Privacy policy

Introduction

Transport for Wales respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit this website, haveyoursay.tfw.wales and dweudeichdweud.trc.cymru (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

Our collection, use and disclosure of your personal information is regulated by the European Union’s General Data Protection Regulation (‘GDPR’) and the Data Protection Act 2018.

In this statement, we've provided detailed information on:

  • When and why we collect your personal information; 
  • How we use it;
  • The limited conditions under which we may disclose it to others; and
  • How we keep it secure

Transport for Wales is committed to ensuring that your privacy is protected. If we ask you to provide information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this notice. 

Transport for Wales may change this notice occasionally by updating this page. You should check this page from time-to-time to ensure that you are happy with any changes. This notice is effective from 1st October 2022. 

The software platform this website runs on and associated technology operations are provided by Granicus LLC. Click this link for the Privacy Policy governing their service.

Controller

We are Transport for Wales, which incorporates Transport for Wales Rail Ltd. Our address is 3 Llys Cadwyn, Pontypridd, Rhondda Cynon Taf, CF37 4TH.

Transport for Wales is the data controller and responsible for your personal data (collectively referred to as "TfW", "we", "us", or "our" in this privacy statement).

Our registered reference number with the Information Commissioner’s Office is ZA209543.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details Postal address: Data Protection Officer, Transport for Wales, 3 Llys Cadwyn, Pontypridd, Rhondda Cynon Taf, CF37 4TH E-mail: dataprotection@tfw.wales

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

This website may contain links to third-party websites, plug-ins and applications. 

Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

In line with GDPR, we have taken steps to reduce the amount of personal data that we need to collect in order to carry out our business.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • identity data includes first name, last name and title. 
  • demographic data, relating to your gender, age, race, ethnicity and postcode (partial)
  • contact data includes address, email address and telephone numbers.
  • technical data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • content you share with us to projects that we have listed for engagement or consultation, this includes responses to surveys, comments on discussion forums or any of the other engagement opportunities available here.
  • marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences

We also collect data about your usage of this site such as the pages you've visited or the documents you've downloaded.

Please note that you are able to browse any publicly accessible sections of this website completely anonymously without signing up.

2. How is your personal data collected?

We use different methods to collect data from and about you including through direct interactions.  You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you:

  • register to use this site
  • subscribe to our email updates;
  • request marketing to be sent to you;
  • responding to a survey or another engagement tool hosted on this site; or
  • give us some feedback.

Automated technologies or interactions.  As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie section below for further details.

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

A 'legitimate interest' means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. 

This means we may use your personal data to:

  • Improve our engagement with the people of Wales and ensure that the engagement we undertake is representative of the communities with an interest in our work
  • support our analysis of responses to surveys or engagement tools
  • communicate information to you about engagement opportunities, events and other initiatives; and
  • respond to enquiries and otherwise engage with stakeholders
  • to comply with a legal or regulatory obligation

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Third-party marketing

We will ensure that we get your express opt-in consent before we share your personal data with any company outside of TfW for marketing purposes. 

Opting Out

You can ask us or third parties to stop sending you marketing messages or email updates at any time by following the opt-out links on any marketing message sent to you.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
Our Cookie Notice is available at haveyoursay.tfw.wales/cookie_policy

4. Sharing your personal data

We may have to share your personal data with the parties set out below in order to comply with legal obligations or out of legitimate interest:

Service providers acting as processors based in the United Kingdom who provide,

  • Customer service, IT and system administration services. 
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We do not use the data that you provide with us on this website for marketing services other than those related to the activities of this site, and only with your consent on sign-up.

In some circumstances, we work with third-party consultants to help support our projects. They may be contracted to undertake analysis of survey data that we collect, and in this context we will share the data collected from the specific projects they are contracted to support with, with them in order to deliver the function they have been contracted to undertake. Once they have finished processing data, we require them to delete it.

We may also deliver projects in partnership with other organisations, including but not limited to local authorities, other public bodies and companies and charities providing services relating to transport and placemaking. We may share data collected from the specific projects we are working in partnership on, with them for their assistance in analysing responses or to communicate the outputs of an engagement or consultation delivered in partnership. Once they have finished processing data, we require them to delete it.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

In most cases, your personal data is stored securely within the United Kingdom.

Some of our external third parties are based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by UK Government. For further details, see the UK Information Commissioners Office (ICO) guidance on adequacy.

We may also transfer your personal data to countries that have no adequacy decision granted, and where this is the case, we only do so under the protection of standard contractual clauses (SCC’s) in accordance with international data sharing regulations. 

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.