This privacy notice covers the provision of transport for eligible service users:
- of Post-19 transport, for young adult learners aged 19-25
- who are eligible for free school transport based on distance to their designated school
- where the parent or carer requests to pay for transport on a hired school transport vehicle as part of the Concessionary Seat Scheme.
- of the SEND post-16 scheme provided by Education & Skills
West Sussex County Council (WSCC) takes data protection seriously. Please be assured that your information will be used appropriately in line with data protection legislation, will be stored securely and will not be processed unless the requirements for fair and lawful processing can be met.
Data Controller
WSCC complies with the Data Protection Act and the General Data Protection Regulation (GDPR). It is registered as a ‘Data Controller’ with the Information Commissioner’s Office (Reg. No. Z6413427).
The Data Protection Officer (DPO) for WSCC can be found on our Privacy Policy.
We ensure that your personal data is processed fairly and lawfully, accurate, kept secure and retained for no longer than is necessary.
Information we use
- name
- address
- date of birth
- gender
- child’s pupil reference
- parent’s name (in the case of children)
- parent’s address (in the case of children)
- parent’s telephone number (optional) (in the case of children)
- parent’s email address (in the case of children)
- looked after child status (if applicable)
- proof of disability (Disabled applications only) and relevant EHCP information to assist travel (for children)
- physical and mental health (to determine transport/resource need)
- financial data (where paying or reimbursement)
- location data
- photograph (when required for photo card travel passes)
How we use your information
We use your information to determine eligibility for the scheme and enable WSCC to allocate transport effectively and appropriately.
We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing. Your information is never sold for direct marketing purposes.
Our staff are trained to handle your information correctly and protect your confidentiality and privacy.
Your information is processed in the UK or in a country with an adequacy agreement with the UK.
The legal basis for processing personal data
Free School Transport for eligible pupils is provided under Section 508B and Schedule 35B of the Education Act 1996 as inserted by Part 6 of the Education and Inspections Act 2006 and administered by the County Council under Article 6(1)(e) GDPR. In line with article 9(2)(a) GDPR your consent will be sought for any sensitive (health) data.
The Concessionary Seat Scheme is a paid for service and administered with your consent under Article 6(1)(a).
Payments are administered for families:
- making SEND post-16 contributions to transport.
- who are eligible for a mileage allowance or personal transport budget.
- where a charge is necessary for replacement of passes.
Smart cards allow details of where and when your pass has been used to be recorded anonymously. The Council may re-identify you from this data in the following circumstances:
Analysing usage for carrying out renewals (Article 6(1)(e) GDPR)
Identifying fraudulent use (Sch. 8 Para. 8(1)(b)(ii) Data Protection Act 2018)
Safeguarding vulnerable individuals (Sch. 8 Para. 4(1) Data Protection Act 2018).
Location data is also used to administer scheduling, mapping and routing of transport to be able to deliver services.
Sharing your information
We will share your information with trusted partner organisations to process your data on our behalf.
DDS Wireless International Incorporated, a third-party provider of Mobisoft Travel
Centre (MTC) software used to manage the transport provision.
Where a photocard is required, your details will also be shared with our partner organisation, Euclid Ltd, who produce, and issue passes on the Council’s behalf.
The minimal amount of data to ensure a suitable transport service will be shared securely with transport providers (coach, taxi and minibus companies).
The council has a duty to protect the public funds it administers. To prevent and assist in the detection of fraud, the information you provide on any forms may be shared with other public bodies responsible for auditing or administering public funds, including checks on credit reference agencies and taking part in the National Audit Office’s National Fraud Initiative.
We will share information regarding the times and locations that passes have been used in the event that the police are carrying out safeguarding investigations relating to persons they believe to be vulnerable.
Any sharing of personal data is always done:
- on a case-by-case basis
- using the minimum personal data necessary
- with the appropriate security controls in place
- in line with legislation.
Information is only shared with those agencies and bodies who have a "need to know" or where you have consented to the sharing of your personal data to such persons.
We may use the information we hold about you to assist in the detection and prevention of crime or fraud. We may also share this information with other bodies that inspect and manage public funds.
Your rights
See our Privacy Policy for more information on your rights.
Should you have any further queries on the uses of your information, speak directly to our service:
Transport Coordination Group
Phone: 01243 753530
Email: school.transport@westsussex.gov.uk
Complaints
See our Privacy Policy for information about making a complaint.
You can also contact the Information Commissioner's Office (ICO) for further information or to make a complaint.