Privacy Notice

We may collect the following types of personal data from you when you contact Independent Travel Toolkit directly:

• Name

• Address

• Contact details including email address and telephone number

• Details about any issues you are wishing to raise

• Health data, where it is applicable to home/school transport, for example

• Criminal offence data, for example, in relation to driver awareness courses, and driver checks

• Audio recordings of live streaming events, for example, public events run by Independent Travel Toolkit

We collect information from members of the public, contractors, and employees from other organisations, whenever they may use our services.

Our reasons for using personal information include:

• Delivery of services and support to you

• Managing our services

• Running consultations

• Determining risks and implementing measures to reduce those risks

• Training workers

• Investigating complaints about our services

• Monitoring and protecting public spending

• Monitoring the quality of our services to ensure they are delivered in the most efficient and effective way

• Helping us to improve and plan new services

• Complying with laws that require us to provide personal information to other organisations, such as health organisations and courts

• Enable communication with user groups/landowners/contractors/volunteers

• Dealing with third party claims for damage/injury caused by or claims for damage to council or highway assets.

1. Personal data

Under data protection law, Independent Travel Toolkit can only process your personal data if it is lawful to do so. Please see the details below of the lawful bases that we rely on for processing different types of personal data.

For processing personal data, we rely on the following lawful basis(es):

• UK GDPR Article 6(1)(a) – where you have provided consent for us to process your information for a specific purpose

• UK GDPR Article 6(1)(b) – where processing is necessary for us to fulfil a contract that we have with you

• UK GDPR Article 6(1)(e) – where processing is necessary for us to perform a task which is in the public interest (public task)

• UK GDPR Article 6(1)(f) – where processing is necessary to meet our legitimate interests which are not part of our public function.

2. Special category data

When we process special category data, we rely on the following additional lawful basis(es):

• UK GDPR Article 9(2)(a) – where you have provided us with explicit consent to process your information for a specific purpose

• UK GDPR Article 9(2)(b) – where processing is necessary for reasons involving employment, social security, and social protection

• UK GDPR Article 9(2)(f) – where processing is necessary to establish, carry out or defend legal claims

• UK GDPR Article 9(2)(g) – where processing is necessary for reasons of substantial public interest, specifically:

1. for statutory and government purposes (Schedule 1, Part 2, section 6, DPA 2018)

2. for the safeguarding of children and of individuals at risk (Schedule 1, Part 2, section 18, DPA 2018)

• UK GDPR Article 9(2)(j) – where processing is necessary for archiving, research or statistical purposes that are in the public interest (Schedule 1, Part 1, section 4, DPA 2018).

3. Criminal offence data – general processing

Independent Travel Toolkit also processes criminal offence data, in particular data relating to driving offences, which may include:

• Information about any criminal record or criminal history

• Allegations of criminal behaviour, including unproven allegations

• Absences of convictions, for example the results of DBS checks, or Police National Computer checks

• Personal data of victims and/or witnesses

• Personal data about criminal penalties that may have been awarded.

In addition to the lawful bases that we have identified under “Personal data” above, we process criminal offence data under the following condition(s) of Schedule 1 of the DPA 2018:

• Where processing is necessary to carry out specific obligations or exercise rights relating to employment, social security, and social protection (Schedule 1, Part 1, section 1, DPA 2018)

• Where processing is necessary for the provision of health and/or social care purposes (Schedule 1, Part 1, section 2, DPA 2018)

• Where processing is necessary for statutory and government purposes (Schedule 1, Part 2, section 6, DPA 2018)

• Where processing is necessary for the administration of justice and for parliamentary purposes (Schedule 1, Part 2, section 7, DPA 2018)

• Where processing is necessary for the safeguarding of children and of individuals at risk (Schedule 1, Part 2, section 18, DPA 2018).

Independent Travel Toolkit relies on legitimate interests as a lawful basis for processing your personal data. The legitimate interest basis under the UK GDPR allows Suffolkonboard to process personal data in ways that you would reasonably expect and that have a minimal impact on you, or where there is a justified reason for processing your data.

Where we rely on consent to process your personal and special category data, you have the right to withdraw that consent at any time. If you would like to withdraw your consent at any time, please contact: customer.services@suffolk.gov.uk

Within Independent Travel Toolkit we may share your personal data to carry out our statutory duties and other services. Information will be shared with the following recipients:

• Other local authorities within Suffolk, including districts, borough, town and parish councils

• County councillors and other elected representatives

• Our contractors and their supply chain who assist the council to deliver services, for example passenger transport services

• Suffolk police

• The Planning Inspectorate

We do not transfer any personal data to any countries or international organisations outside of the EU, the EEA (European Economic Area), or any other country that does not have an equivalent level of data protection to the UK.

Independent Travel Toolkit keep personal data for as long as it is needed it to fulfil the purpose that it was collected for, and in line with any statutory or locally determined retention periods. At the end of its retention period, information will be reviewed and destroyed securely, or archived.

Independent Travel Toolkit does not use automated decision-making processes and/or profiling in respect of your information.

Under data protection law, you have the right to request access to the information that we hold about you. If you would like to make a request to access your personal information, please contact data.protection@suffolk.gov.uk

You also have other rights regarding your personal data. You can find out more information about these rights by looking at the Suffolk County Council’s corporate privacy notice.

If you would like independent advice on this privacy notice or other matters about how Suffolk County Council processes your personal data, including how to make a complaint, you can contact the Information Commissioner’s Office at:

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113

Email: casework@ico.org.uk

You can read Suffolk County Council’s Privacy Notice on our website.

If you would like further information, or if you have any other queries about privacy notice or how Suffolkonboard process your personal data, please contact:

Email: customer.services@suffolk.gov.uk

Telephone: 0345 606 6067 or 0345 606 6171

Suffolkonboard, GHI Directorate, Suffolk County Council, Endeavour House, Ipswich IP1 2BX

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