Transport for Wales respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
We’ve provided detailed information on:
- When and why we collect your personal information;
- How we use it;
- The limited conditions under which we may disclose it to others; and
- How we keep it secure.
Transport for Wales is committed to ensuring that your privacy is protected. If we ask you to provide information by which you can be identiﬁed when using this website, you can be assured that it will only be used in accordance with this notice.
Transport for Wales may change this notice occasionally by updating this page. You should check this page from time-to-time to ensure that you are happy with any changes. This notice is eﬀective from 1st May 2021.
We are Transport for Wales, which incorporates Transport for Wales Rail Ltd. Our Address is 3 Llys Cadwyn, Pontypridd, Rhondda Cynon Taf, CF37 4TH.
Transport for Wales is the controller and responsible for your personal data (collectively referred to as "TfW", "we", "us" or "our" in this privacy statement).
Our registered reference number with the Information Commissioner’s Office is ZA209543.
We have appointed a data protection oﬀicer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details Postal address: Data Protection Oﬀicer, Transport for Wales, 3 Llys Cadwyn, Pontypridd, Rhondda Cynon Taf, CF37 4TH E-mail: email@example.com
You have the right to make a complaint at any time to the Information Commissioner's Oﬀice (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the ﬁrst instance.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
1. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identiﬁed. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer diﬀerent kinds of personal data about you which we have grouped together follows:
- Identity Data includes ﬁrst name, maiden name, last name and title.
- Contact Data includes address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Proﬁle Data includes your interests, preferences, feedback and survey responses.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you when you visit our site (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and oﬀences.
Applying for a job via the TfW’s website portal
Please see our job applicant privacy notice on our careers page for information on the personal data we collect if you are applying for work with us.
2. How is your personal data collected?
We use diﬀerent methods to collect data from and about you including through:
Direct interactions. You may give us your Identity Data and Contact Data by ﬁlling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- subscribe to our email updates;
- request marketing to be sent to you;
- [enter a survey]; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie section below for further details.
Third parties. When you sign up for our email updates, we may receive Contact and Marketing and Communications Data from the email marketing service provider, MailChimp, based outside the EU. More information is available on their website at https://www.mailchimp.com/legal/privacy
3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
When you first buy a Season Ticket, your details will be recorded, and a record will be kept of your details and the details of the Season Tickets(s) that you buy. This enables us to provide you with greater assistance if your Season Ticket is lost or stolen, or if you need to make a claim for a delay under a Train Company’s Delay Repay Scheme.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identiﬁed what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the speciﬁc purpose for which we are using your data. Please contact us if you need details about the speciﬁc legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
The following terms are used in the table below:
means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Comply with a legal or regulatory obligation:
means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To send email updates to users who request them||(a) Identity
|Necessary to develop our services and marketing strategy|
|To respond to any comments or queries you send us||(a) Identity
|Necessary to improve our services|
|To enable you to complete a survey||(a) Identity
(d) Marketing Communications
|Necessary to study how users use our services and to develop them|
|To administer and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for the provision of administration and IT services, network security, to prevent fraud)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website and user experiences||Technical||Necessary to deﬁne types of users of our site, to keep our website updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about services or news stories that may be of interest to you||(a) Identity
|Necessary to develop our services|
|Legal Liability Insurance Claims||(a) Identity
|When making a personal injury claim against Transport for Wales additional identity information is required in order to register the claim with the Compensation Recovery Unit. This will include date of birth and national insurance number. This information will be shared with the Claims Underwriting Exchange (CUE), the Motor Insurers Bureau (MIB) and other identification and fraud detection companies in the prevention and detection of insurance fraud. Transport for Wales takes a zero tolerance approach to insurance fraud, and personal data may also be shared with the Insurance Fraud Bureau (IFB) or the police and other crime agencies to detect and prevent fraud|
We will get your express opt-in consent before we share your personal data with any company outside TfW for marketing purposes.
You can ask us or third parties to stop sending you marketing messages or email updates at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time by email at firstname.lastname@example.org.
Our Cookie Notice is available at tfw.wales/cookies.
4. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above:
Service providers acting as processors based in the United Kingdom who provide,
- Customer service, IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for speciﬁed purposes and in accordance with our instructions.
5. International transfers
In most cases, your personal data is stored securely within the United Kingdom.
Some of our external third parties are based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is aﬀorded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by UK Government. For further details, see the UK Information Commissioners Office (ICO) guidance on adequacy.
We may also transfer your personal data to countries that have no adequacy decision granted, and where this is the case, we only do so under the protection of standard contractual clauses (SCC’s) in accordance with international data sharing regulations.
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of conﬁdentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulﬁl the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indeﬁnitely without further notice to you.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for speciﬁc legal reasons which will be notiﬁed to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not aﬀect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request speciﬁc information from you to help us conﬁrm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.