GDPR Policy

The Confederation of Passenger Transport (CPT) takes the security and privacy of your data seriously. Our full contact details are:

Full name of legal entity: Confederation of Passenger Transport (UK) Ltd

Name or title of data privacy manager: The Company Secretary

Email address: gdpr@cpt-uk.org

Postal address: Fifth Floor (South), Chancery House, 53-64 Chancery Lane, London WC2A 1QS

Telephone number: 020 7240 3131 

We need to gather and use information or ‘data’ about you as part of our service to our membership and to manage our relationship with you. We intend to comply with our legal obligations under the Data Protection Act 2018 (the ‘2018 Act’) and the EU General Data Protection Regulation (‘GDPR’) in respect of data privacy and security. We have a duty to notify you of the information contained in this policy.

This policy applies to personal data held on members, member’s employees, directors of members, past members, delegates at CPT conferences and events and key individuals in the Bus and Coach industries that CPT works with for the benefit of its members.  This policy is not intended for children and we do not knowingly collect data relating to children.

CPT has separate policies and privacy notices in place in respect of job applicants, current and former employees, workers, volunteers, apprentices and consultants and CRB applications.

CPT has measures in place to protect the security of your data in accordance with our Data Security Policy. A copy of this can be obtained from the Finance Director.

CPT will hold data in accordance with our Data Retention criteria as detailed in this policy. We will only hold data for as long as necessary for the purposes for which we collected it.

CPT is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data. 

This policy explains how CPT will hold and process your information.  It explains your rights as a data subject.

Data Protection Principles

Personal data must be processed in accordance with six ‘Data Protection Principles.’ It must:

  • be processed fairly, lawfully and transparently;
  • be collected and processed only for specified, explicit and legitimate purposes;
  • be adequate, relevant and limited to what is necessary for the purposes for which it is processed;
  • be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay;
  • not be kept for longer than is necessary for the purposes for which it is processed; and
  • be processed securely.

We are accountable for these principles and must be able to show that we are compliant.

How we Define Personal Data

‘Personal data’ means information which relates to a living person who can be identified from that data (a ‘data subject’) on its own, or when taken together with other information which is likely to come into our possession.  It does not include anonymised data.

This policy applies to all personal data whether it is stored electronically, on paper or on other materials.

This personal data might be provided to us by you, or someone else (such as an employer), or it could be created by us. It could be provided or created during the membership recruitment process, during CPT membership or in the process of business undertaken on behalf of our members.

We will collect and use the following types of personal data about you:

  • Information supplied on your application form for membership of CPT
  • Contact details
  • Details of any operator (‘O’) licences you hold
  • your images (whether captured by photograph or video)

Special Categories of Data we do not hold or process special categories of personal data. Special categories of personal data are types of personal data consisting of information as to:

  • your racial or ethnic origin;
  • your political opinions;
  • your religious or philosophical beliefs;
  • your trade union membership;
  • your genetic or biometric data;
  • your health;
  • your sex life and sexual orientation; and
  • any criminal convictions and offences.

How we define processing

‘Processing’ means any operation which is performed on personal data such as:

  • collection, recording, organisation, structuring or storage;
  • adaption or alteration;
  • retrieval, consultation or use;
  • disclosure by transmission, dissemination or otherwise making available;
  • alignment or combination; and
  • restriction, destruction or erasure.

This includes processing personal data which forms part of a filing system and any automated processing.

How will we process your personal data?

CPT will process your personal data (including special categories of personal data) in accordance with our obligations under the 2018 Act.

We will use your personal data for:

  • Performing the contract of membership between us or your employer, which includes contacting you to advise you of benefits which, as a member of CPT you are entitled to, either by ourselves or the third party offering the benefit. Such third parties include:
    • Arthur J Gallagher for insurance and risk management
    • Backhouse Jones Solicitors for legal services
    • Brodies Solicitors for legal services in Scotland
    • Language Line Solutions for interpretation and Translation Service
    • Lloyd Morgan Group for compliance support
    • Nationwide Coach Assistance for vehicle breakdown and replacement coach service
    • DKV Euroservice for assistance with fuel bills, tool charges, and VAT /Excise duty recovery
    • TruTac for tachograph analysis
    • CPT Energy for assistance with gas, electricity and water supplies
    • Other organisations that may from time to time be added to this list and notified to you as a CPT member
  • If it is necessary for our legitimate interests (or for the legitimate interests of someone else). However, we can only do this if your interests and rights do not override ours (or theirs).  You have the right to challenge our legitimate interests and request that we stop this processing. See details of your rights below.

We can process your personal data for these purposes without your knowledge or consent. We will not use your personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for processing it.

If you choose not to provide us with certain personal data you should be aware that we may not be able to carry out certain parts of the contract between us. For example, if you do not provide us with your email address or telephone number we will not be able to provide you with the regular technical and industry news bulletins.

Examples of when we might process your personal data

We have to process your personal data in various situations during your recruitment, membership, employment within the bus and coach industry and for a period after (membership and or employment in the bus and coach industry).

For example:

  • To contact you regarding membership of CPT
  • To provide you with regular membership and industry news
  • To elicit your opinion on membership and industry matters
  • To renew your membership
  • To provide statistical data on membership or industry related matters

Access to your personal data

Members of staff will have access to your personal data in order to carry out the contractual obligations CPT has to its members and in order to fulfil the legitimate business interests of CPT.

Other members of CPT will have access to your personal data where it is provided as membership contact information.

Other members and the general public will have access to personal information that you have supplied in your personal profile on the CPT website.

Sharing your personal data

We share your personal data with supplier members of CPT for our and their legitimate interests. These suppliers are all connected to and supply the bus and coach industry with products that are relevant to CPT members. A full list of suppliers can be found in the member’s section of the CPT website, www.cpt-uk.org. With regard to CPT conferences and events the information that you provide will be shared with other delegates as set out in the conference/event terms and conditions.

We do not send your personal data outside the European Economic Area. If this changes you will be notified of this and the protections which are in place to protect the security of your data will be explained.

Subject access requests

Data subjects can make a ‘subject access request’ (‘SAR’) to find out the information we hold about them. This request must be made in writing to the Data Privacy Manager, contact details above.

If you would like to make a SAR in relation to your own personal data you should make this in writing to the Data Privacy Manager. We must respond within one month unless the request is complex or numerous in which case the period in which we must respond can be extended by a further two months.

There is no fee for making a SAR. However, if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to your request.

Your data subjects rights

You have the right to information about what personal data we process, how and on what basis as set out in this policy.

You have the right to access your own personal data by way of a subject access request (see above).

You can correct any inaccuracies in your personal data. To do you should contact the Data Privacy Manager in writing, contact details are listed above.

You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected. To do so you should contact the Data Privacy Manager in writing, contact details are listed above.

While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made. To do so you should contact the Data Privacy Manager in writing, contact details are listed above.

You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.

You have the right to object if we process your personal data for the purposes of direct marketing.

You have the right to receive a copy of your personal data and to transfer your personal data to another data controller. We will not charge for this and will in most cases aim to do this within one month.

With some exceptions, you have the right not to be subjected to automated decision-making.

You have the right to be notified of a data security breach concerning your personal data.

In most situations we will not rely on your consent as a lawful ground to process your data. If we do however request your consent to the processing of your personal data for a specific purpose, you have the right not to consent or to withdraw your consent later. To withdraw your consent, you should contact the Data Privacy Manager in writing, contact details are listed above, or you may use the unsubscribe button.

You have the right to complain to the Information Commissioner. You can do this be contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (www.ico.org.uk). This website has further information on your rights and our obligations.

Internal Complaints Procedure

We will attempt to resolve any complaints through our internal procedure in the first instance. This is a two stage process:

  • Initially the complaint will be considered by the Finance Committee of CPT within 5 working days of receiving the complaint. This will all be done by written submission.
  • Should you not be satisfied with the findings of the Finance Committee a panel of three members of the CPT Council will be convened to review the findings of the Finance Committee. You may address the panel directly at this stage.

How long will we keep your data?

CPT will keep your data whilst we are entitled under law to process it, there are legitimate business interests for doing so or where it is necessary for the establishment, exercise or defence of legal claims.

The following criteria are used to determine data retention periods of personal data:

  • Retention in membership
  • CPT will retain your personal data for as long as you are in membership and for a period of 36 months after
  • Retention as an employee of a member
  • CPT will retain your personal data as long as you are employed by a member and for a period of 12 months after we have been notified that you are no longer an employee of a member
  • Retention as a delegate to a CPT conference/event
  • CPT will retain your personal data for a period of 36 months after the last conference/event you attended
  • Retention in case of Claims
  • CPT will retain your personal data for as long as you might, as a member, legally be able to bring claims against CPT

All personal data will be disposed of confidentially and securely.