By accessing and using the London TravelWatch website you agree to our use of your personal information and to be bound by the following terms. If you do not agree to these terms, you should exit this website immediately.

The data controller as defined by the Data Protection Act 2018 for this website is the London Transport Users Committee, operating under the name ‘London TravelWatch’. The Data Protection Officer is Luke Muskett, Communications and Operations Officer.

London TravelWatch considers its obligations under the Data Protection Act 2018 and Freedom of Information Act 2000 and related legislation to be of paramount importance, and has taken steps to ensure compliance with those provisions. This privacy policy explains what information London TravelWatch collects about those customers who register with the ‘londontravelwatch.org.uk’ website and the procedures that we have in place to safeguard your privacy. Further information is available on the information we may hold about you elsewhere on the website.

Information we collect from you

We collect personal information from you if you email us with consumer enquiries and complaints about the transport services as the independent, statutory watchdog for transport users in and around London or with comments and complaints about the service we provide and the information provided on this website.

We also collect data when you sign up to receive alerts about forthcoming meetings or subscribe to our stakeholder e-newsletter.

Information collected may include personal details such as names and addresses, email addresses and details of individual queries. In addition, we collect information on the usage of the site itself. This usage information will not identify you individually and is stored and processed in aggregate and will not allow the identification of individual users.

Please note that you are not required to provide your personal details to use the London TravelWatch website, though if you choose not to this may limit the extent to which you can use the site.

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Lawful basis for processing your data

We are required to have and explain a valid lawful basis for holding and processing your data.

In respect of passenger enquiries and complaints this basis is provided in Article 6 (1) (e) of the General Data Protection Regulation 2018: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. The ‘official authority’ in this case is set out in Section 248 of the Greater London Authority Act 1999 and section 252A of the same Act (as amended by Schedule 6 of the Railways Act 2005).

When signing up for email alerts and to our stakeholder newsletter you are giving us consent to store the personal details you have submitted for as long as you wish to receive these. Depending on what information you provide, we may contact you by post, email or telephone.

How we protect your privacy

Any personal information you provide will be held securely by London TravelWatch in accordance with the Data Protection Act 2018 and the General Data Protection Regulation 2018. These statutes protect your personal information and ensure that:

• we only hold and process your information for purposes that we make clear to you in advance
• we keep your information only for as long as we need to carry out these purposes but this will not be for longer than three years
• we will put in place appropriate measures that ensure your information is held and processed securely and confidentially.

If you provide us with ‘sensitive personal data’ as defined by the Data Protection Act 2018, we will never pass this information on to a third party without your explicit consent. If you withhold such consent, it may limit the extent to which we can deal effectively with your complaint or query.

Sensitive personal data is information relating to a data subject which identifies:

(a) racial or ethnic origin

(b) political opinions

(c) religious beliefs or other beliefs of a similar nature

(d) trade union membership

(e) physical or mental health or condition

(f) sexual life

(g) the commission or alleged commission of any offence, or

(h) any proceedings for any offence committed or alleged to have been committed, the disposal of such proceedings or the sentence of any court in such proceedings.

How we use your information

Consumer enquiries and complaints

If you email us with an enquiry or complaint, we will use the information you have provided to advise you on your rights as a consumer, on how to avoid problems and how to address any problems you may have encountered.

We may need to pass information you have provided to a service provider (often but not limited to a train operator) or to the Passengers Council operating as Transport Focus to address a problem you have encountered. Enquiries may be forwarded to other service providers.

Unless you advise us otherwise, but with the exception of the sensitive personal data described above, we will assume that you have already provided your personal details as they relate to your complaint or query to the third party to which your complaint or query is directed and that you consent to any further processing or routeing of your information as it is necessary, in our opinion, to help you resolve the problem you have asked us to look into. We will only hold details of your enquiry or complaint for as long as we need them but this will not be longer than three years.

We will not share your information with third parties without your prior consent and in the event of being given permission to do this we will always prohibit the onward sharing of any personal data.

If you are making a complaint or query on behalf of another adult or adults, we may ask for written confirmation that you are doing so with their authority. This applies to circumstances, for example, in which one adult contacts us on behalf of a group of travellers who have experienced a similar problem, or where an adult is physically or mentally unable to contact us in their own right. If you are making a complaint or query on behalf of a child under the age of 16, we may ask you to confirm that you are the child’s parent or legal guardian. Please note that we expect anyone over the age of 16 to contact us in their own right, unless there are clear grounds for an adult to contact us on their behalf.

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Freedom of Information or subject access requests

Freedom of Information

The Freedom of Information Act 2000 (FoI) gives the public the right to request information held by London TravelWatch.

The Act aims to ensure that public sector bodies are open and accountable and encompasses any recorded information.

For more information on the Freedom of Information Act please visit the Information Commissioner’s Office.

Information that is already available

London TravelWatch proactively publishes a lot of information on our website to reflect our commitment to openness and transparency. Please check our website before making a request for information www.londontravelwatch.org.uk

Making a FOI request

If you cannot find the information you are looking for, please make your request in writing to the following email address: enquiries@londontravelwatch.org.uk or you can write to us at

Freepost LONDON TRAVELWATCH

Timothys Bridge Road

Stratford Enterprise Park

Stratford-Upon-Avon

CV37 9BG

If your request is unclear, or we cannot identify the information you are interested in, we will write back to you to ask for clarification.

Please also remember that you must provide contact details for where you would like the information to be sent to.

We will acknowledge your request within five working days. Requests will be handled within the statutory time limit of 20 working days but we aim to respond as soon as possible. If we cannot achieve this deadline, we will write to advise you of this and provide an estimated response time.

Although you may request any information that we hold, there are some exemptions under the Acts which mean we may not be able to provide the information you require. If we decide that we cannot release the information requested, we will state which exemptions we have used and clearly explain the reasons why we cannot release the information into the public domain.  If a request is made for a large amount of data, we may refuse the request or impose a charge in accordance with ICO regulations. We will always write to advise you of any charge or offer alternative solutions to provide the data that would not attract a cost.

We will refuse any vexatious requests and repeated requests from the same person.

Making a subject access request (SAR)

An SAR is a request to see all data that pertains to you.  London TravelWatch manages their SAR using the timescales as that of FoI requests.  Requests for large amounts of data may attract a fee.

How to apply to re-use information

Information provided in response to an information access request does not automatically entitle you to re-use that information. Most of the information that we provide in response to Freedom of Information Act 2000 may be subject to copyright protection.

In most cases the copyright will be owned by London TravelWatch but some information may be owned by another person or organisation, as indicated on the information itself.

You are free to use any information supplied for your own non-commercial research or private study purposes. The information may also be used for any other purpose allowed by a limitation or exception in copyright law, such as news reporting. However, any other type of re-use will require the permission of the copyright owner.

For information where the copyright is owned by London TravelWatch you can apply to re-use information by submitting a written request to the address above, including your name and address, details of what information you wish to re-use and the purpose for which the information is to be re-used.

What to do if you are unhappy with London TravelWatch’s response

If you are dissatisfied with our response to your request for information you have a right to an internal review, conducted by someone who was not involved in the handling of your request.

If you are still not satisfied following an internal review you can make a complaint to the Information Commissioners Office.