Metrolink Privacy Notice

Our core data protection obligations and commitments are set out in the organisation’s primary privacy notice.

This notice provides additional privacy information for: applicants and users of the Metrolink mobility scooter permit scheme; Metrolink customers; and offenders.

For details of how we process ticketing data, and customer complaints and enquiries, please see the Customer Relations Privacy Notice.

For details of how we process CCTV please see the CCTV Privacy Notice

For details of how we process data for marketing purposes, please see the Commercial Services Privacy Notice

Purposes

We obtain your personal information for the following purpose(s):

• To administer the Metrolink mobility scooter permit scheme;
• To undertake revenue protection activities;
• To enforce the Metrolink Conditions of Carriage under the Metrolink Byelaws;
• For research and evaluation purposes; and
• Monitoring of anti-social behaviour.

Categories of personal data

In order to carry out these purposes we collect and obtain:

• Personal details;
• Financial details
• Visual images, personal appearance and behaviour;
• Details of complaints;
• Case file information; and
• Goods and services provided.

We may also collect, store and use the following special category personal information:

• Racial or ethnic origin;
• Health data; and
• Criminal Offence data.

Legal basis for processing

The legal basis we rely on for processing your personal information is:

• The processing is necessary for the performance of a contract with the data subject;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us, namely the operation of the Metrolink light rail network in Greater Manchester under the Greater Manchester (Light Rapid Transit System) Act 1988 and the Greater Manchester (Light Rapid Transit System)(No2) Act 1988; and
• Marketing purposes: where we have asked and you have consented to receive electronic marketing information about our services (you may withdraw your consent at any time).

The legal basis we rely on for processing your special category personal information is:

• The processing is necessary for the establishment, exercise or defence of legal claims;
• The processing is necessary for reasons of substantial public interest under the Data Protection Act 2018, Schedule 1 Part 2, s7(a) for the administration of justice;
• The processing is necessary for reasons of substantial public interest under the Data Protection Act 2018, Schedule 1 Part 2, s8 for equality of opportunity or treatment; and
• The processing is necessary for reasons of substantial public interest under the Data Protection Act 2018, Schedule 1 Part 2, s10 prevention or detection of an unlawful act.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (for example, to provide you with a mobility scooter permit).

Information sharing recipients

We may share personal information about you with the following types of organisations:

• Transport Providers – including KeolisAmey Metrolink in order to operate Metrolink on our behalf; and
• Suppliers – in order to deliver services on our behalf (for example Shopmobility who provide Mobility Scooter safety on trams training).
• Police, HMCTS and other law enforcement agencies in relation to the prevention or detection of crime and/or the apprehension or prosecution of offenders.
• Agencies that assist with revenue protection activities following court proceedings (e.g. Court Enforcement Officers).

Sources of personal data other than the data subject

As well as information directly collected directly from you, we also collect or receive information from:

• Transport Operators;
• Police; and
• GBG Group Plc – our delivery partner uses the GBG Connexus tool to trace, investigate and confirm details provided to us during revenue protection activity.

Automated decisions

For this processing, all the decisions we make about you involve human intervention

Data retention criteria

Our Retention Schedule outlines how long we retain certain types of information for.

Rights of individuals

You have a right to be informed about how and why your personal information is being processed. This notice fulfils that obligation. You also have a number of other rights.

Information about the following rights is available in our Guide to Exercising Your Rights:
- Contacting our Data Protection Officer;
- Raising a concern with us; and/or
- Making a compliant to the Information Commissioner

Updates

We may update or revise this Privacy Notice from time to time and provide supplementary privacy information as is necessary to TfGM’s current workforce.