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1. Who we are

Transport for Greater Manchester ["TfGM"] is committed to making sure that we tell you about the ways in which we use your personal information and that we have the right controls in place to make sure it is used responsibly and kept safe from inappropriate access, theft, or misuse.

TfGM is acting on behalf of the 10 Greater Manchester Local Authorities to undertake a participatory policy development process to develop and shape the new Clean Air Plan Policy, including proposals for funding support. 

The case for a new plan, which has been submitted to Government, sets out evidence supporting an investment-led approach, with no charging Clean Air Zone, to address the city-region's nitrogen dioxide air pollution problem. This is to ensure the right funding and eligibility criteria are in place to enable category B vehicles, which includes buses, coaches, taxis, PHVs and HGVs, to be upgraded to those with cleaner engines, while mitigating any additional economic risk or hardship to residents and businesses.

This process includes a survey or interviews with vehicle owners to ensure the policy is well-grounded in evidence from key stakeholders.

TfGM is the data controller for the personal data gathered from this Clean Air Plan survey activity, which means that they will determine the purpose and means of processing your personal data, with AECOM as a data processor, only processing your personal data on TfGM's behalf.

AECOM have been commissioned to assist TfGM in collecting feedback from the research. As independent consultants AECOM will collate, thematically code, analyse and report on the responses received.

This notice explains how we use your information and tells you about your privacy rights and how the law protects you. For further information about our core data protection obligations and commitments please see TfGM's primary privacy notice.

2. What information we will collect from you (the purpose and legal basis for processing information)

The survey or interviews will ask you questions in relation to the new Greater Manchester Clean Air Plan policy to understand your views. The personal information we process and collect will be provided to use directly by yourself. Whilst it is not compulsory some personal data may be collected in the process of this research. Personal data that may be collected includes:

  • Age

  • Gender

  • Business/organisation details

  • Business/home postcode

  • Email address

  • Location information / geocode

  • Names and titles

We may use your personal details to keep you informed on the development of the Clean Air Plan proposals, as well as providing you with information about support if you are affected by the proposals. We may also use your details to contact you if you are willing to take part in further research/consultation activity.

If you wish to leave the survey and return later, you can enter your email address, and we will send you a link so you can return to the survey where you left.

We may also collect some special category personal data within the research. Special category data is data that is deemed more sensitive. For the purpose of this research, we may collect the following special category data:

  • Physical or mental health information

  • Racial or ethnic group information

  • Religious beliefs or similar

We ask for this data so that we can check impact on different demographic groups and to show we reach a proportionate amount of the community.

You do not have to answer the questions on personal data if you do not want to.

Data collected from this research will be aggregated, so you will not be identified. Anonymised data will be shared with local authorities, academic institutions or contractors working on behalf of TfGM for the development of the new Clean Air Plan and research purposes.

### Lawful basis for processing your information

As TfGM has been asked to co-ordinate this research on behalf of the 10 Local Authorities who have a statutory duty under Section 170 Transport Act 2000, our lawful basis for processing under the UK GDPR is:

  • GDPR Article 6(1)(e): the processing is necessary for the performance of its official tasks carried out in the public interest.

And for special category data:

  • GDPR Article 9(2)(g): the processing is necessary for reasons of substantial public interest

3. How do we keep your information safe?

TfGM is committed to the security of the information we collect, and we use reasonable measures to prevent unauthorised access to that information. We are required to demonstrate that our solutions meet the required levels of personal, procedural, policy, data and technical security. We will only process personal information for the purposes it has been collected or subsequently authorised.

The survey is hosted by AECOM using Askia. Askia is a survey platform which has the highest standards of data security achieving ISO27001 accreditation.

All electronic consultation information will be encrypted with a secure password. AECOM and TfGM will restrict access to your personal information to only people who have a right to know.

4. How long is the information kept for?

Your information will only be kept for as long as necessary. After the research process has closed AECOM will transfer all the responses to TfGM and securely delete their own copies.

TfGM will retain your data for two years, or as long as required if there are any legal challenges to the research.

5. Who we will share your information with?

The information collected as part of this research will only be used by TfGM. Your personal data will not be shared with any other third parties. An anonymised report will be shared with the Greater Manchester Local Authorities. This will not contain any personal data.

If you are responding on behalf of an organisation. The organisation's name may be used but you will not be personally identified.

6. Your rights as a data subject (any individual person who can be identified)

  • The GDPR gives you the following rights over your information:

  • Your right of access - You have the right to ask us for copies of your personal information.

  • Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

  • Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

  • Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.

  • Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.

  • Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

If you wish to make a request, please contact us at:


By post: Data Protection Officer, Transport for Greater Manchester, 2 Piccadilly Place, Manchester, M1 3BG

Further details of how TfGM process your data and how you can exercise your rights are available at

For AECOM's privacy policy, please visit or email

Further information about data privacy and your rights under the General Data Protection Regulation (the "GDPR") can be found at the ICO website

7. How can I make a complaint?

If you are not satisfied with how the GMCA is using the information we hold about you please contact our Data Protection Officer by emailing

If you are still not satisfied with the GMCA's response to any request to exercise your individual rights or if you believe that the GMCA is not processing your personal data in accordance with the law, you can contact the Information Commissioners' Office: 

  • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

  • Telephone: 0303 123 1113