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Chiltern Railways Privacy Policy

Last updated: May 28th 2018

The Chiltern Railway Company Limited, trading as Chiltern Railways (”We”) are committed to protecting and respecting your privacy.

This policy (together with our Website Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.chilternrailways.co.uk or providing your information in the circumstances described below, you are accepting and consenting to the practices described in this policy.

For the purpose of Data Protection Legislation, the data controller is The Chiltern Railway Company Limited of 1 Admiral Way, Doxford International Business Park, Sunderland SR3 3XP. The Chiltern Railway Company Limited is registered as a data controller on the UK Data Protection Register. Our registration number is Z8387561 .

1. What personal data do we collect?

  • Information provided by you. You may give us information about you by completing forms on our site www.chilternrailways.co.uk (our site) or by corresponding with us by phone, e-mail, web or by post. This includes information you provide when you:
    • register to use our sites
    • download our mobile app
    • subscribe to our services
    • purchase tickets
    • register to receive email updates
    • register with us to use our on-train Wi-Fi service
    • enter a competition, promotion or survey
    • when you report a problem with our sites or make a complaint
       
  • Information you give us may include the following items:
    • your name and/or your address
    • e-mail address  
    • Mobile and/or landline number 
    • financial and credit card information 
    • personal description and photograph 
    • Your travel details
    • geographical location, IP or MAC address or details regarding your use of your mobile device or PC (specifically when you register to use our on-train wi-fi service)]. 
       
  • Information we collect about you. With regard to each of your visits to our sites or when you register to use our on-train wi-fi services, we may automatically collect the following information:
     
    • IP (Internet Protocol) address: your IP address indicates your location, unless you are using a VPN service 
    • MAC (Media Access Control) address: is a unique identifier, or address, assigned by the manufacturer of your device 
    • Device: what type of device you are using (TV, smartphone, laptop, desktop) 
    • OS (Operation system): what operating system your device has (IOS, Android, Windows, Linux, MAC OS X) 
    • Browser & browser version: which web browser you are using (Internet Explorer/Edge, Opera, Chrome, Safari, Firefox) 
    • Domain: depending on your device and browser settings, we sometimes identify the web address of the domain you came from before landing on our website 
    • Clickstream data: this is a list of all the web pages that you visited, and the order you viewed them in, on each visit to www.chilternrailways.co.uk . We also record how much time you spend on each web page, and record any actions you make on each page 

 

  • Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
     
  • Sensitive personal data.  Chiltern Railways does not routinely collect, store or use any sensitive personal information, that would be classed as a special category of data under the General Data Protection Regulation, in connection with ticket sales, or enquires regarding ticket sales.
     
  • Where we store your personal information: The personal information we collect about you is stored within our secure UK/EU IT infrastructure. No identifiable personal information is stored or shipped to non UK/EU locations. Your personal information is stored in databases which are encrypted at rest, providing the highest level of security. All personal information is moved to and from our website www.chilternrailways.co.uk via an HTTPS connection, which means that the transfer of data is also encrypted. Access to your personal data held on databases managed by Chiltern Railways or its’ authorised subcontractors, is granted only when there is a need to use the data, no permanent access exists.

2.Cookies

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and allows us to improve our sites. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

3. How do we use your personal data and what is the legal basis for such processing?

The collection of the personal data described above is usually mandatory and, if such personal data is not provided, we will not be able to provide the information, products and services to you. Where the collection of any personal data is not mandatory, we will inform you of this prior to collection, as well as the consequences of failing to provide the relevant personal data.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally process your personal information only:

  • where we have your consent to do so;
     
  • where the processing is necessary to perform our contract with you; or 
     
  • where the processing is in our legitimate interests or those of a third party and such interests are not overridden by your data protection interests or fundamental rights and freedoms; and
     
  • where we have a legal obligation to process your personal information.
Purpose of processing Legal basis for processing
Provision of your tickets to use our services Performance of a contract
Travel information & service availability notices Performance of a contract
Legitimate interest
Renewal notices for season ticket holders  Performance of a contract
Site Optimisation: the device-level information we automatically gather about you allows us to optimise the speed and performance of the website for you  Legitimate interest
Web analytics: we use cookies and the device-level personal information to build a profile of your use of the site, including any transactions that you make, so that we can personalise our marketing offers to you, and to customise your website visits Consent
Wifi data:  we use data gathered from your use of our free wifi service to identify where you start and end your train journeys. This helps us to optimise our train service. We will also provide you with destination-related travel offers, where you have opted-in to receive them. Performance of a contract

Consent
Analysis & modelling: your transaction & location data is also stored on a business insight platform. We use this platform to customise marketing campaigns, for business reporting & for data retention modelling. You can opt out of this use of your data via our preference centre.   Legitimate interest
Surveys: we survey portions of our customer and website visitor database periodically to find out more about your travel experience with us, how you use our trains and how we can improve our service delivery to you. We will not confuse this with marketing or promotional messages.  Legitimate interest
Travel rewards & promotions: if you are an active customer or have enquired about the purchase of our services, Chiltern Railways may send you discounted travel offers via email unless you have opted out. These offers are based on our knowledge of your travel on our trains and your visits to our website, and are aimed at providing you with savings that are relevant. Legitimate interest
Travel rewards & promotions: if you are not an active customer or purchased our services using guest check-out, Chiltern Railways will send you discounted travel offers via email but only if you have opted in. These offers are based on our knowledge of your travel on our trains and your visits to our website, and are aimed at providing you with savings that are relevant.  Consent
Competitions: we offer competition entry via both email and the website, competition entry is sometimes conditional on providing us with additional demographic information about you, which in turns allows us to further customise our communications and travel offers to you  Legitimate interest 

Consent 

Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

You can change your marketing preferences at any time using the Chiltern Railways Preference Centre. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Questions about this Privacy Notice” heading below.

4.  Sharing Your Information

We may disclose your personal data to the following categories of recipient for the purposes described in this Privacy Notice: 

  • Qbase Data Services Limited, of 31-33 Bold Street, Warrington, Cheshire, for the purpose of building a marketing database and business insight platform using Chiltern Railways customer data
     
  • Syrenis Limited, of Vanguard House, Sci-Tech Daresbury, Warrington, WA4 4FS, for the purpose of managing Chiltern Railways customer communications preferences
     
  • Pure360 Limited, of New England House, New England Street, Brighton, BN1 4GH, for the purpose of the transmission of emails from Chiltern Railways
     
  • WiFi Spark Limited, of 5 Cranmere Court, Lustleigh Close, Matford Business Park, Exeter, EX2 8PW, for the purpose of providing station and in-journey wifi services
     
  • Icomera UK Limited, of Victory House, Quayside, Chatham Maritime, Chatham, ME4 4QU, for the purpose of providing onboard wifi services
     
  • The Gate London, of  90 Tottenham Court Road, London, W1T 4TJ, for the purpose of providing analysis reports, strategic recommendations and campaign implementations

We may also disclose your personal data to any competent law enforcement body, regulator, government agency or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation; (ii) to exercise, establish or defend or legal rights; or (iii) to protect your vital interests or those of any other person;

We may also transfer your personal data to a buyer or potential buyer (and its agents and advisers) in connection with any reorganisation, restructuring, merger or sale, or other transferring of assets provided that we inform any receiving party it must use your personal information only for the purposes disclosed in this Privacy Notice.

We operate the Chiltern Railways franchise under arrangements with the Secretary of State for Transport and the franchise operations may pass to a successor operator. We may disclose your personal data to the relevant franchising authority and/or any successor operator and any successor operator must use your personal information only for the purposes disclosed in this Privacy Notice.

Finally, we may disclose your data to any other person to whom you request us to make disclosure or if you consent to such disclosure.

5. Data Retention

We will not retain your personal data for longer than is necessary to fulfil the purposes for which we collected that personal information, unless the law permits or requires that we retain it for longer.  

The table below explains in more detail how long Chiltern Railways will store different types of information for:

Passenger Information  
Passenger details (e.g., name, address of customer etc)
(i)  Prospective passengers
(ii)  Current passengers
 
(iii)  Lapsed passengers  
24 months
For the duration of the passenger's registration with the Customer and then for the period specified for lapsed passengers
For a period of 36 months following the end of the year in which the passenger last purchased the Customer's services
Passenger  transaction data* For the duration of the passenger's registration with the Customer and then for a period of 6 years following the end of the year in which the passenger last transacted with Chiltern Railways we will retain details of those transactions in line with the reporting requirements of the Companies Act
Passenger consents to Customer terms and conditions For the duration of the processing of the Personal Data and up to 6 years thereafter
Passenger service enquiries  3 years
Statistical reports/marketing data   6 years
Register of complaints Review after 10 years
Correspondence and papers including emails  Review after 2 years (or 10 years if the documents relate to a complaint or investigation)

6. Information Security

We apply appropriate administrative, technical and organisational security measures to protect your personal data that is under our control from unauthorised access, collection, use, disclosure, copying, modification or disposal.  All information you provide to us is stored on secure servers.  We are part of the Arriva plc Group, which trains its employees regarding our data privacy policies and procedures and permit authorised employees to access personal data on a need to know basis, as required for their role.  We also take steps to ensure that any service provider that we engage to process personal data on our behalf takes appropriate technical and organisational measures to safeguard such personal data.

7. Transferring Information Internationally

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country. However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Notice. These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information to our third party service providers and further details can be provided upon request.

Third party service providers Data storage location
Icomera   Sweden
ACE  Ireland 
ESP  Ireland 

8.  Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. 

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.  

9.  Your Data Protection Rights

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us at any time at the Chiltern Railways Preference Centre, or by writing to us
    • Data Protection Officer, The Chiltern Railway Company Limited, Great Central House, Marylebone Station, Melcombe Place, London, NW1 6JW
       
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us at :
    • Data Protection Officer, The Chiltern Railway Company Limited, Great Central House, Marylebone Station, Melcombe Place, London, NW1 6JJ
       
  • If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

10.  Questions about this Privacy Notice

If you have any question, concerns or complaints about this Privacy notice or our handling of your personal data, you can contact us by email on data.protection@chilternrailways.co.uk or by post to the following address:

  • Data Protection Officer, The Chiltern Railway Company Limited, Great Central House, Marylebone Station, Melcombe Place, London, NW1 6JJ

If you are unsatisfied with the response, you can contact Arriva plc's Data Protection Officer at data.protection@chilternrailways.co.uk

You have the right to complain to a data protection authority about our collection and use of your personal information.  If you are based in the European Economic Area, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries are available on the EU Commission's website via the following link): http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm)

The controller of your personal data is The Chiltern Railways Company Limited.