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Greater Manchester rail travel survey privacy notice

1. Who we are

Transport for Greater Manchester 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 to law protects you.

2. Summary of the use of personal data for consultation and surveys

Transport for Greater Manchester (TfGM) is dedicated to enhancing the experience of Rail passengers, therefore exploring how, when, and where people travel by train.

TfGM are conducting Origin and Destination surveys of rail passengers boarding trains at five rail stations within Manchester City Centre; Piccadilly, Oxford Rd, Deansgate, Salford Central and Victoria. These surveys are to understand the current day usage of rail including full details of each leg of the rail journey being undertaken. It will enable TfGM to evaluate the changes in rail usage since the surveys were last undertaken in March 2017 in response to both changes in train service provision and the impact of the COVID pandemic.

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

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

The survey will ask for demographic details. This is to allow us to analyse whether certain demographical characteristics are common for the same views.

Demographic questions are optional and include:

  • Age
  • Gender
  • Ethnicity
  • Health and disability
  • Origin and destination postcodes/addresses for journey being made
  • Employment status
  • Annual Income
  • Name (prize draw purposes)
  • Email Address/telephone number (prize draw purposes)
  • Name (IQCS follow up survey)
  • Email Address (IQCS follow up survey)

We process personal information as the law requires us to, or as it’s needed to perform a public function.

For personal data captured on our surveys and consultations we may use:

  • Article 6(1)(a) consent: the individual gives clear consent for us to process their personal data for this specific purpose.
  • Article (6)(1)(e) public task: the processing is necessary for the performance of a task carried out in the public interest.

For special category data we may use:

  • Article 9(2)(a) the individual has given explicit consent to the processing of those personal data for one or more specified purposes”.
  • Article 9(2)(g) processing is necessary for reasons of substantial public interest

4. How we ensure the security of your data

We are committed to keeping your information safe and protected from accidental loss or alteration, inappropriate access, misuse or theft.

As well as technical, physical and organisational controls, we recognise that a well-trained, informed, and security alert workforce minimises privacy risks from human error and/or threats from malicious actors.

We require our service providers to implement appropriate industry standard security measures, and only allow them to process your personal information for specified purposes as written in our contracts with them.

5. Information retention

TfGM will only keep your personal information for as long as the law specifies. Where the law doesn't tell us this, we'll decide how long we need to keep your personal information to meet our business needs.

TfGM will advise on each individual survey/consultation how long the data will be kept for and the reasons for it.

6. Transferring data

For surveys and consultations conducted by TfGM, personal data will not be transferred out of the UK/EU.

Where personal data is transferred outside of the UK/EU TfGM will only do so under certain circumstances including:

  • With your consent
  • If we have a lawful reason or legitimate interest to do so
  • If we use service providers or contractors that are outside of the EU.

In these circumstances TfGM will provide further explanations and continue to make sure that the personal data is protected in the same way as it would be if data was remaining in the UK/EU.

At all times TfGM will comply with UK privacy laws.

7. Data sharing

There may be occasions where TfGM will share information with third parties. Where information may be shared TfGM will only do so if they have a lawful basis to do so and inform individuals who that information will be shared with, what information will be shared, the purpose of the sharing, and the security measures around the sharing.

We may also pass your information to other people and organisations providing a service on our behalf. These providers are legally obliged to keep your details securely and use them only to provide the service to you in accordance with our instructions.

8. What rights do individuals have?

TfGM must comply with the 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:

9. 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 officeofdpo@greatermanchester-ca.gov.uk.

If you are still not satisfied with the 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