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Transport and Highways' privacy policy and retention schedule

Introduction​

Transport is registered as a ‘data controller’ under the Data Protection (Jersey) Law 2018 (Ref number 15801) as we collect and process personal information about you. Transport is part of the Operations and Transport Group, which sits under Infrastructure, Housing and Environment (IHE).

We process and hold your information in order to provide public services and meet our statutory obligations. This notice explains how we use and share your information. Information may be collected on paper, over the telephone, or in digital form such as e-mail, a mobile app, a website or online portal or in person by a member of our staff, or in some cases, by another Government department.

We will continually review and update this privacy notice to reflect changes in our services and feedback from service users, as well as to comply with changes in the law.

What information we collect about you

We collect a variety of information about you, including your:
  • name
  • email address
  • telephone number(s)
  • postal and / or residential address
  • date of birth
  • business and organisation details
  • financial information
  • disability status 
  • CCTV images from car parks, or for vehicle and pedestrian movements
  • vehicle registration number
  • responses to consultations and surveys
  • geographical location, (where you have this switched on, on your device) also known as geolocation or geospatial data, which captures the latitudinal and longitudinal location of your internet-connected mobile device 
  • personal opinions and viewpoints, where you have responded to a consultation related to potential Transport schemes  

Why we collect and hold information about you

We need to collect and hold information about you in order to:

  • manage your request for us to carry out the work you have asked us to do and to ensure public safety
  • arrange payment of costs and invoices for road work permits
  • verify your location for mapping purposes in relation to road safety requests 
  • administer event planning that affect roads and streets
  • respond to your general enquiries, compliments and complaints 
  • manage and investigate claims
  • record and administer incidents or damage within a car park
  • issue parking permits or parking fines
  • allocate parking facilities reserved for disabled drivers
  • maintain the ParkSmart and disabled card register
  • administer vehicle impounds
  • administer parking dispensations within St Helier 
  • investigate concerns and complaints about the road network and provide you with a response and updates on actions
  • consider and evaluate requests for additions or changes to bus stop markings, or to waiting shelters at bus stops
  • manage public transport services
  • advise on eligibility for senior citizens' or disabled persons' travel pass schemes
  • administer road work requests, issue permits, collect fees and carry out safety inspections
  • review and improve the infrastructure of the Islands’  roads and cycle lanes
  • ensure our contracts are administered in accordance with signed agreements
  • to analyse the data collected from public consultations

How we will use the information we hold about you

We will use the information you provide in a manner that conforms to the Data Protection (Jersey) Law 2018 and endeavour to keep your information accurate and up to date.
 
We will process your information for the following purposes:
  • to verify your identity for requested services 
  • to prevent and detect crime
  • to ensure payment of charges and invoices
  • to influence decision making on policy or design of future transport services
  • to carry out surveys and consultations
  • to notify you of roadworks, events and road closures
  • to enforce parking infractions and process appeals
We may not be able to provide you with a service unless we have enough information or your permission to use your information.

We will not pass any personal data on to anyone outside of the Government of Jersey (GoJ), other than to those who either process information on our behalf, or where we are required to assist other organisations in fulfilling their legal obligations, or because of a legal requirement.  We will only do this, where possible, after we have ensured that sufficient steps have been taken by the recipient to protect your personal data and where necessary we will ensure that the recipient has signed a data sharing agreement.  A data sharing agreement sets out the purpose of the sharing and the rules that must be followed when processing your data.   

We will not disclose any information that you provide ‘in confidence’, to anyone else without your permission, except in the few situations where disclosure is required by law, or where we have good reason to believe that failing to share the information would put someone else at risk. You will be told about this. 

Data Processing

We use the following organisations to process information on our behalf:
​Organisation
​Reason for processing
​​PaybyPhone Limited 
​Car payments using a mobile app and website
​Integrated Skills Limited 
​TrafficWorx roadworks permit application website and systems
​Blackburn IT Services t/a bbits
​Love Jersey fault reporting mobile app data
​Delib Limited and Gaist Limited
​Citizen Space system for formal public consultations,  surveys and engagement 
​WSP Global Inc
​Analysis of public consultation data and production of reports


Information processed outside of the European Economic Area ('EEA')

We do not routinely process any personal data overseas using web services that are hosted outside the European Economic Area.

However, from time to time we may use processors outside of the EEA for one off projects.  When we do this we will only do so after having carried out a full data privacy impact assessment, to ensure that they have the relevant standard contractutal clauses in place to protect personal data.  

Data sharing

We may need to pass your information to other GoJ departments or organisations to fulfil your request for a service. These departments and organisations are obliged to keep your details secure, and only use your information for the purposes of processing your service request.  
​Organisation
​Reason for sharing
​Legal basis
​Parishes
​Parking administration and road traffic offences

Consultations for Transport schemes

Set out responsibilities for anyone carrying out road works
​Road Traffic (St. Helier) (Jersey) order 1996

Road Traffic (Public Parking Places) (Jersey) Order 2006

Road Works and Events (Jersey) Law 2016  
Honorary Police
Investigating road safety or parking complaints 
​Road Traffic (Public Parking Places) (Jersey) Order 2006
​States of Jersey Police
​Detection, investigation and prevention of crime

Collision data for Road Safety requests
​Police Procedures and Criminal Evidence (Jersey) Law 2003
​Regulation Group of Infrastructure, Housing and Environment
​Transport scheme planning applications
​Planning and Building (Jersey) Law 2002
​Treasury and Exchequer 
Processing payments for goods and services 
​Public Finances (Jersey) Law 2019
​Law Officers' department
​Legal advise and preparation of case files
Processing of un-paid parking penalties
​All laws mentioned above

Other forms of sharing

If we need to disclose any sensitive or confidential information about you, we will only do so if absolutely necessary or once we have obtained your consent where appropriate or unless we are legally required to do so. Examples of this include but are not limited to: 
  • where the disclosure is necessary for the purposes of the prevention and/or detection of crime
  • or for the purposes of meeting statutory obligations.
At no time will your information be passed to organisations for marketing or sales purposes or for any commercial use without your prior express consent.

Data Security

We have put appropriate security measures in place to prevent your personal data from being used or accessed, altered or disclosed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legal or legitimate business need to know.

All of our staff have received training on data protection awareness and security. We have procedures in place to deal with any suspected personal data breach and will notify you and the Office of the Information Commissioner of any breach where we are legally required to do so.

Publication of your information 

We may need to publish your information on our website where we are required to provide statistical information or where you have responded to a public consultation, although your data will be anonymised to protect your identity.

How long we keep information about you

We will endeavour not to keep your information for longer than is necessary. In some instances, the law sets the length of time information must be kept. Our retention schedules are available for you to view at the bottom of this page. These set out what information we hold, how long we plan to keep it for and what we plan to do with it at the end of its lifecycle.

In some instances, we will not be able to remove your data automatically from our files because of the limitations of some of our legacy processes and systems. There are also some instances where we are still working towards meeting the requirements set out in our retention schedules. 

If you are concerned about us continuing to hold your personal information you can contact us to ask that we remove the data immediately. We will always seek to comply with your request, but we may require further information from you to be able to locate your data or we may still be required to continue to hold or process your information in order to comply with a legal requirement. 

Telephone calls

We do not record or monitor any telephone calls you make to us using recording equipment, although if you leave a message on our voicemail systems your message will be kept until we are able to return your call or make a note of your message. File notes of when and why you called may be taken for record keeping purposes. We will not pass on the content of your telephone calls, unless is it necessary for us to do so, either to fulfil your request for a service, to comply with a legal obligation, or where permitted under other legislation. 

Emails

If you email us, we may keep a record of your email address and a copy of the email for record keeping purposes. For security reasons we will not include any confidential information about you in any email we send to you. We would also suggest that you keep the amount of confidential information you send to us via email to a minimum or use our secure online services where possible or correspond with us by post. 

We will not share your email address or your e-mail contents unless is it necessary for us to do so, either to fulfil your request for a service, to comply with a legal obligation, or where permitted under other legislation. 

Your rights 

You can ask us to stop processing your information 

You have the right to request that the IHE department stop processing your personal data in relation to any of our services. However, this may cause delays or prevent us delivering a service to you. Where possible we will seek to comply with your request, but we may be required to hold or process information to comply with a legal requirement. 

You can withdraw your consent to the processing of your information

In instances where the processing of your information can only be carried out with your consent, you have the right to withdraw your consent to the further processing of your personal data.  However, this may cause delays or prevent us delivering a service to you. We will always seek to comply with your request, but we may be required to hold or process your information to comply with a legal requirement.

You request that the processing of your personal data is restricted

You have the right to request that we restrict the processing of your personal information.  You can exercise this right in instances where you believe the information being processed in inaccurate, out of date, or there are no legitimate grounds for the processing. We will always seek to comply with your request, but we may be required to continue to process your information to comply with a legal requirement.

You can ask us to correct or amend your information

You have the right to challenge the accuracy of the information we hold about you and request that it is corrected where necessary.  We will seek to ensure that corrections are made not only to the data that we hold but also any data held by other organisations/parties that process your data on our behalf.

You can ask us for a copy of the information we hold about you

You are legally entitled to request a list of, or a copy of any information that we hold about you. You can submit a subject access request (SAR) using our online form

Retention Schedule

Our retention schedule is currently being updated and will be posted shortly 

Complaints

If you have an enquiry or concern regarding the Government of Jersey processing your personal data you can contact the Central Data Protection Unit.

You can also complain to the Jersey Office of the Information Commissioner about the way your information is being used.







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