TFI Anseo – Privacy

Privacy

TFI Anseo Privacy Policy

This Privacy Policy is issued by the National Transport Authority of Haymarket House, Smithfield, Dublin 7, D07 CF98 (“NTA”, “we”, “us”, “our”). The Rural Transport Programme (the “RTP”) is a nationwide, community based public transport system in rural Ireland that consists of a combination of scheduled public transport services and door-to-door services (“TFI Local Link Services”). “TFI Anseo” is an application and website, powered by Via Technologies Europe B.V, which enables TFI Local Link Services to be booked in advance or on-demand.

The purpose of this policy is to inform you of the data relating to you that we may collect and use in connection with the RTP and the provision of TFI Local Link Services and the uses (including disclosures to third parties) we may make of such data. If you have any questions about our use of your personal data, please contact us at the above or you can contact our Data Protection Officer at
privacy@nationaltransport.ie.

Personal Data that we Collect and Process

We will collect and process personal data relating to you in connection with the RTP and our relationship with you. This personal data may include:

• your name and contact details, including your address, phone number and email address;
• health-related data, to the extent that this is relevant to the provision of TFI Local Link Services;
• your credit/debit card details , where you make payments by credit/debit card or your bank account details if you request a refund;
• details of your location, mobile connection and mobile device to the extent that this is relevant to the provision of TFI Local Link Services, including sending you necessary operational and functional notifications
• any other personal data relating to you that you provide to us or that we generate about you in connection with the RTP or your use of TFI Local Link Services.

Purposes of Processing and Legal Basis

We will use your personal data for the purposes of:

• facilitating your use of rural transport services and TFI Local Link Services, particularly where these involve door to door services and on-demand services
• providing you with information and updates on the RTP and TFI Local Link Services;
• enabling you to pre-order, or order on-demand, TFI Local Link Services;
• enabling you to pay for TFI Local Link Services, where possible, by card payment
• providing you with customer support;
• carrying out research and customer satisfaction surveys;
• generating and analysing statistics regarding usage of the RTP and TFI Local Link Services.  Where possible, personal data will be anonymised before being used for this purpose;
• fraud prevention, investigation and detection;
• establishing, exercising or defending legal claims;
• performing our functions as a public authority and complying with our legal obligations.

The legal basis on which we process your personal data are:

• that this is necessary for the performance of tasks that we carry out in the public interest, or substantial public interest, or in the exercise of official authority vested in us by law and that this is necessary for compliance with a legal obligation that applies to us.
• This includes but is not limited to sections 11.1, 11.2, 48.1 and 73.1 of the Dublin Transport Authority Act 2008, as amended, and sections 38.1, 49(b) of the Data Protection Act 2018, as amended.
• in limited circumstances, that you have given your consent to the processing.

Recipients of Data

We may disclose your personal data to other organisations in connection with the above purposes, including:

• Via Technologies Europe B.V, the third party who we engage to provide TFI Anseo services and related systems
• to operators of public transport services, where they use TFI Anseo to provide bus services
• to the Transport Coordination Units, known as TFI Local Link Offices, the third parties who we engage to manage rural transport operations across the State where they are involved in TFI Anseo
• to third parties who we engage to provide services to us in connection with the RTP and TFI Local Link Services such as professional advisers and auditors;
• to other public authorities and bodies where required or permitted by law, such as the Gardaí or other law enforcement authorities for the purposes of the prevention, investigation or detection of crime.

The following organisations support the NTA in providing TFI Anseo:

Requirement to Provide Data

You are not under a statutory or contractual obligation to provide us with any personal data. However, there are some pieces of information that we require in order to register you with an account on our booking and management systems.

If you do not provide us with the information required, we will not be able to facilitate your booking requirements.

Retention

We will not hold your personal data for longer than is necessary. We retain your personal data for as long as we need it for the purposes described in this Notice, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.

We hold the personal data associated with your Account for the whole duration of the time you are using our services and when you cease to use the services we shall anonymise the data.

Your journey history will be deleted and anonymised after 13 months of the journey being taken.

We will delete Accounts that have become inactive after 13 months’ of inactivity.

Transfers Abroad

In connection with the above we might transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers.  These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission. If you would like to receive further details of the measures that we have taken in this regard, please contact us at privacy@nationaltransport.ie.

Your Rights

You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

• the right to access your personal data;
• the right to request the rectification and/or erasure of your personal data;
• the right to restrict the use of your personal data;
• the right to object to the processing of your personal data; and
• where our processing of your personal data is based on you having provided consent, the right to withdraw your consent to the processing at any time.

If you wish to exercise any of the rights set out above, please contact us at the address above or at privacy@nationaltransport.ie.

Updates

We may occasionally update this policy. We encourage you to periodically review this policy for the latest information on our privacy practices.

Complaints

If you are not happy with the way we are using your personal data or how we facilitate your rights or comply with our obligations under applicable data protection law, you have the right to make a complaint to the Data Protection Commissioner by visiting https://forms.dataprotection.ie/contact

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