Clean Bus Fund survey privacy policy

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.

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.

Summary of the survey

TfGM is to conduct semi-structured interviews with applicants of the Clean Bus Fund to understand the impact of funding on bus operators’ fleets in terms of compliance and mitigating risks by the Greater Manchester Clean Air Plan to support project evaluation.

The interviews will also gauge satisfaction with the application process and identify any issues with using the funding for retrofitting/replacing vehicles, which will be fed back to the project team. TfGM is the Data Controller. This means that TfGM make decisions on how personal data is processed and for what purposes.

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

Selected bus operators will be contacted by email to arrange a suitable time to conduct the interview to participate in the Survey. The personal information we hold in order to contact you may include your name and phone number, physical business address and email address.

The surveys will be achieved by telephone and/or Microsoft Teams and will ask questions to provide insights and opinions to gather feedback on the application process and the impact of the funding on the compliance of the bus fleet. The survey includes lines of questioning around:

• Confirmation of number of vehicles receiving funding
• Satisfaction with the application process
• If vehicles have since been upgraded (if not the reasons why), compliance of the current fleet, and the impact funds have had in preparing for compliance.
• A recontact question seeking consent to follow up with respondents on the CBF in future.

Our lawful basis for processing under GDPR

Article 6 1(e) 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.

No processing of sensitive data or special category data is envisaged for the purposes of the Survey. Where TfGM may be processing inferred special category data appropriate safeguards are applied by the use of anonymisation and pseudonymisation where appropriate. The lawful basis we apply in those circumstances is:

Article 9 2(g) processing is necessary for reasons of substantial public interest

How information is collected

Surveys are completed via telephone or by Microsoft Teams by TfGM in line with the UK GDPR.

How we ensure the security of your data

TfGM complies with its obligations under the UK GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

TfGM has technical and organisational measures in place to ensure respect for the principle of data minimisation and only the absolute minimum amount or type of personal data required is processed. All survey information will be encrypted with a secure password. All data from the survey will be analysed anonymously with all other survey data. TfGM may report the aggregated anonymised findings of the survey to the Joint Air Quality Unit (JAQU). No individual will be made identifiable during reporting.

Information retention

We will only keep your information for as long as we need to for legal reasons, or for the length of time that we need to for our business needs. Our Retention schedule tells you how long we keep certain types of information. Data will be kept for the length of the project and assigned retention schedule in line with TfGM policies.

Transferring data

Data collected and stored by TfGM will be stored in the United Kingdom.

Data sharing

The information collected as part of this survey will only be used by TfGM for the purposes explained above. TfGM may in the future share the results of the surveys or aggregated/anonymised data with our research partners. Individuals will not be identifiable in any results or data shared.

What rights do individuals have?

TfGM must comply with the UK General Data Protection Regulations (GDPR) and the Data Protection Act 2018.

Under data protection law, your rights include:

• 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: data.protection@tfgm.com

How can I make a complaint?

If you are not satisfied with how TfGM is using the information we hold about you, please contact our Data Protection Officer by emailing data.protection@tfgm.com data.protection@tfgm.com

If you are still not satisfied with TfGM's response to any request to exercise your individual rights or if you believe that TfGM 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