Privacy notice

School Travel Assistance (STA) and Transport Co-ordination

The London Borough of Hounslow is a Data Controller and we are responsible for collecting and processing your personal information. Processing includes the organisation, retrieval, consultation, use and deletion or destruction of information and its disclosure to other agencies

This privacy notice tells you what to expect when the Council collects personal information.

If you have any questions regarding this privacy notice please contact schooltravelassistance@hounslow.gov.uk

Our Lawful Basis under the General Data Protection Regulations (GDPR):

Our lawful basis for processing personal data under the Data Protection Legislation is:

  • Public Task
  • Legal Obligation
  • Legitimate Interests

The legal obligations which we are bound by are as follows:

  • The Home to School Travel and Transport Guidance (July 2014),
  • The Post 16 Transport to Education and Training Statutory Guidance for Local Authorities (February 2014)
  • The Special Educational Needs and Disability Code of Practice: 0 to 25 years (January 2015).

The legitimate interests are:

  • For safeguarding vulnerable passengers and staff members,
  • To provide prompt and accurate resolution to complaints, investigations and allegations, and
  • Swift resolution to insurance claims.

The details of your child’s needs will fall under special categories of personal data for the safe transportation of a child/young person if relevant to your application. Our lawful basis for processing special category data is found in Article 9(2)(g) ‘...medical diagnosis, the provision of health or social care treatment or the management of health and social care systems…’ of the General Data Protection Regulations.

Purpose for processing your information

The Council’s School Travel Assistance Team will process your information in order to determine eligibility for assistance, to arrange assistance and ensure when deemed eligible relevant information is used for processing payments or provided to colleagues / third parties in order to ensure your child is transported safely to school.

Information we request from you is for processing your assisted transport provision application and to assess your child’s eligibility against the Council’s Policy for Assisted Passenger Transport to ensure appropriate travel assistance is put in place.  These are:

  • Full name of your child,
  • Date of birth,
  • Home address,
  • Parent/carers full name and address if different from your child,
  • Your contact details including phone numbers and email address
  • Information on the child’s siblings
  • Details of your child’s needs
  • CCTV videos and images

This information is only used for the intended purpose but if we intend to use it for any other purpose; we will normally ask you first. In some circumstances we may have to share without your knowledge, and this will be to prevent and detect crime for example for safeguarding and fraud purposes.

Changes in your circumstance

You must notify us immediately if there are any changes in your circumstances and personal details, so we can maintain an accurate and up to date record of your information.

How we collect your information

The information provided is directly by you, via an application for school travel assistance. It is completed online using an e-application form (which is a form created to fill out online.)  Additional information will be requested by STA or Transport Co-ordination during the assessment process and thereafter once travel assistance is in place either by letter, email, telephone or face- to-face and shared with:

  • Council’s Drivers and Attendants
  • External contractors who provide transport on the Council’s behalf and where necessary their Drivers and Attendants.
  • Educational establishments and medical professionals.

The STA and Transport Co-ordination services may also use your information for other legitimate purposes and may share (where necessary) with other Council departments and external bodies responsible for administering services to children and young people. 

Reasons for sharing information with internal or external bodies will be.

  • to enable the processing of travel assistance,
  • to fulfil the council’s safeguarding duty and comply with the Prevent Strategy, to provide Central Government bodies with mandatory data returns,
  • The Home Office to notify of potential illegal immigration and the Police may request information at any time as part of a criminal investigation.

Internal departments are as follows:

  • the SEND (Special Educational Needs and Disabilities) Teams,
  • the Management Information Team,
  • the Early Help Service,
  • the Multi-Agency Safeguarding Team (MAS) and Safeguarding Services
  • the Early Years’ Service and Drivers and Attendants.

External organisations are;

  • Transport suppliers (private minicab and minibus operators) and their drivers and attendants,
  • Schools/academies/nurseries (previous, current, and applied for),
  • Health professionals,
  • other Councils/boroughs  
  • Central Government bodies comprising of the Department of Education, the Local Government Ombudsman; the Home Office and the Department of Work and Pensions.
  • The Police

For validating proof of address, the STA team will refer to data held by any of the services mentioned above, internal Council Tax records, the Housing Team, and the Fraud Team.

How we store and transfer the data and information

Your application form and supporting information will be stored securely by the STA and Transport Co-ordination Teams both electronically and in some circumstances, there will be hard copies. Any data shared outside the Council will be transferred in a secure, encrypted electronic format.

Data and information will be retained in line with our retention schedule, please refer to appendix one for details.

Travel Assistance Appeals

Personal data is held to ensure that all information relevant to an appeal is available to enable a fair judgement to be made. See the council’s appeals process

CCTV on vehicles (as from 19 April 2021)

The aim is to commence operating CCTV in vehicles after the Easter break 2021, they are currently not in use.

Council owned passenger transport vehicles will be equipped with audio CCTV for the safeguarding of passengers and crews.  CCTV will only be accessed and viewed by Management as and when a concern has been brought to Management’s attention, this could be in the form of a complaint, allegation, incident, accident or any other form of communication to us.

The CCTV system will store footage for approximately 8 weeks (this will vary slightly depending on the length of journeys). Following this period of time the data will be overwritten and no-longer accessible.

Any footage downloaded in connection with an incidents/investigation will be kept for no longer than 4 months.  It will only be kept for longer if deemed necessary for current or on-going concerns/investigations - this will continually be under review and deleted once the investigations/or concerns have been addressed.

Your data protection rights

The rights available to you depend on our reason for processing your information. Further information about your data protection rights and how to make a request.

Your right to make a complaint

The Council tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.

If you want to make a complaint you can contact us on:

Complaints Team

London Borough of Hounslow
Hounslow House
7 Bath Road
Hounslow
TW3 3EB

Data Protection Officer

The Council’s Data Protection Officer can be contacted on:

InformationGovernance@hounslow.gov.uk

Information Governance Team
London Borough of Hounslow
Hounslow House
7 Bath Road
Hounslow
TW3 3EB

Information Commissioner’s Office

The Information Commissioner is the UK's independent body set up to uphold information rights.

If you would like to know more about your rights under the Data Protection law, and what you should expect, visit the Information Commissioner’s website: https://ico.org.uk/

If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner’s Office:

Information Commissioner's Office
Wycliffe House~
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113 or 01625 545 745

Email: casework@ico.org.uk

A full list of what information we control and process and for what purposes is set out in our notification with the Information Commissioner's Register of Data Controllers. Our registration number is Z5761176. You can view our registration on the Information Commissioner's website.Appx 1

School Travel Assistance/Transport Co-ordination Retention Schedule

Type of Record

Retention Period

Rationale

Records in relation to applications, those eligible and have been in receipt of School Travel Assistance.

Destroy 35 years from last action for Special Educational Needs (SEN) pupils.

 

Non-SEN data 10 years after last contact.

This data forms part of the child/young person’s Special Educational Needs data.

 

CCTV footage from vehicles

The footage will be automatically saved on the CCTV hard drive for approximately 8 weeks (this will vary slightly depending on the length of journeys).  Any footage downloaded in connection with an incident/investigation will be kept for no longer than 4 months.  It will only be kept for longer if deemed necessary for current or on-going concerns/investigations and will continually be under review and deleted when no longer required.

Legitimate interest to ensure:

  • The safeguarding of vulnerable passengers and staff.
  • Prompt and accurate resolution to complaints, investigations and allegations.
  • Swift resolution to insurance claims.

 

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