Privacy Policy

Use of Personal Data at HITRANS
This document describes how HITRANS uses personal data (information relating to
individuals)
The Highlands and Islands Regional Transport Partnership (HITRANS) is a Data Controller
(ICO Registration Number Z9382377) which means we are responsible in law for how we
use any personal information
Our Data Protection Officer, Rachael Fraser, can be contacted with any concerns or
requests relating to our use of personal data:
Rachael Fraser
Project Officer – Finance
2nd Floor Rear
7 Ardross Terrace
Inverness
IV3 5NQ
Telephone: 01463 719002
Email: info@hitrans.org.uk
Why does HITRANS process personal data?
HITRANS processes a minimal amount of personal data in the exercise of our official
authority under the Transport (Scotland) Act 2005 including:
• Administration of the partnership
• Development and publication of regional transport strategies
• Consultation, promotion and communication on issues relating to sustainable and
efficient transport in the partnership area
• Administration of projects and grant schemes
HITRANS also processes personal data relating to its staff to meet our legal
obligations as an employer (including in connection with employment law, social
security and social protection law) and for the performance of our contracts of
employment with our staff. This may include processing some special categories of
personal data such as health information.
What personal data does HITRANS process?
The personal data HITRANS processes includes:
• For the public: Names and contact details for individuals responding to
consultations, raising concerns or complaints, subscribing to newsletters or
attending events
• For staff: Name and contact details, banking details for payroll management;
performance and health information for employment administration and contract
purposes
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• For suppliers and contractors: Names and contact details for the management of
the supplier relationship; bank details of sole traders for the purposes of making
payments
• For Forum members: Names and contact details for the administration of meetings
and distribution of newsletters and information on HITRANS activities
• For partnership board members: Name and contact details; banking details for
payment of expenses; records of views expressed and of attendance at and
contributions to meetings.
HITRANS undertakes no automated decision making affecting individuals or profiling of
personal data.
With whom will HITRANS share personal data?
The following organisations will receive personal data as necessary from HITRANS:
• Microsoft UK are data processors, hosting HITRANS IT systems on Office
365
• Partner local authorities or the Scottish Public Sector Ombudsman may
receive data relating to complainants or correspondents where
correspondence from the public should appropriately be redirected to the
authority or SPSO
• The Highland Council will receive personal data relating to employees and
contractors for the purposes of the management of our payroll and for
financial management, which they provide on our behalf
• Comhairle nan Eilean Siar will receive personal data relating to staff and job
applicants for the purposes of the human resources management, and legal
support they provide on our behalf
HITRANS will put appropriate written arrangements in place with these organisations to
protect your personal data.
HITRANS transfers no personal data outside the European Economic Area. Microsoft hosts
data on our behalf on servers within the UK and the European Union.
How long does HITRANS retain personal data?
Personal data is managed in line with our records retention policy, For example,
consultation responses are retained for five years before being securely deleted.
Your Rights to personal data
You have the right to:
Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold about you and to
check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have
any incomplete or inaccurate data we hold about you corrected, though we may need to
verify the accuracy of the new data you provide to us.
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Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your personal data where you have successfully
exercised your right to object to processing (see below), where we may have processed
your information unlawfully or where we are required to erase your personal data to comply
with local law. Note, however, that we may not always be able to comply with your request
of erasure for specific legal reasons which will be notified to you, if applicable, at the time of
your request.
Object to processing of your personal data where we are relying on a legitimate interest
(or those of a third party) and there is something about your particular situation which
makes you want to object to processing on this ground as you feel it impacts on your
fundamental rights and freedoms. You also have the right to object where we are
processing your personal data for direct marketing purposes. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your information which
override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to
suspend the processing of your personal data in the following scenarios: (a) if you want us
to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not
want us to erase it; (c) where you need us to hold the data even if we no longer require it as
you need it to establish, exercise or defend legal claims; or (d) you have objected to our use
of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to
you, or a third party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the information to perform a
contract with you.
Withdraw consent at any time where we are relying on consent to process your personal
data. However, this will not affect the lawfulness of any processing carried out before you
withdraw your consent. If you withdraw your consent, we may not be able to provide certain
products or services to you. We will advise you if this is the case at the time you withdraw
your consent.
These rights are subject to certain caveats and exemptions under GDPR.
You will not have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we may refuse to comply with your request in these
circumstances.
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights). This
is a security measure to ensure that personal data is not disclosed to any person who has
no right to receive it. We may also contact you to ask you for further information in relation
to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us
longer than a month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.
To exercise these or any of your rights under GDPR, please contact the Data Protection
Officer using the details above.
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For more information on data rights see the website of the Information Commissioner’s
Office.
Complaints or concerns relating to HITRANS’s use of personal data
If you have any concerns relating to HITRANS management of personal data, you can raise
them with the Data Protection Officer, Jayne Golding, at the contact details above.
If you remain dissatisfied you can complain to the Information Commissioner’s Office by
phoning their helpline on 01334 464610, by using their online portal for raising concerns or
by post at:
Scottish Information Commissioner
Kinburn Castle
Doubledykes Road
St Andrews
Fife
KY16 9DS
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