Freedom Pass privacy notice
What service is being provided?
The Freedom Pass is a concessionary travel scheme for older and disabled people that provides free travel within the London area on buses, the underground, and Docklands Light Railway all day, as well as local rail services after 9.30am
The Freedom Pass scheme is run by Hammersmith & Fulham Council, and London Councils has delegated responsibility for the administration of the Freedom Pass scheme on behalf of all London Local Authorities.
Hammersmith & Fulham and London Councils are joint data controllers and are jointly responsible for making sure that your information is managed properly. A description of our responsibilities as joint controllers is as follows:
Hammersmith & Fulham are responsible for:
- Assessing and reviewing the eligibility of Disabled Freedom Pass applicants. If you have a qualifying disability you can submit a completed application and supporting information to us by email, post or in person. Details about the Freedom Pass scheme and how to apply.
London Councils are responsible for:
- Verifying the eligibility of Older Persons Freedom Pass applicants
- Administering both the Older Persons and Disabled Freedom Pass schemes. Details about the scheme and how to apply can be found on the London Councils website
- Contractual arrangements with London Councils service provider, ESP Group, to provide the Freedom Pass application processing, card production and contact centre services.
Under data protection legislation, we must ensure that we have an adequate reason or legal grounds to support the use of your personal information. The legal grounds we use to determine that the processing of personal information is necessary, is to enable us to fulfil a ‘legal obligation’. We also rely on the following legal grounds:
- The Freedom Pass scheme operates in accordance with Chapter VIII, sections 204-244 of, and Schedule 16 to the GLA Act 1999 and the Concessionary Bus Travel Act 2007.
- Processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law insofar as it is authorised by Union or Member State Law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.
- London Councils has been delegated administration of the Freedom Pass scheme by the London boroughs as set out in paragraphs 12.3 of, and Schedule 2, part 3 to the London Councils Transport and Environment Committee (LCTEC) Governing Agreement (consolidated version) 13 December 2001. LCTEC is a joint committee of the London boroughs and TfL established under sections 101 and 102 of the Local Government Act 1972 and section 20 Local Government Act 2000.
Hammersmith and Fulham are registered with the Information Commissioner’s Office for the purposes of processing personal data.
Further information about how London Councils handle your information is available in the London Councils Freedom Pass privacy statement.
The information you provide
The personal information we hold is provided by you when you register to become a Freedom Pass holder and through your continued use of the Freedom Pass scheme.
The information you provide will be held and used in accordance with the requirements of UK and European data protection law for a period of 6 years plus the current year, when it will be securely destroyed.
When you contact Hammersmith & Fulham by telephone we will record the call for quality and training purposes. Telephone recordings are kept for a period of 6 months, at which point they are then deleted.
When you make an appointment to visit our service Hammersmith & Fulham will keep the appointment details for a period of 6 months, at which point it will then be deleted.
Further information about London Councils arrangements can be found in the London Councils Freedom Pass privacy statement.
What data do we collect?
Unless otherwise agreed with you, we will only collect the minimum personal data required to deliver the service, which includes:
- Contact details
- Date of birth
- GP’s name
- National Insurance Number
- Proof of your identity (e.g. driving licence, passport)
- Proof of your address (e.g. council tax bill, utility bill)
- Details of any person with legal responsibility for you
- Any other personal information that you supply in your supporting documentation as part of your application for a Disabled Persons Freedom Pass
The following special category data is collected
- Ethnicity (optional)
- Evidence to support automatic and non-automatic eligibility to be registered (e.g. Certificate of Visual Impairment, evidence of entitlement to benefits or allowances you receive relating to your mobility etc)
- Details of the West London Mental Health Team that supports your care and details of the Care Plan in place (where applicable)
- Details of medical conditions affecting mobility, pain medication and assessment of walking ability
Information is collected by Hammersmith & Fulham and London Councils by submission of a completed application and supporting evidence which is used to assess and review your eligibility for the Freedom Pass scheme.
Following assessment of your application for a Disabled Persons Freedom Pass, you may be asked to attend a mobility assessment where further information may also be gathered. We ask for your consent to attend a mobility assessment. You are not required to do so but it may affect the outcome of your application if you do not attend.
Once you become a Freedom Pass holder London Councils will collect information generated by your use of the Freedom Pass scheme.
Who will be using your personal data?
To enable us to provide services to you, it may be necessary for us to obtain relevant information and to share your personal information with others.
Your information (only as relevant) will be shared with London Councils who are responsible for the administration of the Freedom Pass scheme.
As a Freedom Pass holder, your information will also be shared with London Councils contractor (ESP Group) which provides the Freedom Pass application processing, card production and contact centre service.
London Councils also has information sharing agreements in place with Transport for London (TfL)
Who else might we share your data with?
With the Cabinet Office for data matching processes in respect of The National Fraud Initiative.
IT software providers - IT Software providers such as Conduent Parking Enforcement Solutions Ltd who are contracted by Hammersmith & Fulham to host and manage our data.
Prevention and detection of fraud - Hammersmith & Fulham may share and compare your information with other council services and other organisations to make sure the information is accurate, to protect public funds, recover debt and/or prevent or detect fraud. These other organisations include government departments, other local authorities, the police, and private sector organisations such as banks or organisations that lend money.
Legal requirements - Hammersmith & Fulham will use all information held by us for the purposes of law enforcement, regulation and licensing, criminal prosecutions, and court proceedings.
Corporate business intelligence – Hammersmith & Fulham may share the information you give us (only as relevant) with other council services for research and analysis purposes, to help us design and improve the services we provide, and to identify and contact residents who may benefit from them.
Developing and testing business applications – Hammersmith & Fulham may use the information you give us (only as relevant) to maintain and improve the services which we deliver, this includes developing and upgrading the systems which we use to process your information.
Statistical purposes – Hammersmith & Fulham (only as relevant) may use your information for statistical purposes in order monitor and manage the Freedom Pass scheme.
Authorised representatives – Hammersmith & Fulham may share your information (only as relevant) with representatives who are legally responsible for you or with representatives such as Members of Parliament or councillors who you have authorised to make enquiries on your behalf.
Further information about how London Councils handle your information is available in the London Councils privacy statement.
What is your personal information used for?
Hammersmith & Fulham will use your personal information:
- To assess and review your eligibility for the Disabled Persons Freedom Pass in accordance with governing legislation.
- For administrative purposes.
- To monitor the Freedom Pass service locally and ensure that it continues to meet your needs
London Councils and the companies that process your information will use it:
- To assess and review your eligibility for the Older Persons Freedom Pass in accordance with governing legislation
- For customer service and administration
- For provision of a customer relationship database
- For the provision of travel services
- For customer research
- For fraud investigation and prevention
- For service improvement
- To arrange financial settlement for the scheme.
The Joint Data Controllers are London Borough of Hammersmith & Fulham and London Councils.
The Data Protection Officer for London Borough of Hammersmith & Fulham can be contacted at firstname.lastname@example.org
The Data Protection Officer for London Councils can be contacted at email@example.com
The Data Processor supporting this purpose are the IT Software providers who host and manage our data.
How do I know the information about me is kept safely?
All the information we collect is stored securely on our IT systems and manual filing systems. We have strict procedures for the way this is done. Any and all information about you is treated as confidential and with respect. There are also clear rules and guidance about storing, recording, and sharing information which staff receive training on.
We take information sharing very seriously. Any member of staff who is found to be breaking the rules will be dealt with through appropriate disciplinary procedures.
The information we hold will not be stored in or accessible from countries with non- UK-equivalent Privacy Law protections
London Councils and their contracted providers have processes in place to describe how your information is handled and protected. Further details can found in the London Councils privacy statement.
Hammersmith & Fulham Council and London Council do not process your personal information for marketing purposes.
Profiling and automated-decision making
Hammersmith and Fulham do not process your personal information using profiling or automated decision-making processes
Profiling and automated decision making does not apply to London Councils processing of your information.
Our use of your data will be subject to the following legal rights
- Your right to be Informed
- Your right to access your personal data
- Your right for us to rectify your personal data
You have the right of access to the personal data we process about you, and in this instance, the right for us to rectify your personal data. Details of how to make a subject access request
Alternatively, you can contact London Councils by emailing firstname.lastname@example.org
As we have a statutory basis for collecting your personal data, we do not need to ask for your permission to share it; however, we will only ever share your data on a basis of need, in line with legislation and will work transparently with you at all times.
If you do not provide your data, we will not be able to process your Freedom Pass application and you will not be able to use the service.
Visit the following links for more information about privacy law, our obligations, and your rights
- The ICO Guide to the General Data Protection Regulation 2016
- The General Data Protection Regulation 2016
If you have concerns
If you have concerns over the way we are asking for or using your personal data, please raise the matter with our H&F In Touch Team by the following means:
H&F In Touch Team, London Borough of Hammersmith and Fulham Hammersmith, London W6 9JU
020 8748 2456
If you still have concerns following our response you have the right to raise the matter with the Information Commissioner's Office.