Highways Privacy Notice

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

This notice provides additional privacy information for: DriveSafe driver training customers, applicants for the Greater Manchester Road Activities Permit Scheme (GMRAPS) and members of the public who contact TfGM to make complaints about the highways /traffic signals in Greater Manchester.

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Purposes

We collect [or obtain] your personal information for the following purpose(s):

• Administration and delivery of the National Driver Offender Retraining Scheme (NDORS), taxi driver training, minibus driver training and fleet training courses;
• Administration and membership of National Driver Improvement Scheme Providers (NADIP);
• Administration of the GMRAPS;
• Dealing with complaints and service requests from the public about highways/ traffic signals/ enforcement.

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Categories of personal data

In order to carry out these purposes we collect and obtain:

• Personal details;
• Visual images, personal appearance and behaviour;
• Licenses, permits or certificates held;
• Details of complaints;
• Goods and services provided;
• Financial details; and
• Incident and accident details.

We also collect, store and use the following special category personal information:

• Race or ethnic origin;
• Religious or philosophical beliefs.

We also collect, store and use criminal offence or convictions data.

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Legal basis for processing

The legal basis we rely on for processing your personal information is:

• The processing is necessary for the performance of a contract with the data subject;
• The processing is necessary to meet our legal obligations under Part 2 of the Traffic Management Act 2004, the Greater Manchester Combined Authority Order 2011, Sections 39(2) and 39(3)(a) and (b) of the Road Traffic Act 1988, and Section 108(1) (a) of the Transport Act 2000;
• The processing is necessary for the performance of a task carried out in the public interest;
• The processing is necessary for the purposes of the legitimate interests pursued by TfGM in order to deliver National Driver Offender Retraining and other DriveSafe driver training courses; and
• Marketing purposes: where you have consented to receive electronic marketing information about our services (you may withdraw your consent at any time).

The legal basis we rely on for processing your special category personal information is:

• Processing is necessary for the purpose of carrying out obligations and exercising rights in the field of social security and social protection law, in the form of meeting our accessibility obligations under the Equalities Act 2010; and
• Processing is necessary in the substantial public interest for the purpose of equality of opportunity or treatment.

The legal basis we rely on for processing criminal offence or convictions data is:

• Processing is necessary in the substantial public interest for the purpose of the administration of justice.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (for example, providing you with driver training), or we may be prevented from complying with our legal obligations (for example, the issuing of permits under GMRAPS).

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Information sharing recipients

We may share personal information about you with the following types of organisations:

• Police (NDORS) – to confirm when training has been completed on NDORS courses;
• Training providers and Trainers – to deliver and administer training courses;
• NADIP – to administer NADIP membership. Electric Vehicle charging system operators to assist in improving service provision; and
• Road Traffic Incident Information is shared with partners to allow recovery of costs for damage caused by third parties.

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Sources of personal data other than the data subject

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

• Mystery shoppers – reviews of training delivered by individual trainers.

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Data retention criteria

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

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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:

• Contacting our Data Protection Officer;
• Raising a concern with us; and/or
• Making a compliant to the Information Commissioner

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Updates

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

Last updated: 23/09/2021

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