At Unicard Limited we take the protection of your personal data, including your sensitive data very seriously, (both terms are explained below in the section headed "The details"). In line with the GDPR (General Data Protection Regulation 2016 and the Data Protection Act 2018) we believe in transparency and as such the following describes your personal data journey within the Unicard Limited environment.
As a Data Controller and Processor, we work alongside many authorities and organisations. Unicard are Joint Controllers working with your Authority, Operator or Council to provide the concessionary travel service.
It is important that you read this privacy notice together with any other notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This notice supplements the other notices and is not intended to override them.
What's a Data Controller or Processor?
A Data Controller is an organisation or individual who determines the purposes and means of processing personal data. What does this mean? An example is where a controller (council, authority or bus company) will need your information to provide you with a service such as a bus pass so they will ask us to create a system to gather that information. A Data Processor is an organisation or individual who is responsible for processing personal data on behalf of a controller. What does this mean? The controller asks us to create a system to gather the personal data for their service and we must make sure we do so in a safe and secure way and only use that data how they instruct us.
Our contact details
Full name: Unicard Limited
Address: Peartree Business Centre, Cobham Road, Wimborne, Dorset, BH21 7PT
Our Data Protection Officer can be reached by calling 01202 850810 and asking for the DPO or by emailing email@example.com. Should you have any queries or wish to exercise any of your rights (which are explained below) please email and we will get back to you as soon as possible.
Young person information
If you are under 16 and aren't sure on the meaning of any of the terms please ask your parent/guardian. We have included information to help. We will need the consent of your parent or guardian where you are under 13 years of age to collect and use your personal data.
What's personal/sensitive data and what's a data field?
Personal data is "any information relating to an identified or identifiable natural person". This means that if information can be used to identify you it is personal, this includes your name, your date of birth, but also IP addresses. Sensitive data (also known as special categories of data) includes sexual orientation, religious beliefs, information about your health and biometric data. This data can be 'direct' or 'indirect' identification. This means if a work title could describe someone, e.g. The CEO of Sizzle Bank, it can be classed as Personal Data, if there is only one CEO of Sizzle Bank. Any area where we ask you to enter information can be described as a data field.
How do we collect your personal data?
We use different methods to collect data from and about you including:
- Direct interactions - By you filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services, create an account with us, request marketing to be sent to you or give us some feedback.
- Automated technologies or interactions - We may automatically collect technical data about your equipment and actions when you interact with us as part of our services, such as through an app or using any electronic card we have provided.
- Third parties or publicly available sources - We may receive personal data about you from various third parties such as the Data Controller listed above, analytics providers such as Google based outside of the EU and from providers of technical and payment services who may be based outside of the EU.
Where do we store this personal data?
All personal data is stored in secure data centres in the EU within a database unique to individual clients/authorities. Before being placed into this central database your personal data could be kept in other secure databases or files whilst we check it is correct. Data will be backed up at additional EU data centres using secure replication technologies.
What's a Data Centre and Replication?
A data centre is a collection of servers (computers) hosted in a secure site, replication means information is copied securely from one place to another.
Who do we share this personal data with?
Your personal data is shared with the Data Controller found at the top of the page, Microsoft (for email storage should you contact us), Unicorn Systems, Euclid, Experian, Credit Call, Google (for IP addresses and google analytics), local authorities and bus operators. We use secure data transfer protocols to pass data between systems including TLS (transport layer security) for emails. To comply with legal or government regulations we may send your personal data elsewhere, this could include government or anti-fraud agencies. However, this transfer will be encrypted and secured. We may also share your personal data with 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. Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
What gives us the right to process this personal data?
We process this information to comply with our clients' (including local authorities) contractual obligations to you. We may also process the data if we have a legal or regulatory obligation to do so (for example if we are required to pass on your personal data to the police authorities) or we have a legitimate obligation to process your personal data and your interests and fundamental rights do not override those interests. Generally, we do not rely on consent other than in relation to sending marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.
If you are under the age of 16 consent will be sought from the person(s) with parental responsibility for you.
What does process data mean?
Process means any action we undertake with your personal data, including collecting, storing, transferring and recording this data.
How long will we hold on to your personal data?
Any personal data that we collect through our systems and has passed our verification checks will be held for 3 months in the verification databases before being added to the unique central database. Once the data has been added to the unique central database it will be deleted from the verification database. Data held within the unique central database will be processed in accordance with the contract you have in place with the Data Controller listed above (and held for the time they have told you). Data that does not pass our verification checks will be held for up to 6 months to allow us to carry out troubleshooting and for further checks. Should these additional checks fail it will be deleted and not be transferred into the central database. If the data passes the further checks then it will be transferred into the central database. Data may be kept for a longer period than the time we have set out above if we are required to keep it for combatting fraud, it relates to a legal case or claim, we are under instruction from police authorities to keep hold of the data or we have any other legal or contractual obligation to keep hold of the data.
How do we look after your personal data?
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 the data controller, you and any applicable regulator of a breach where we are legally required to do so.
Changes to your personal data
It is important that the personal data we hold about you is accurate and current. Please keep the Data Controller informed if your personal data changes during your relationship with us.
Changes to the purpose for which we use your personal data
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
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. We may need to check the accuracy of the new data you provide to us.
- Request the 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. 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 situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. 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 personal 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. 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. If you withdraw your consent, we may not be able to provide certain products or services to you.