Privacy

Transdev Dublin Light Rail Limited (Transdev Ireland)

Privacy Notice

25 May 2018

This is the Privacy Notice of Transdev Dublin Light Rail Limited (“Transdev Ireland”).  It provides information about what personal data (personal information) we collect and use about individuals outside our organisation, including users of our websites (www.luas.ie and www.transdevireland.ie) and about customers of Luas.

Index to Privacy Notice

  1. About Us
  1. What is the purpose of this Privacy Notice?
  1. What is data protection and why are we concerned about it?
  1. What are the data protection rules?
  1. What information we hold about you and why
  1. Basis of our use of your personal information
  1. If you fail to provide personal information
  1. Do we need your consent?
  1. Automated decision-making
  1. Information about our data processors and other recipients of personal information from Transdev Ireland
  1. Transferring information outside the EEA
  1. Data security
  1. Data retention: how long will you use my information for?
  2. Please help us to keep your information accurate and up-to-date

  3. Your rights in connection with personal information
  1. Our Data Protection Officer
  1. Right to complain to the Data Protection Commissioner
  1. Changes to this Privacy Notice
  1. About Us

We are Transdev Dublin Light Rail Limited (referred to as “we”, “us”, our” or “Transdev Ireland” in this Privacy Notice).  We are the operators of the Luas Light Rail Service in Dublin.  We provide the service under contract from the National Transport Authority (“NTA”, see www.nationaltransport.ie) and Transport Infrastructure Ireland (“TII”, see www.tii.ie). 

Our contact details are: Transdev Dublin Light Rail Limited, Luas Depot, Red Cow Roundabout, Clondalkin, Dublin 22, D22 C5P3. More information about our functions and services is available on our website at www.luas.ie and on the corporate website at www.transdevireland.ie.

Please read this Privacy Notice in conjunction with our Terms and FAQs relating to Luas Services, and with the Luas Bye-Laws, all available at www.luas.ie.

We have appointed a Data Protection Officer (DPO) to oversee our compliance with data protection rules. More information about our DPO, including contact details, is provided in Section 16.

  1. What is the purpose of this Privacy Notice?

Transdev Ireland collects and uses personal data (personal information) about individuals who come in contact with us, for a variety of purposes, including about Luas customers and about app and website users.  In circumstances where we are responsible for deciding how we hold and use personal data about individuals, we are a “data controller”.

This Privacy Notice provides information about the personal data that we collect about customers of the Luas Light Rail Service and related services (including Park+Ride services, Luas TaxSaver and the Luas Text Service) (“Luas Services”) and about users of our app and websites (www.luas.ie and www.transdevireland.ie). The Luas Text Service is a service that allows Luas customers and members of the public to discreetly report incidents of anti-social behaviour that they witness on board Luas trams or at Luas stops.

We use cookies on our websites, and for more information about this, please see our Cookie Notices on our websites. 

This Privacy Notice also provides information about other personal data that we collect and use about individuals who are external to our business.

As outlined the About Us section above, we operate the Luas Services under contract from the National Transport Authority (“NTA”, see www.nationaltransport.ie) and Transport Infrastructure Ireland (“TII”, see www.tii.ie).  We are a data controller of personal information collected on our websites including in relation to Luas Standard Fares and Luas TaxSaver and for the Luas Car Park Payment System, as well as of CCTV footage captured at Luas stops and on Luas trams and in relation to the operation of the Luas Text Alert Service.  We provide more information in this Privacy Notice about these data processing activities. 

The NTA and TII are the data controllers of certain of the personal information that we process in relation to the Luas Services. In particular, they are responsible for personal information that is collected and used for the purposes of issuing Leap cards and they operate the websites www.leapcard.ie and www.studentleapcard.ie.  For example, we process applications for Leap cards, and where we do so, we are data processors of this personal information on behalf of the NTA and TII.

It’s also very important to note that the NTA and TII have certain rights under our contract with them to access Luas customer information and, when the contract between us ends, to have that Luas customer information transferred to them and/or to a succeeding service provider for the Luas. 

Where we refer to our data processing activities in this Privacy Notice in relation to the Luas Services, please note that we are also doing so in relation to data processing that we are undertaking for and on behalf of the NTA and TII, as identified above.

The primary data protection legislation that applies to us is the EU General Data Protection Regulation (the GDPR) effective from 25 May 2018, and Irish legislation that supplements the GDPR (being the Data Protection Acts 1988 – 2018 and the ePrivacy Regulations 2011).  One of our obligations under the GDPR is to be transparent with you about our collection and use of personal information about individuals.

  1. What is data protection and why are we concerned about it?

Data protection law provides rights to individuals with regard to the use of their personal information (personal data) by organisations, including Transdev Ireland.  Irish and EU laws on data protection govern all activities we engage in with regard to our collection, storage, handling, disclosure and other uses of personal data.

Compliance with the data protection rules is a legal obligation.  In addition, our compliance with the data protection rules helps individuals to have confidence in dealing with us and helps us to maintain a positive reputation in relation to how we handle personal information.

The data protection rules that apply to us are contained in the EU General Data Protection Regulation (the GDPR) effective from 25 May 2018, and in Irish legislation that supplements the GDPR (being the Data Protection Acts 1988 – 2018 and the ePrivacy Regulations 2011).

  1. What are the data protection rules?

The data protection rules require that the personal data (personal information) that we (as data controller) collect and use about you must be:-

  1. Collected and used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about, be sufficient (adequate) for those purposes, and be limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

We must also follow rules in relation to who receives personal data from us (see Section 10 below), transferring personal data outside the European Economic Area (EEA) (see Section 11 below) and about individuals rights in relation to their personal data (see Section 15 below).

  1. What information we hold about you and why

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 (permanently and irrevocably) removed (anonymous data).

There are "special categories" of more sensitive personal data which require a higher level of protection, such as information about a person's health or about commission of criminal offences, prosecution for criminal offences, criminal convictions and/or sentencing for criminal convictions.

We collect, store, and use the various categories of personal information about Luas customers, app and website users and other individuals who are external to Transdev Ireland (that is, outside our organisation).  We have prepared a table (available at the Appendix of this Privacy Notice) which sets out the main categories of personal information we collect about individuals (including but not just Luas customers), why we collect this personal information, our legal basis for collecting and using this personal information, where we got the personal information from and who receives the personal information from us.  

  1. Basis of our use of your personal information

Transdev Ireland will only use your personal information when the law allows us to.  Most commonly, we will use your personal information in the following circumstances:-

We may also use your personal information in the following situations, which are likely to be unusual:-

  1. If you fail to provide personal information

If you fail to provide certain information when requested by Transdev Ireland, then we may not be able to respond or deal with a request that you have made to us (for example, to deal with a complaint that you have made to us or to subscribe to a service that we provide).

  1. Do we need your consent?

Yes, for some uses of your personal information.  Please see the table in the Appendix to this Privacy Notice for more information.  For some uses that Transdev Ireland makes of the personal information that is described in this Privacy Notice, we do not require your consent.  For example, for Luas customers, our collection and use of personal information is mainly based on our contractual obligations.

For marketing communications, we only communicate to individuals who have asked to receive these updates or where we are entitled to rely on “opt-out consent” which are provided for under the rules on direct marketing (for example, for marketing to existing customers who we have transacted with in the previous 12 months or for business-to-business communications).

Please also see our Cookie Notices on our websites (www.luas.ie and www.transdevireland.ie), which explains how and why we use cookies and other information-gathering devices on our websites, and how you can prevent cookies being used.

(Right to withdraw consent)  In the circumstances where you may have provided your consent to the collection or use of your personal information for a specific purpose, you have the right to withdraw your consent for that specific use at any time. To withdraw your consent, please contact our Data Protection Officer (DPO) – please see the section below which provides contact details for our DPO (see Section 16 of this Privacy Notice below). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

  1. Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request reconsideration.

2. Where it is necessary to perform a contract with you and appropriate measures are in place to safeguard your rights.

3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify affected individuals if this position changes.

  1. Information about our data processors and other recipients of personal information from Transdev Ireland

We may share your data with third parties, including our third-party service providers and other recipients. Some of these recipients are our data processors, that is, they can only take and use the personal information that they receive from us strictly only on our instructions and under our control. 

Then there are other recipients which are not our data processors, but which are regarded as separate data controllers, with which we interact and share personal information. These separate data controllers include the National Transport Authority and Transport Infrastructure Ireland: these are the public authorities which have contracted us to operate the Luas. It also includes our auditors and solicitors (to the extent that they might need to review our records in order to provide professional services to us) and our payment services provider (to facilitate payments made to us).

We require all our data processors to respect the security of your personal information and to treat it in accordance with the law.

We will share your personal information with these third parties where required by law, or where we have legitimate interest in doing so (for example, to help us to efficiently operate our business).

We may transfer your personal information outside the EU or our data processors may do so.

If this happens, you can expect a similar degree of protection in respect of your personal information.

In the table which is provided in the Appendix to this Privacy Notice, we have outlined the main recipients of personal information from us.  These recipients are either our data processors or are separate data controllers.

Also below is a list of our data processors which process personal information on our behalf, and under our control:-

STT Risk Management, which provides security services in relation to the Luas Services and which can collect and process personal data relating to customer complaints and incidents on the Luas.

Salesforce, which assists us in managing and storing our customer information.

Dovetail, which helps us to manage our fare collection system (e.g. recording fare evasion details, fines issued and action taken on non-payment of fares or fare evasion).

Scheidt & Bachman GmbH, which assists us in providing and maintaining our ticketing machines at Luas stops, including facilitating payments at the ticket machines.

Neon Communication Solutions (“Neon”), which provides us with the technology to enable texts to be sent, received and reviewed by Luas in relation to the Luas Text Service, and which assists us in processing the text messages received by the Luas Text Service.

There are other organisations to which we disclose personal information or with which we share personal information.  These include:-

All our data processors are required to take appropriate security measures to protect your personal information. We do not allow our data processors to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

You’ll also be aware from using the Luas website (www.luas.ie) that we allow you to link to other websites and services, for example to allow you to register for and obtain Leap cards (at www.leapcard.ie, operated by the National Transport Authority), to allow students to register for and obtain Student Leap cards (at www.studentleapcard.ie, operated by the National Transport Authority) and Park+Ride services (at www.parkbytext.ie and www.ncps.ie, operated by Nationwide Controlled Parking Systems Limited).  The NTA and NCPS are separate data controllers to us, and you should refer to their Privacy Notices to understand what personal information they collect about you and how they use it.

  1. Transferring information outside the EEA

We may transfer your personal information outside the EEA or our data processors may do so.

However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects data protection legislation, for example using contractual arrangements with the recipients of personal information that have been approved by the EU Commission (Standard Contractual Clauses) or transferring to recipients in the USA if they subscribe to the Privacy Shield protection mechanism for personal information. If you require further information about these issues, please contact our DPO (see Section 16 below).

  1. Data security

We have put in place measures to protect the security of your personal information.

Our third-party service providers (data processors) will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

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

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

  1. Data retention: how long will you use my information for?

We will only retain your personal information 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 any specific legal obligations that apply to us to retain personal information or records which might contain personal information.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention schedule (or based on applicable laws and regulations where these override our nominated retention period). 

We may retain your personal information longer than our nominated retention period where we need it in order to make or defend legal claims, and if this happens, we will retain the personal information for as long as it takes to finally resolve or have determined the legal claim or the relevant legal proceedings.

Please see the table at the Appendix to this Privacy Notice for more information on the retention periods that we use for the categories of personal information that we collect and use.

  1. Please help us to keep your information accurate and up-to-date

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us. You can do so by contacting our Data Protection Officer (DPO) – see Section 16 of this Privacy Notice.

  1. Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

(How to make requests to us to exercise your rights) If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer (DPO) in writing (see Section 16 of this Privacy Notice below).

(No fee usually required) You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the personal information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information 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 in order to speed up our response.

(Time limit for us to respond to requests) We try to respond to all legitimate requests within one month of receiving them. (One month is the specified time limit for response under the GDPR.) Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated about our timing for response.

  1. Our Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Notice and generally with our obligations under the data protection rules. If you have any questions about this Privacy Notice or how we handle your personal information, please contact the DPO at our office address (Transdev Dublin Light Rail Limited, Luas Depot, Red Cow Roundabout, Clondalkin, Dublin 22, D22 C5P3) or by email at info@luas.ie.

  1. Right to complain to the Data Protection Commissioner

If you have any issues about our handling of your personal information or about our data protection compliance, you have the right to make a complaint at any time to the Data Protection Commission (DPC), which is the Irish supervisory authority for data protection legislation (including under the GDPR).

  1. Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

 

25 May 2018

 

Appendix

Descriptions of the personal information we process, why, where we source it, who receives it and how long we keep it

 

(where NTA and TII are identified as data recipients, this is generally where they are entitled to the return of personal information on Luas customers at the end of the contract)

 

What personal information we collect and use

Why we collect and use the personal information

Legal basis for collection and use

Where we obtain the personal information

Who receives the personal information from us

How long we keep the personal information for

Data relating to customers of Luas Services and (more limited information about) Park+Ride services, including:

·       Customer identification details obtained for the purposes of ID and/or travel cards (Luas 7-day and 30-day tickets or group tickets), including photographs.  This includes information obtained from companies/businesses which provide details (including photos) of their employees for the purpose of availing of TaxSaver discounted tickets.  

·       Customer payment information through use of our ticketing system and regarding payments for Luas fares (including payment of standard fare notices) and for Park + Ride services. (Park+Ride services are provided by a separate company, NCPS, but users can make payment for their parking using Luas ticket machines, and we have access to the NCPS system.)

Note: If customers apply for and obtain Leap cards or Student Leap cards directly through retail outlets or from www.leapcard.ie or www.studentleapcard.ie; or if Park+Ride customers register directly with the Park+Ride service, then we do not obtain this information from the providers of these services. They are separate data controllers to us.

 

To operate the Luas Services (including the 7-day and 30-day Luas ticket services, group ticket services and the TaxSaver service) and fulfil our contracts with Luas Customers

To obtain correct fare payments and deal with fare evasion and to obtain payment for unpaid fares.

To fulfil our contractual obligations to Luas customers.

To fulfil our contractual and legal obligations under our operating contract with NTA and TII.

The Luas Bye-Laws, which we are responsible for implementing.

Customers and (in relation to following up on fare payments) our Revenue Protection Officers.

1.      NTA and TII.

2.      Our ticketing system (and related software) suppliers has access to customer data in relation to our ticketing system in the context of providing support, maintenance and payment services in relation to the ticketing system.

3.      Our payment services providers Realex and its related service providers process customer online payment data; Scheidt & Bachman, TNS, Payware & Sage process customer card payment data.

4.      NCPS (operators of the Park+Ride service) receives payments from us regarding customer payments made at Luas ticketing machines.

 

Luas tickets: 4 months on live system; data deleted within one year of being transferred onto the archive system).

TaxSaver: employers: active customers for as long as remain active; inactive customers (including of employees who were registered): deleted from live system and then kept in archive for two years).

Standard Fare Notices:

·       For paid fines and related Standard Fare Notice information: 2 years.

·       For unpaid fines and related Standard Fare Notice information: for as long as required to obtain payment + 7 years.

Contact details for subscribing Luas customers, including email address and mobile number.

This includes personal information provided by individuals who register for an account on www.luas.ie to be updated with offers and information (“Sign up for Info & Promos”).

To market Luas Services to subscribers.

Consent (where the person is not an existing customer and has chosen to positively opt-in to receive marketing communications).

“Soft opt-in” (legitimate interests) as permitted under the ePrivacy Regulations 2011, where the person is an existing customer or we are sending B2B marketing communications.

 

The individuals to whom we marketing, including our customers.

1.      NTA and TII.

2.      Salesforce, which assists us in managing our customer information.

3.      Newsweaver, which assists us in sending e-zines to subscribing Luas customers

 

For as long as the person remains subscribed to the service.

For unsubscribers: customers via unsubscribe option at the bottom of email (through Newsweaver), their contact details are removed from our contact list immediately.

For customers who notify that they wish to unsubscribe from email alerts via info@luas.ie (through Salesforce): within 30 days (removal is manual).

 

Data relating to customer feedback, queries and customer complaints received via our Customer Call Centre, via email, as communicated to our staff and to our security contractors (STT), via customer feedback forums, customer satisfaction surveys, from Luas social media accounts (Facebook and Twitter) and from other communications from customers.  This data includes customer names and contact details and details of the incident or issue experienced by the customer.

 

To deal with customer complaints and queries and to correct and/or improve Luas Services;

To take action in relation to incidents (e.g. anti-social behaviour or criminal behaviour) on the Luas or at Luas stops, including if the customer is required to provide evidence as part of the follow-up. This can include legal action and/or reporting to the Gardai.

To fulfil our contractual and legal obligations under our operating contract with NTA and TII.

The Luas Bye-Laws, which we are responsible for implementing (in the context of complaints that relate to breaches of the Bye-Laws).

Our legitimate interests in dealing with and resolving complaints, in correcting and/or improving Luas Services and in protecting our rights and business.

Legal obligations in the context of crime reporting and assistance to the Gardai.

 

Customers (directly or via information relayed to our contractors (e.g. STT)).

Our CCTV system (if a reported incident needs to be verified).

1.      NTA and TII.

2.      Salesforce, which is the system we use to record the customer feedback, queries and complaints and the actions taken.

3.      STT, our security contractor, in relation to customer feedback, complaints and/or incidents reported to them.

4.      Our CCTV service provider, CCTV Ireland, to assist us in converting the CCTV camera footage to a viewable format.

5.      The Gardai, to the extent that any customer communication involves the reporting of a crime.

(To the extent that customer information is relayed by those customers via our Luas social media accounts (Facebook and Twitter), note that Facebook and Twitter are also data controllers in relation to the personal data processed by them on these accounts.)

 

·       Recordings of calls are kept for 28 days, then archived for 3 years.

·       Staff notebooks which are used to keep notes about the calls are kept for 6 months in live files are then archived for one year.

·       Postal queries: the letter is held in live files for 4 months, and then archived for one year.

·       For queries and complaints received via our websites and by email: we keep for one month and then we delete.

·       If any queries or complaints are escalated for investigation and action, details about the complaint or query (and related personal information) is kept for as long as takes to resolve issue/incident and (if applicable) deal with legal claims or legal proceedings.

Information about users of the websites www.luas.ie and www.transdevireland.ie and of the Luas App, including where users/customers or their employers register for services directly provided on the www.luas.ie website (e.g. the TaxSaver service). Note: the Leap card websites (www.leapcard.ie and www.studentleapcard.ie and the Park+Ride website are independent of Transdev Ireland and are operated by the National Transport Authority and by NCPS.

In relation to the websites at www.luas.ie and www.transdevireland.ie, we use cookies to obtain information on the browsing habits of users of our website (being internet log information and visitor behaviour patterns).

Please see our Cookie Notice on our website homepage for more information link.

 

To better understand what users/customers are interested in with regard to Luas Services, and to improve our website and the information and services provided on it.

Customer consent (based on the cookie notice provided on the homepage of our website).

Our legitimate interests in understanding the interests and requirements of users of our website, so that we can improve the website and the services provided on it.

Customers.

1.      NTA and TII.

 

No longer than 2 years.

CCTV footage, captured at Luas stops and on Luas trams, and at our office premises.

 

For security purposes, and to enable us to investigate incidents (e.g. accidents,  anti-social behaviour, property damage and/or personal injuries).

 

To fulfil our contractual and legal obligations under our operating contract with NTA and TII.

The Luas Bye-Laws, which we are responsible for implementing (in the context of complaints that relate to breaches of the Bye-Laws).

Our legitimate interests in investigate incidents (e.g. accidents, anti-social behaviour, property damage and/or personal injuries) and in protecting our rights and business.

Legal obligations in the context of crime reporting and assistance to the Gardai.

 

From the CCTV footage and recordings.

1.      Salesforce, which is the system we use to record the customer feedback, queries and complaints and the actions taken.

2.      Transit9, via the system provided by them to assist in recording incidents.

3.      STT, our security contractor, in relation to customer feedback, complaints and/or incidents reported to them.

4.      Our CCTV service provider, CCTV Ireland, to assist us in converting the CCTV camera footage to a viewable format.

5.      The Gardai, to the extent that any customer communication involves the reporting of a crime.

 

·       CCTV footage that does not reveal any incident which is required to be investigated is deleted within 28 days.

·       CCTV footage that reveals incidents (including health & safety-related incidents or incidents that could result in civil or criminal proceedings) is retained for 10 years (in compliance with health & safety legislation) or for as long as required to resolve the legal claim, whichever period is longer.

 

 

For texters to the Luas Text Service, the texter’s mobile phone number and the text they sent. 

When we receive a text to the Luas Text Service, we may also check the CCTV footage on the tram and/or at the tram stop for the time of the reported incident, and this footage may include footage of the texter to the Luas Text Service and it may identify them.

To enable us to identify, address, and track anti-social behaviour on the Luas or at Luas stops and/or to identify, address, and track damage to Luas property in real time.  

For the sending to us of the text and related mobile number, this is based on the texter’s consent. 

Our further processing of the information is based on our legitimate interests (see Purpose(s) of Processing in this Schedule).

The texter + our own CCTV footage.

(Note that our CCTV footage may be processed on our behalf in certain limited circumstances by CCTV Ireland.)

1.      NTA and TII.

2.      Our text service provider, Neon Communication Solutions and Transit9, to assist us in operating the text service.

3.      Our CCTV service provider, CCTV Ireland, to assist us in converting the CCTV camera footage to a viewable format.

4.      Depending on the nature of the incident, we may be required to pass the texter’s information to the Gardaí, particularly if the Gardaí are investigating criminal activity on the Luas (or at Luas stops) and the texter is a witness to the commission of a crime.

 

Texts received are deleted within 60 days.

Data captured by the Luas Service Delivery Application (system that we use to record the day-to-day running of Luas services and incidents), which can include personal information about customers if there is an incident.

To operate the Luas Services.

For security purposes, and to enable us to investigate incidents (e.g. accidents,  anti-social behaviour, property damage and/or personal injuries).

 

To fulfil our contractual and legal obligations under our operating contract with NTA and TII.

The Luas Bye-Laws, which we are responsible for implementing (in the context of complaints that relate to breaches of the Bye-Laws).

Our legitimate interests in investigate incidents (e.g. accidents, anti-social behaviour, property damage and/or personal injuries) and in protecting our rights and business.

Legal obligations in the context of crime reporting and assistance to the Gardai.

 

From employees, sub-contractors and customers who report to us.

1.      NTA and TII.

2.      Transit9, our application provider of the Luas Service Delivery Application.

3.      STT, our security contractor, in relation to incidents identified.

4.      Our CCTV service provider, CCTV Ireland, to assist us in converting the CCTV camera footage to a viewable format if relevant to corroborating an incident recorded on the central control room system.

5.      The Gardai, to the extent that any customer communication involves the reporting of a crime.

 

Definitive retention periods are not finalised, but we hold the data for at least 10 years (in accordance with health & safety obligations) or if the personal information is required for the purposes of legal claims or legal proceedings, for as long as required to resolve those legal claims or proceedings, whichever period is longer.

Lost property: name and contact details for individuals who contact our Lost Property Section; personal information contained in lost property handed in to us or discovered at Luas stops or on trams. (This can include ID cards or bank cards.)

To enable us to track and return lost property.

To fulfil our contractual and legal obligations under our operating contract with NTA and TII.

Our legitimate interests in operating our business: it is right to try to assist customers in obtaining their lost property.

From customers who contact us to seek their lost property.

From banks or other sources which we contact (depending on the contents of the lost property) to enable us to track down the owner. (Note we return lost bank cards to the relevant banks.)

 

1.      NTA and TII.

 

We keep physical objects for 46 weeks.

We keep personal contact information in relation to lost property for one year.

Name, contact details, claim information and payment details relating to customer who seek refunds.

To enable us to process refunds.

To fulfil our contractual obligations to Luas customers.

To fulfil our contractual and legal obligations under our operating contract with NTA and TII.

 

From customers seeking the refunds.

1.      Realex (our payment processing service provider), for refunds to credit/ debit cards.

2.      NTA and TII, including Leap (NTA/TII), for refunds to Leap cards.

3.      RW Pierce, for refunds by cheque.

We keep refund file (containing the claimant’s personal information) for 4 months on our live files and then in archive files for one year.

The refund amount (which does not contain any personal information) is held by our Account Department for the current year plus 5 years.

 



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