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Our core data protection obligations and commitments are set out in TfGM’s primary privacy notice.

This notice provides additional privacy information for staff of bus operators and their trade union/employee representatives, whose personal information TfGM will collect on behalf of GMCA in connection with Bus Reform TUPE.


On 25 March 2021, the Mayor of Greater Manchester made the decision to introduce a bus franchising scheme covering the entirety of Greater Manchester. On 30 March, the mayor made the Greater Manchester Franchising Scheme for Buses 2021 (the Franchising Scheme).

Under the Franchising Scheme, there may be a need for staff of current bus operators within the Greater Manchester area to transfer to new operators who have won local service contracts to provide franchised bus services on behalf of GMCA. In some cases, some staff may transfer to GMCA/TfGM. The transfer of staff was considered by TfGM when preparing its assessment of a proposed bus franchising scheme on behalf of GMCA and the Transport Act 2000 (as amended by the Bus Services Act 2017) makes specific provision for the Transfer of undertakings (Protection of Employment) Regulations 2006 (TUPE) to apply to franchising schemes.

The Franchising Schemes and Enhanced Partnership Schemes (Application of TUPE) (England) Regulations 2017 (the Regulations) sets out the process for determining which staff would be subject to TUPE under a franchising scheme. In summary, the Regulations provide that an authority must look in the first instance to reach agreement with the existing local bus operators who are affected by franchising, and local employee representatives, about the criteria to be applied when determining which staff are ‘principally connected’ to the affected local services and are therefore in the scope of TUPE and a potential transfer to a new employer. The Regulations require the authority to consult on the determination of ‘principally connected’ and also the proposed allocation arrangements (i.e., the plan which sets out which staff members of current bus operators should transfer to which local service contract under the Franchising Scheme).

The Regulations also provide that GMCA/TfGM may make a request to a bus operator whose services are covered by the franchising scheme to provide information about their employees to GMCA/TfGM. The information is set out in Categories of personal Information below GMCA/TfGM will pass this information on to bus operators who are bidding to run the franchised services, Bus operators will then be able to factor into their bids to run the franchised bus services the cost of employing the current staff who will potentially transfer to them if their bid is successful.

On 24 September 2021, the GMCA delegated certain functions to TfGM. Those functions included

  • The function of requesting relevant information from bus operators as set out in regulations 5 and 6 of the Franchising Schemes and Enhanced Partnership Schemes (Application of TUPE) (England) Regulations 2017 (the Regulations); and
  • The function of undertaking any consultations as required by the Regulations.

Categories of Personal Information

To allow TfGM to consult on behalf of GMCA (“We/Us”) in connection with the Franchising Scheme and TUPE the following personal data will be collected:

  • Name, job title, and work contact details of nominated representative(s) of current bus operator
  • Name, job title and work contact details of trade union representatives and employee representatives of current bus operators’ staff;
  • Categories of staff employed by current bus operators – roles and job titles
  • Employment information about individual employees of current bus operators covered by the Franchising Scheme as set out in regulations 5 and 6 of the Franchising Schemes and Enhanced Partnership Schemes (Application of TUPE)(England) Regulations 2017 (the Regulations). Examples of this information would include; job title, salary (including pensions), holiday. length of employment, type of contract, work base etc. Information which would enable a staff member to be identified individually by a bus operator bidding to run a franchised service such as name and address will not be disclosed. The current bus operator which employs an individual will identify that individual by a number so only they and not bus operators bidding for the franchised services will be able to identify the individual. For more information, please see The Franchising Schemes and Enhanced Partnership Schemes (Application of TUPE) (England) Regulations 2017 (

Legal Basis for Processing

The EU General Data Protection Regulation (EU GDPR) (if applicable), UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018 provide for a number of different legal bases under which processing of personal data may take place. The legal basis we rely on for processing your personal information is:

  • Article 6 (1) (c) UK GDPR -processing is necessary for compliance with a legal obligation as detailed above in the Introduction

  • Article 9 2 (b) (processing is necessary for the purposes 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 in so far as it is authorised by domestic law or a collective agreement pursuant to domestic law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.

The relevant employment law is detailed above in the Introduction section.

Information Sharing recipients

  • Bus Operators – both current and prospective under the Franchising Scheme
  • Greater Manchester Combined Authority – for their purposes in relation to their transport powers in connection with the Bus Franchising Scheme;
  • Recognised Trade Union Officials – in connection with TUPE consultation in respect of the Franchising Scheme; and
  • Elected Trade Union/Employee Representatives - in connection with TUPE
    consultation in respect of the Franchising Scheme.

Sources of personal information other than the data subject

As well as information directly collected directly from you, we also collect or receive information from:

  • Bus Operating Companies – provide us with specific personal information about staff members of bus operators for TUPE purposes; and
  • Elected Trade Union/Employee Representatives – provide us with limited personal information about staff members of bus operators they represent for TUPE purposes.

Automated decisions

For this processing, all the decisions we make about you involve human intervention

Data retention criteria

Our Retention Schedule outlines how long we retain certain types of information.

Information Security

TfGM are committed to keeping your information safe and protected from accidental loss or alteration, inappropriate access, misuse or theft. As well as technical physical and organisational controls, we recognise that a well-trained, informed and security alert workforce minimises privacy risks from human error and/or threats from malicious actors. We require our service providers to implement appropriate industry-standard security measures, and only allow them to process personal information for specified purposes as written in our contracts with them.

Rights of individuals

You have a right to be informed about how and why your personal information is being processed. This notice fulfils that obligation. You also have a number of other rights.

Information about the following rights is available in our Guide to Exercising Your Rights:

  • These rights and how to exercise them;
  • Contacting our Data Protection Officer;
  • Raising a concern with us; and/or
  • Making a complaint to the Information Commissioner


We may update or revise this Privacy Notice from time to time as the Franchising Scheme progresses and provide supplementary privacy information as is necessary to TfGM’s current workforce.