Use of Personal Data at HITRANS

This document describes how HITRANS uses personal data (information relating to individuals).

The Highlands and Islands Regional Transport Partnership (HITRANS) is a Data Controller (ICO Registration Number Z9382377) which means we are responsible in law for how we use any personal information Our Data Protection Officer, Jayne Golding, can be contacted with any concerns or requests relating to our use of personal data:

Jayne Golding
Projects and Policy Officer
2nd Floor Rear
7 Ardross Terrace

Telephone: 01463 719002

Why does HITRANS process personal data?

HITRANS processes a minimal amount of personal data in the exercise of our official authority under the Transport (Scotland) Act 2005 including:

  • Administration of the partnership
  • Development and publication of regional transport strategies
  • Consultation, promotion and communication on issues relating to sustainable and efficient transport in the partnership area
  • Administration of projects and grant schemes

HITRANS also processes personal data relating to its staff to meet our legal obligations as an employer (including in connection with employment law, social security and social protection law) and for the performance of our contracts of employment with our staff. This may include processing some special categories of personal data such as health information.

What personal data does HITRANS process?

The personal data HITRANS processes includes:

  • For the public: Names and contact details for individuals responding to consultations, raising concerns or complaints, subscribing to newsletters or attending events
  • For staff: Name and contact details, banking details for payroll management; performance and health information for employment administration and contract purposes
  • For suppliers and contractors: Names and contact details for the management of the supplier relationship; bank details of sole traders for the purposes of making payments
  • For Forum members: Names and contact details for the administration of meetings and distribution of newsletters and information on HITRANS activities
  • For partnership board members: Name and contact details; banking details for payment of expenses; records of views expressed and of attendance at and contributions to meetings.

HITRANS undertakes no automated decision making affecting individuals or profiling of personal data.

With whom will HITRANS share personal data?

The following organisations will receive personal data as necessary from HITRANS:

  • Microsoft UK are data processors, hosting HITRANS IT systems on Office 365
  • Partner local authorities or the Scottish Public Sector Ombudsman may receive data relating to complainants or correspondents where correspondence from the public should appropriately be redirected to the authority or SPSO
  • The Highland Council will receive personal data relating to employees and contractors for the purposes of the management of our payroll and for financial management, which they provide on our behalf
  • Comhairle nan Eilean Siar will receive personal data relating to staff and job applicants for the purposes of the human resources management, and legal support they provide on our behalf

HITRANS will put appropriate written arrangements in place with these organisations to protect your personal data.

HITRANS transfers no personal data outside the European Economic Area. Microsoft hosts data on our behalf on servers within the UK and the European Union.

How long does HITRANS retain personal data?

Personal data is managed in line with our records retention policy, For example, consultation responses are retained for five years before being securely deleted.

Your Rights to 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.

These rights are subject to certain caveats and exemptions under GDPR.

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.

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.

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.

To exercise these or any of your rights under GDPR, please contact the Data Protection Officer using the details above.

For more information on data rights see the website of the Information Commissioner’s Office.

Complaints or concerns relating to HITRANS’s use of personal data

If you have any concerns relating to HITRANS management of personal data, you can raise them with the Data Protection Officer, Jayne Golding, at the contact details above. If you remain dissatisfied you can complain to the Information Commissioner’s Office by phoning their helpline on 01334 464610, by using their online portal for raising concerns or by post at:

Scottish Information Commissioner
Kinburn Castle
Doubledykes Road
St Andrews
KY16 9DS

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