Document Control Confidential Ref: PP Issue No: 1.1 Issued: 06.06.19
We are strongly committed to protecting your privacy. We understand the importance of ensuring that the personal information entrusted to us is protected and respected and we therefore treat personal data in accordance with our obligations under the General Data Protection Regulation (2018).
In respect of providing transport services for private and corporate coach hire, York Pullman Bus Company is the controller of your personal data in that we determine what personal data should be collected, processed, retained and shared.
In respect of providing transport services for School Services, York Pullman Bus Company is the processor of your personal data. As the processor, we will never collect, process, retain or share data which is not necessary for the transaction of services.
York Pullman Bus Company and its employees agree to conduct their business according to the following charter:
- We only hold data (e.g. personal and company information) to support the business service that we provide to our clients.
- All information collected about you via our website is the sole property of York Pullman Bus Company and it will not be shared, sold, or released to any other entity without your consent, except where it is required by law and/or legal processes.
- Your details will be added to the York Pullman Bus Company database in order to process your quotation, booking, bus pass request, fulfil our contractual obligations, and keep you up to date with relevant changes to our products and services.
- We will respond immediately to questions about the accuracy of information we hold and process for our clients.
- We will maintain strict data security systems that ensure specific individual information will not be made available to any unauthorised person.
INFORMATION WE COLLECT ABOUT YOU
Information you give to us. This refers to information collected as part of your communications with York Pullman Bus Company such as, by phone, email, social media channels/website, face to face meetings or submission of online or hard copy forms.
- Requests for quotations/bookings for private coach hires, excursions, school trips and weddings. This information can include name, name of school/company/organisation, email, postal address, telephone (landline and mobile), bank account and credit card details.
- Contractual transport services such as ‘home to school transport’. This includes information such as your school name, school address, school business email address, business phone number and contact details of key members of staff.
- Provision of school bus passes. This information includes school name, school address, school business email address, business phone number and contact details of key members of staff and pupil photo ID, name, address, DOB, Parent/Carer’s Details, parent/carer bank and payment details.
Information we collect automatically With regards to each of your visits to our website, we will collect the following information:
- Information that does not identify you: this includes analytical information about your visits to the website; your IP address, geographical location, browser type and version, operating system, source of referral, how long your visit is and which pages you look at.
WHY WE COLLECT THIS INFORMATION?
The information that we collect helps to:-
- Improve our services and provide a better experience for our clients.
- Contact you by phone, post, or email regarding any enquiries, feedback, comments or complaints.
- Fulfil our contractual obligations to our clients, legal obligations and legitimate business interests.
WHO WE SHARE YOUR PERSONAL DATA WITH
Your personal data is never sold or made available to a third party.
There may also be circumstances where we are under a duty to disclose your personal information or share your personal information in order to comply with any legal or regulatory requirement, obligation or request. This includes the police for the prevention or investigation of a crime or our Insurers, legal advisors or other third parties who need access to it in the context of managing, investigating or defending claims or complaints.
York Pullman Bus Company sets the age when a child can give their own consent to processing their information at 16. If a child is younger, then York Pullman Bus Company require consent from a person holding ‘parental responsibility’, (even though our privacy notice is written in language that children will understand). Guardian consent must be verifiable.
York Pullman Bus Company collects children’s data only for provision of services and do not use their personal data in the context of commercial Internet services such as social networking.
What is a cookie?
A “cookie” is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognise your browser and recall your user preferences, giving you a better experience of the site. Cookies may store user preferences and other information for this purpose. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.
List of cookies used on The York Pullman Bus Company website
_utma: stores the amount of visits (for each visitor), the time of the first visit, the previous visit, and the current visit.
_utmb and utmc: are used to check approximately how fast people leave: when a visit starts, and approximately ends (expires quickly).
_utmz: records whether the visitor came from a search engine (and if so, the search keyword used), a link, or from no previous page (e.g. a bookmark).
These cookies enable the function of Google Analytics software. This software helps us take and analyse visitor information such as browser usage, new visitor numbers, response to marketing activity and shopping times. That information helps us to improve the website.
The data stored by these cookies do not identify people and do not collect any personal data.
Full details on the cookies set by Google Analytics are published on the Google website. Cookies set by Google Analytics
How to disable cookies on your browser.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to our users’ needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please be aware that this may prevent you from taking full advantage of the website.
LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website.
Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
We cannot guarantee that the information you send us over the internet is secure, but once we receive it, we will take all reasonable steps to protect the information you supply to us. York Pullman Bus Company will not transfer your data outside of the European Economic Area. Backups of electronically stored data are taken regularly, with strong encryption used to protect all files.
York Pullman Bus Company maintains its statutory rights to hold data for as long as is required for legitimate purposes and legal regulations.
HOW CAN I SEE WHAT INFORMATION YOU HAVE ON ME?
You have the right to get a copy of the information that is held, collected, stored and used about you, at any time. This is called a Subject Access Request. In most cases you will not be charged for making a request. However, York Pullman Bus Company can refuse or charge for requests that are manifestly unfounded or excessive.
By law you have the following rights:-
- The right to be informed – you can make a request regarding the data York Pullman Bus Company collect, store and use about you.
- The right of access – you have the right to know exactly what information is held about you and how it is processed.
- The right of rectification – you are entitled to have personal data rectified if it is inaccurate or incomplete or to notify us of any changes to your circumstances i.e.: address, contact details, email address etc. to ensure accurate records are maintained.
- The right to erasure – also known as ‘the right to be forgotten’, this refers to an individual’s right to having their personal data removed subject to legitimate or legal requirements.
- The right to restrict processing – your right to block or suppress processing of your personal data.
- The right to data portability – allows you to retain and reuse your personal data for your own purpose.
- The right to object – in certain circumstances, you are entitled to object to your personal data being used.
- Rights of automated decision making and profiling – safeguards to protect individuals against the risk that a potentially damaging decision is made without human intervention.
- Right to object where processing is based on public interests or legitimate interests or for direct marketing’.
If you want to access any of these rights, email firstname.lastname@example.org or write to The Data Protection Manager, York Pullman Bus Company, Wetherby Road, Rufforth, York YO23 3QA, who will take your initial contact details and send an appropriate ‘Subject Access Request’ form.
The Data Protection Manager may contact the Data Subject to be sure we have enough information to be sure of the requester’s identity and ask further questions to ensure we have all the information from the requester to find what they want.
RIGHT TO COMPLAIN
If you are in any way unsatisfied with the original decision of a Subject Access Request you have the right to complain. Complaints should be addressed to Commercial Manager, York Pullman Bus Company, Wetherby Road, Rufforth, York YO23 3QA.
You also have the right to take any complaint you may have to your Supervisory Authority. For the UK, this is the Information Commissioner’s Office (ICO). You can register a complaint here https://ico.org.uk/make-a-complaint/ Public
Signature: Date: 01/08/18
Name: Position: Data Protection Manager
Change History Issue Number Issue Date Comments
1.0 12/02/19 Initialissue
1.1 06/06/19 GDPR certification project