport acts as a Controller for the internal data that we process. However, we also act as a Processor for a number of clients. The contacts for the organisation are the Company Directors. The Data Protection Officer is Ms. E. Taylor.
There are many ways you can contact us, including by phone, email and post.
Our postal address is:
Our phone number is 0203 609 8734 .
Most of the personal information we process is provided to us directly by users of our Apps who are typically using our Apps for reporting defects on trains or for requesting support. We may also be in receipt of data if:
We abide by the principles of data protection, and therefore minimise the data that we collect to the minimum required to deliver our services.
Under data protection law, you have rights; we need to make you aware of the rights available to you and to demonstrate our reason for processing your information. All the data that we hold is encrypted, which restricts unauthorised access.
Your right of access
You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can make the request verbally or in writing. The ICO gives guidance here .
Your right to rectification
You have the right to ask us to rectify information you think is inaccurate. Where necessary, we will pass on the changes to any third parties who need to change their records, and let you know that this has been done. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right here .
Your right to erasure
You have the right to ask us to erase your personal information in certain circumstances. We will pass on such requests to third parties, where necessary, so that they can ensure that your details have been erased if this is applicable. You can read more about this right here .
Your right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right here .
Your right to object to processing
You have the right to object to processing if we re able to process your information because the process forms part of our public tasks, or is in our legitimate interests. You can read more about this right here .
Your right to data portability
This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about this right here .
You are not required to pay any charge for exercising your rights. We have one month to respond to you.
Your Right To Complain
We work to high standards when it comes to processing your personal information. If you have queries or concerns, please contact us at [email protected] and we’ll respond.
If you remain dissatisfied, you can make a complaint about the way we process your personal information to the Information Commissioners Office; please follow this link to see how to do that.
This is what we normally process about you to help us provide you with Transreport services and information, where we can:
Customers And Suppliers
We hold the names and contact details of individuals acting in their capacity as representatives of their organisations, across the business. If the interactions relate to contracts or potential contracts for work to be conducted by us, then the legal basis is article 6(1)(b) because the processing is necessary for the performance of a contract, or to take steps to enter into a contract. If the interactions relate to suppliers, buildings management, IT services, accounts, etc., the legal basis is article 6(1)(c) of the GDPR for any legal obligation or article 6(1)(b) because the processing is necessary for the performance of a contract, or to take steps to enter into a contract.
We hold the names, addresses and telephone numbers of individuals in order that we can deliver goods as required by our customers. This data is all encrypted. The legal basis is article 6(1 (b) because the processing is necessary for the performance of a contract, or to take steps to enter into a contract.
Personal data is not utilised in any marketing activities; there is no direct marketing carried out.
We do pass on some details to our partners; these are transport operators who need this information in order to be able to provide a service, which includes Passenger Assist or responding to defect reports.
We will not pass on your personal information to any other third parties except in accordance with this policy and our Terms and Conditions or where we are required by law to disclose that information. As an example, you may wish us to share your contact details with selected third parties. This will only be carried out following discussion with you, and if you grant specific permission to do this.
When you visit www.transreport.co.uk, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
If we do collect personal data through our website, we’ll be upfront about this. We’ll make it clear when we collect personal information and we’ll explain what we intend to do with it. This may be, for example, when you complete the Contact Us form.
Purpose and legal basis for processing
The purpose for implementing all of the above is to maintain and monitor the performance of our website and to constantly look to improve the site and the services it offers to our users. The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.
What are your rights?
As we are processing your personal data for our legitimate interests as stated above, you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it.
Purpose and legal basis for processing
Our purpose for processing this information is to assess your suitability for a role you have applied for.
The legal basis we rely on for processing your personal data is article 6(1)(b) of the GDPR, which relates to processing necessary to perform a contract or to take steps at your request, before entering a contract. The legal basis we rely on to process any information you provide as part of your application which is special category data, such as health, religious or ethnic information is article 9(2)(b) of the GDPR, which also relates to our obligations in employment and the safeguarding of your fundamental rights and article 9(2)(h) for assessing your work capacity as an employee. And Schedule 1 part 1(1) and (2)(a) and (b) of the DPA2018 which relates to processing for employment, the assessment of your working capacity and preventative or occupational medicine.
What will we do with the information you give us?
We’ll use all the information you provide during the recruitment process to progress your application with a view to offering you an employment contract with us, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide with any third parties for marketing purposes.
We’ll use the contact details you give us to contact you to progress your application. We’ll use the other information you provide to assess your suitability for the role.
What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not keep it longer than necessary.
The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it may affect your application if you don’t.
We ask you for your personal details including name and contact details. We’ll also ask you about previous experience, education, referees and for answers to questions relevant to the role. Our recruitment team will have access to all this information.
You will also be asked to provide equal opportunities information. This is not mandatory – if you don’t provide it, it won’t affect your application. We won’t make the information available to any staff outside our recruitment team, including hiring managers, in a way that can identify you. Any information you provide will be used to produce and monitor equal opportunities statistics.
Our hiring managers shortlist applications for interview. They will not be provided with your name or contact details or with your equal opportunities information if you have provided it.
If we make a conditional offer of employment, we’ll ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We must confirm the identity of our staff and their right to work in the United Kingdom, and seek assurance as to their trustworthiness, integrity and reliability.
You must therefore provide:
We’ll contact your referees, using the details you provide in your application, directly to obtain references. We’ll also ask you to complete a questionnaire about your health to establish your fitness to work.
If we make a final offer, we’ll also ask you for the following:
If we do not have any suitable work at the time, we’ll let you know but we may ask if you would like us to retain your application so that we can proactively contact you about possible opportunities in the future. If you say yes, we’ll keep your application for six months.
How long is the information kept for?
For information about how long we hold personal data, see the retention schedule in this statement.
How we make decisions about recruitment
Final recruitment decisions are made by hiring managers and members of our recruitment team. We take account of all the information gathered during the application process.
As an individual, you have certain rights regarding your own personal data.
For more information on your rights, please see ‘Your rights as an individual’ .
Do we use any data processors?
Yes – we use several processors to provide elements of our recruitment service for us.
We use recruitment agencies and staffing agencies to help to fill our vacancies.
If you accept a final offer from us, some of your personnel records will be held on our accounting systems. This will include your name, bank details, address, date of birth, National Insurance Number and salary.
Likewise, your details will be provided to the administrator of our Pension Scheme. After successful completion of the 6 month probationary period, You will be auto-enrolled into the pension scheme and the details provided will be your name, date of birth, National Insurance number and salary. Your bank details will not be passed to the pension scheme at this time.
For information about how long we hold personal data, our retention schedule is as follows:
|Trigger||Retain for||Asset Owner|
|Employee files and training records||End of employment||6 years||CFO|
|Payroll Sheets||End of employment||6 years||CFO|
|Employee bank details||End of employment||3 months after final settlement||CFO|
|3 rd party NOK details||End of employment||Immediate||CFO|
|Unsuccessful applicant details||Decision not to recruit||1 month||CFO|
|Maternity, paternity, adoption leave, etc||End of financial year after return||3 years||CFO|
|Customer Contact Details||End of contract||10 years||CFO|
|User details (Passenger Assist)||End of contract||6 months||Head of IT|
|User Details (Defect Report)||End of contract||6 months||Head of IT|
|Supplier contact details||End of contract/receipt of goods||10 years||CFO|