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GDPR Data processing modelTicketing system of transport organizing authorities

Organisation: PublicSector: Local authoritiesSector: Transport
This processing model relates to the ticketing system of transport organizing authorities

Purposes (5)

A purpose is the objective pursued by the setting up of your file. It indicates what the processing of personal data will be used for, its purpose. This purpose must be clear and understandable

1
Measuring the quality of system operation
Analysis of technical problems related to the card, technical problems related to the validators, detection of functional anomalies in the information system
Public interest
Art. 6(1)(e) UK GDPR – public task of the transport authority (planning and operating the public transport network). A public authority cannot rely on legitimate interests for processing carried out in the performance of its tasks (UK GDPR, Art. 6(1), final subparagraph).
2
Statistical analysis of network usage
Traffic, type of tickets issued, clientele, usage by type of ticket
Public interest
Art. 6(1)(e) UK GDPR – public task of the transport authority (planning and operating the public transport network). A public authority cannot rely on legitimate interests for processing carried out in the performance of its tasks (UK GDPR, Art. 6(1), final subparagraph).
3
Management and monitoring of commercial relations
Management of commercial offers (for example: sending of offers by commercial partners) / Management of loyalty programs.
Public interest
Art. 6(1)(e) UK GDPR – public task of the transport authority (planning and operating the public transport network). A public authority cannot rely on legitimate interests for processing carried out in the performance of its tasks (UK GDPR, Art. 6(1), final subparagraph).
4
Management, issue and use of transport tickets
Management of season tickets and issue of full-fare, reduced-fare or even free tickets / Management of after-sales service operations and customer complaints.
Contract
5
Fraud Management
Detection of counterfeiting and technological fraud / Processing of technological fraud cases / Management of invalidated cards following loss or theft / Management of invalidated cards following detection of misuse (for example: detection of several dozen swipes with the same pass) / Management of invalidated cards following a payment incident.
Public interest
Art. 6(1)(e) UK GDPR – public task of the transport authority (planning and operating the public transport network). A public authority cannot rely on legitimate interests for processing carried out in the performance of its tasks (UK GDPR, Art. 6(1), final subparagraph).

Data categories (5)

Personal data is any information relating to an identified or identifiable natural person. A natural person can be identified either directly (eg surname and first name) or indirectly (eg phone number, social security number, email or postal address, but also voice or image)

Data for managing overdue payments

Data details


Commentsrequired
Data relating to the settlement of sums duerequired
Date and reason for rejectionrequired
Credit card numberrequired
bankrequired
Amount unpaidrequired
subscriber account numberrequired
Date of birth

Definition

person's date of birth

required
first and last namerequired

Data conservation rules

Active base:

Information on unpaid amounts is removed from the card deny list (hotlist) as soon as the sums due have been paid. No statutory period applies to the deny list; the controller should set a maximum, e.g. 2 years from listing, based on the time reasonably needed to recover the debt. Records of the debt itself may be kept until the limitation period expires, i.e. 6 years from when the sum fell due (Limitation Act 1980, s.5).

Limitation Act 1980, s.5

Destruction

Validation data

Data details


Reason for exclusion from the validation listrequired
Date, time and place of validationrequired

Data conservation rules

Active base:

Customer data are kept for the duration of the contractual relationship. No statutory period applies after it ends; the controller should set a period, e.g. 2 years, for customer relations and statistics, using aggregated or anonymised data for statistics where possible. Data needed to deal with claims or disputes may be kept until the limitation period expires (6 years, Limitation Act 1980, s.5). Deleting the card number, or deleting the date, time and place of use, can contribute to anonymisation; hashing the card number is only pseudonymisation and the data remain personal data under UK GDPR. Journey (validation) data linked to a card or account number: no statutory period applies; the controller should keep them only as long as needed, e.g. 48 hours where used solely to detect technical fraud. Where the customer uses post-payment (pay as you go) travel, the data needed for billing (excluding location where not needed) may be kept, e.g. for 4 months from the journey, to handle charging disputes and refund claims. When validation data are collected centrally, they should be sorted so that only the data of post-payment customers are kept for that period.

Limitation Act 1980, s.5; UK GDPR

Destruction

Payment data

Data details


Start and end date of card validityrequired
Credit card numberrequired
RIP/RIBrequired
Customer numberrequired
Subscription Typerequired
Customer Historyrequired
Name of school or universityrequired
Situation socioprofessionnellerequired
Payment methodrequired
Identity and address of payer if different from subscriberrequired

Data conservation rules

Active base:

Customer data are kept for the duration of the contractual relationship. No statutory period applies after it ends; the controller should set a period, e.g. 2 years, for customer relations and statistics, using aggregated or anonymised data for statistics where possible. Data needed to deal with claims or disputes may be kept until the limitation period expires (6 years, Limitation Act 1980, s.5).

Limitation Act 1980, s.5

Destruction

Management data for free or reduced fare transport tickets

Data details


Transport operating agent statusrequired
Large family statusrequired
Incomerequired
Social benefitsrequired
Agerequired
Disabilityrequiredsensitive data
schoolingrequired

Data conservation rules

Active base:

Customer data are kept for the duration of the contractual relationship. No statutory period applies after it ends; the controller should set a period, e.g. 2 years, for customer relations and statistics, using aggregated or anonymised data for statistics where possible. Data needed to deal with claims or disputes may be kept until the limitation period expires (6 years, Limitation Act 1980, s.5).

Limitation Act 1980, s.5

Destruction

Traveler identification data

Data details


Proof of addressoptional
Copy of IDoptional
Photograph

Definition

Photograph including the person's face

required
Email addressrequired
Telephone numberrequired
Postal Addressrequired
Date and place of birthrequired
Name and surnamerequired
Genderrequired
Civilityrequired

Data conservation rules

Active base:

Customer data are kept for the duration of the contractual relationship. No statutory period applies after it ends; the controller should set a period, e.g. 2 years, for customer relations and statistics, using aggregated or anonymised data for statistics where possible. Data needed to deal with claims or disputes may be kept until the limitation period expires (6 years, Limitation Act 1980, s.5).

Limitation Act 1980, s.5

Destruction

Data subject (1)

A data subject is any person whose data is collected, retained or processed by the data processing. e.g. In a recruitement process, any candidate for a position proposed in recruitement management process

  • Customers

Created at:07/08/2023

Updated on:10/05/2026

License: © Creative commons :
Attribution / Pas d'utilisation commerciale
CC-BY-NC AttributionPas d'utilisation commerciale

Nb using:10


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