We are registered as a data controller with the Information Commissioner's Office (ICO) under registration number: ZA072414
The data controller is:
Govia Thameslink Railway Limited
24, Monument Street
Registered in England company no. 07934306
Our Data Protection Manager is:
1st Floor, Monument Place
24, Monument Street
Our nominated Data Protection Officer is:
Group Data Protection
The Go-Ahead Group plc
4 Matthew Parker Street
More information about the Data Protection Act can be found on the Information Commissioners Website. The Information Commissioner is our regulator for data protection matters.
1. Information we may collect from you
As “controller” of your personal data, GTR is responsible for making decisions about how and why we process this data, and for ensuring that we do so in accordance with Privacy laws.
“Processing” in this case means the collection, storage, use and sharing of your personal data.
We may collect and process information about you when you:
We collect information such as your contact details, ticket purchases, stations visited (for example for charging the correct fares on smart cards), payment and refund details. We may require additional details for some services, such as your age for age restricted tickets. This information is generally provided by you.
Sometimes we obtain details from third parties, for example if we have taken over a franchise or a complaint is passed to us from another operator.
2. How we use your information
The lawful bases for processing your personal data include:
Where it is necessary for:
Our legitimate interests include data processing which allows us to:
In limited situations, we may process special category personal data, which includes information revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, information concerning your health or information concerning your sex life or sexual orientation.
This will only be done where at least one of the above purposes/justifications, and one of the following additional purposes apply:
In limited situations we may process criminal convictions and offences data, which includes information about actual or suspected crimes such as about fraudulent ticket use and incidents happening on trains. This will only be done where at least one of the purposes/justifications outlined above apply, and when one of the substantial public interest reasons in Privacy Laws (as mentioned directly above) applies – e.g. prevention or detection of crime.
We may use your personal data in the following ways:
3. Sharing or disclosing your information
We will only share or disclose your information as set out in this Policy or in accordance with Data Protection Law and will obtain your consent where we are required to do so. We will only use third parties to process information where we are satisfied that they comply with these standards and can keep your data secure. We may share or disclose information for the following reasons:
4. When we collect information
This section shows the information we collect when you use our website. Before providing us with your details, please read the following important information regarding:
We will only use the information that we collect about you lawfully, in accordance with the Data Protection Law.
The details you provide about yourself and any other information which identifies you (‘Personal Information’) is held by us on this website (the "Site") for operational purposes, for example customer registration or processing payments. We may also use your Personal Information to personalise your experience on the Site by informing you of new products or services that we may think are of interest to you.
We gather general information about users, for example, what services users access the most and which areas of the site are most frequently visited. Such data is used in the aggregate to help us to understand how the site is used.
We gather this information so that we can continue to improve and develop our services to benefit of our users. We may make this aggregated information available to users of the site and also to auditors. These statistics are anonymous and contain no personal information.
When you register with us to set up a travel alert, enter a competition, or buy a ticket, we ask for personal information such as your name, contact details, and other details. Once you register with us and accept our Terms & Conditions, you are not anonymous to us. We may use information that you provide to alert you to our own products and services. We may contact you regarding site changes or changes to the products or services that you use.
If you buy a ticket online with us, we will record your personal details and send you a confirmation email. Your personal data will be used principally to communicate with you with reference to your request.
You may opt-in to receive newsletters, exclusive discounts, special offers and other marketing emails from us. You may unsubscribe at any time by logging in to your account and updating your preferences. Please note changes to your subscription preferences can take up to 14 days to take effect.
Alternatively you can write to our Customer Relations Team at:
PO Box 10240
A cookie is a small piece of information that is sent to your browser when you access a website. Cookies contain information about your visits to that website and the purpose of cookies is to enable our websites to remember you, and your browsing habits, when you visit it again in the future.
In order to increase security we ask you to input a password when you register as a user of the site. Please keep this password secret.
We encrypt your financial information using SSL (Secure Sockets Layer) technology so that no one else can access your credit card details as they travel through the Internet. SSL is certified by Verisign and is recognised as a secure way to pay on-line. As you may be aware, no data transmission over the Internet can be entirely secure. We will always use reasonable endeavours to protect the personal information you provide to us but we cannot guarantee the security of your information and the use of our facilities (e.g. email) is at your own risk. If you have any questions about paying for your ticket through the Site, please contact Customer Relations.
4.2 Customer Relations Data
We collect your information and comments when you contact us by letter, email, web form or phone or social media.
We may hold your name, address, email address, phone number, social media name, ticket details, our correspondence with you, the compensation claims you have made and payment made by us, proof of journey or other supporting information you may provide.
To ensure that we carry have an accurate record of dealings between us (and for training purposes) we may, in certain circumstances, record or monitor telephone calls, however you will always be told when this happens. How we use your personal data
This information is used for administration of correspondence or processing claims you have made, such as delay repay as well as for fraud prevention purposes. We also use it to respond to complaints.
We are required to provide details of your complaint to another Train Operating Company if it relates to their services instead of ours. We may share your correspondence with Passenger Focus or London Travel Watch or the Ombudsman, if you have asked them to act on your behalf under a complaint handling procedure.
We may also share information with other Train Operating Companies for the purpose of fraud prevention. We will only do this where there is a formal data sharing agreement is in place, or where an ad hoc request is received this will be dealt with on a case-by-case basis to ensure that any such disclosure is lawful in accordance with Data Protection Law.
4.3 Ticket Office Purchases
When you buy a season ticket valid for one month or more, we keep a record of this on a database. We keep the following details:
We use this information for contractual obligations, Customer Relations and administration, customer research, marketing and fraud prevention.
We will only send you information about offers and promotions if you chose to receive it and you can change your marketing preferences at any time. We will not pass your personal information to any other organisation outside of our Group of Companies (and Successor franchise or Secretary of State for Transport) for marketing purposes without your prior consent.
If you have agreed to receive information for survey or research purposes, we may share your contact details with a limited number of parties, but only for the reasons you have agreed to. We may also share data in order to provide joint services or tickets.
4.4 Revenue Protection and Penalty Fares
We may collect a range of personal detail during the course of revenue protection activity. This may include name, address, data of birth, proof of ID such as, journey details, payment details, physical descriptions and other information you provide to support an appeal.
We only use this information for the administration of the Penalty Fares scheme, revenue protection, collection of unpaid fares, fraud prevention and the prosecution of travel offences. Sharing data with third parties
We may share your correspondence with:
4.5 Customer Help and Information Points
On our stations, we maintain Customer Help and Information Points and calls are linked directly to our Control Centre or to National Rail Enquiries. Calls are recorded and monitored, but no advance notice is given as this could result in a delay in providing assistance.
Our CCTV is used to capture, record and monitor images of what takes place at our stations, car parks and on our trains, in real time. In limited circumstances, we use body worn cameras which make audio visual recordings. Depending on the type of camera, images are recorded on video tape (analogue) or as digital information. Cameras can be fixed or set to scan an area. In some circumstances, they can be operated remotely by controllers. Why we operate CCTV cameras
We operate CCTV for the following purposes:
We operate cameras at the stations and car parks we manage and on some of the trains that we run.
Network Rail operates CCTV cameras at the following stations:
If you need to see images of yourself recorded by a CCTV camera at one of these stations, you will need to contact Network Rail.
CCTV footage at stations is generally held for a maximum of 30 days from the time of recording before it is automatically overwritten. On train CCTV footage varies depending on the type and model of the train, but it is generally not longer than 30 days.
At our discretion, we may disclose personal data in response to valid requests from the police and other statutory law enforcement agencies.
Before we authorise any disclosure, the police have to demonstrate that the personal data is necessary to assist them in the prevention or detection of a specific crime, or in the apprehension or prosecution of an offender.
Requests from the police are dealt with on a case-by-case basis to ensure that any such disclosure is lawful in accordance with the Data Protection Law.
Some of our CCTV infrastructure is shared with the British Transport Police.
In certain agreed circumstances, they may take control of a limited number of cameras and use them for activities such as the prevention and detection of crime and anti-social behaviour, policing major events and crowd control. We are not responsible for the CCTV when it is in the control of a third party.
We may also disclose personal data to third parties, if required to by law or it is necessary for a legitimate purpose such as defending or bringing legal action. Data Protection Law allows us to do this where the request is supported by:
Legitimate interest may include a request to assist in defending or making a legal claim, for example from insurers following a vehicle collision in a car park. When we are not required to provide CCTV, we will take into account the circumstances and any potential harm to individuals, we will also charge an administration fee and seek indemnity for any use beyond which it is requested.
We use a number of companies to provide replacement buses during disruption or planned engineering. Any CCTV on these buses is the responsibility of the company that runs that particular service.
If you require access to images of yourself recorded by a CCTV camera inside a replacement bus, you should contact the company that operates the service. You can find this information from signage displayed inside each vehicle. External guidelines and best practice
We operate our CCTV systems in compliance with the CCTV Code of Practice issued by the Information Commissioner’s Office in 2014. The Code describes best practice standards which should be followed by organisations operating devices which view or record images of individuals. It also covers other information derived from those images that relates to individuals (for example vehicle registration marks).
5. Where we store your Personal Information
The information that we collect from you will only be stored in the UK or a country which UK GDPR (see section 9) has deemed provides an adequate level of protection (“permitted countries”) or, where it is necessary to disclose it to our processors located outside the permitted countries, other jurisdictions where appropriate legal and security safeguards are in place. Please contact the Data Protection Officer if you wish to find out more about the safeguards.
6. Information Security
We use a range of technical and organisational measures to safeguard access to and use of, your personal information and to ensure it retains its integrity and availability. These include structured access controls to systems, network protection, intrusion detection, physical access controls and staff training. We also consider anonymising or pseudonymising personal data where practical.
7. Your rights
To prevent marketing to you, you have the right to ask us not to process your personal information for marketing purposes. We will usually inform you before collecting your information if we intend to use or disclose it for such purposes. If you do not want us to use your information for marketing purposes either:
It is possible that you may receive a pre-scheduled communication whilst your request is being processed as this can take several days.
If you have any other objections to how we are using your personal data, please contact our Data Protection Manager.
You are entitled to request a copy of the personal information we hold about you.
Please contact us at firstname.lastname@example.org
We may need to ask for some further information, such as checking who you are. You can download and send this form which will help us deal with your request more efficiently.
Please let us know if you want to receive the information electronically.
We aim to get the information to you without undue delay and within one calendar month. If we have any trouble with this timeframe we will let you know within 30 days and explain what the problem is. Sometimes we may hold information that we don’t have to provide, for example it would prejudice a police investigation or contains someone else’s personal data.
In most cases we provide the copy of your data to you for free. We have set out some information about when it might not be free, or provided below.
If you believe the information we hold about you is inaccurate or incomplete you can contact us and ask us to correct it. You may also request any data processing we are carrying out on your data is halted whilst a request for rectification or objection or a dispute over the lawfulness of processing is being considered.
We will provide a response confirming the action we have taken or disagree with taking within 30 days, or provide a response within 30 days if the matter is complex and a further time is needed.
You can request deletion or removal of personal information in some circumstances, such as when there is no compelling reason for its continued processing.
We will provide a response to you without undue delay and within one calendar month, confirming whether/what personal data we have deleted and/or explaining why we don’t agree that some data does not need to be deleted.
If we relied on consent as the ground for processing your personal data, you can withdraw this consent at any time. It does not affect the processing carried out beforehand. You can withdraw consent by contacting Customer Relations, our Data Protection Manager or the Group Data Protection Officer. Where you have consented to receive direct marketing communications, you can withdraw your agreement at any time by updating your preference centre or clicking on the appropriate link in the communication or contacting us as above. We will comply with your request without undue delay and within one calendar month.
You also have a right to request that no further processing takes place in relation to some grounds of processing, such as for direct marketing. We will respond to your request without undue delay and within one calendar month, confirming the action we will or won’t take.
Where you have provided us with personal data and the reasons we are processing it are based on consent or our contract with you, and the processing is automated, you have a right to ask for that information be provided to you or another data controller in a structured, commonly used and machine-readable format. The right may be restricted if it is not practical for us to provide the information in this way or it adversely affects the rights of others.
If we are able to provide your personal data in this way, we will do so in one calendar month or we will let you know within one calendar month if we require more time or there are any issues with carrying out the request.
If you have registered a Key Smartcard then you will be able to access your journey information by logging on to your account.
If you have signed up to receive marketing communications from us, we will use information such as the type of tickets you buy or the stations you use, to send communications which are more relevant to you. We will try and make the communications compatible with the device you are using.
We use automated decision making to calculate the validity and value of Delay Repay claims made through one of our brand websites. If you are not satisfied with the outcome of the claim, you can request it to be manually reviewed by a member of the Delay Repay team. If you remain dissatisfied, you can escalate to our Customer Relations team.
We will try to deal with your request without undue delay and at least within one calendar month. In exceptional circumstances, we may need to extend the time to respond fully, if the request is particularly complex or there are multiple requests. But we will let you know within one calendar month.
We will not charge you a fee for dealing with rights requests, unless they are manifestly unfounded or excessive or in circumstances where copies have been provided previously. We would always let you know if we thought this was the case, so that you can make a decision about what you wanted to do next.
There are various limitations and exemptions in relation to the exercise of rights in Privacy Laws - for example if it would affect another’s rights and freedoms or if we need to retain the information to make or defend a legal claim. We intend only to rely on limitations and exemptions where it is fair to do so and always bearing in mind that it is your personal data.
If you are not happy with the way in which we deal with your data or have dealt with a rights request, then please let us know. Our Data Protection Manager is the first point of contact for dealing with Rights Requests and complaints, and they are assisted by Customer Relations. If you are not satisfied with the way in which they have handled your complaint or rights request then you can contact the Group Data Protection Officer.
If you are not satisfied with their response you can complain to the ICO. Its contact details are:
Information Commissioner's Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
You also have the right to seek a judicial remedy or issue legal proceedings against us.
8. How long we keep your personal data for
We have policies and procedures in place to make sure we do not keep your personal data any longer than required to meet our legal and other obligations.
We generally retain personal data for around 6 months after the legal limitation periods in which claims can be brought or industry recommended periods. We also retain information if we are under a legal or regulatory requirement to do so.
We may also keep your personal data for the purposes of our legitimate interests in running our Group businesses, including anonymising or pseudonymising data for analysis.
The UK general Data Protection regulations (UK GDPR) is a set of regulations designed to keep your personal information safe. Personal information can be your:
GTRis a "Data Controller". This means that it collects and uses information about you. As data controller we are responsible for looking after your information and only using this for relevant purposes.
UK GDPR has some important principles to ensure that we protect your information
We only collect your information so that we can use it to do our job, which is mainly transporting you safely to where you need to go. We also may use your information to:
You must give us quite a lot of the information we need, but there is some information that you can choose whether to let us have it or not. When we ask you for information that you don’t have to give us, we will ask for your permission and let you know why we want it and what we will do with it. If the information we are collecting is information that you can choose not to give, you can tell us to stop collecting it at any time.
We only keep your information for as long as we genuinely need it. We have a policy that tells us how long to keep it for.
We won’t share your information with anyone else without your permission, unless the law says we can or should. If we do share your information, it will generally be with your School or Local Authority.
You have the right to:
Sometimes it might be appropriate for the person who looks after you to ask us for this information.
If you’re worried about how we get and use your information, you can contact our Data Protection Manager at email@example.com or our Group Data Protection Officer at firstname.lastname@example.org.
The registered office for GTR is 3rd Floor, 41-51 Grey Street, Newcastle, NE1 6EE.
If you want to complain about how we use your personal data, you can contact the Information Commissioner’s Officer. You can find out more information about them by visiting https://ico.org.uk/.
We may occasionally update this statement.