Privacy Notice

 

Privacy Notice

This notice explains how and why Westway Community Transport uses personal information from service users, organisations and other members of the public.

It is regularly reviewed and updated in line with the services we deliver and the suppliers that we use. The date that it was last modified is at the end of this notice. We recommend that you check our website periodically for any changes made to this privacy notice. If we make any significant changes that could affect you, we will send you notification.

When we refer to “we” or “us” in this notice we are referring to Westway Community Transport (a Registered Society with FCA number 27317R). We are listed on the Information Commissioner’s register of data controllers under Registration Number Z494945X.

In this notice, we use the term personal information to mean any information from which you can be identified. This might include your name, your home address, your email contact details, or your telephone number. Personal information does not include information where your identity has been removed (i.e. anonymous data).

We use the term special categories of personal information to mean information about your ethnic origin, your religious beliefs and/or your health.

 

Personal information we collect and use

  1. Individual Transport Services

We provide a range of transport services to individuals. This section of our privacy notice explains how we collect and use personal information from people who use our volunteer cars service, shopper service, minibus service, and/or our mobility scooter and wheelchair hire services.

When you contact us about these services, we will collect some personal information from you (for example your name, address, email contact details, telephone number).

During the course of providing these services to you, we may also need to collect additional information about you and/or any other individuals you tell us about (for example emergency contact details, payment information and/or proof of ID).

We will only collect and use your personal information in this way if:

  • it is necessary to enter into, or perform, a contract with you; or
  • if we are satisfied that we have a legitimate interest to record and retain this information for the purposes of delivering our services to you.

Depending on the nature of the services we provide to you, we may also ask you to give us special categories of personal information about you (for example, information about your health or ethnicity). We will collect and use this kind of information:

  • if we have your explicit consent; or
  • for equalities monitoring purposes.

We use a third-party, Shaunsoft Community Transport Software, to supply and support our community transport booking system. For more information, please see Shaunsoft’s privacy notice.

When we provide My Care My Way community transport services on behalf of the Kensington & Chelsea Social Council, we will access your personal details via the CharityLog systems.

2. Home to School Transport Services

When schools or local authorities contract with us to provide home to school transport services, the school/local authorities may provide us with personal information about the children who will be using our services each day. This will include personal information (names, addresses, dates of birth, and emergency contact details). Where relevant and necessary, we may also receive information about ethnic origin, medical needs, health conditions, mobility issues, language or communication requirements and/or disabilities.  In this regard, we will be acting as a data processor on behalf of the school or local authority and it is the responsibility of the contracting body to ensure that it has appropriate consents or authorisations to transfer this information to us.

We will share this information with our drivers for the purposes of delivering the home to school transport services and we will keep this information on record to comply with safeguarding best practice (see ‘Data Retention’ below).  We are satisfied that we have a legitimate interest to collect, use and retain this information for the purposes of delivering our home to school transport services.

3. My Care, My Way

When we provide My Care My Way community transport services on behalf of Kensington & Chelsea Social Council, we will access your personal information via the CharityLog system. We act as a data processor when we provide these transport services. If you have questions about how your personal information is shared by My Care, My Way, you should contact them directly or visit the frequently asked questions page on their website.

4. Group Transport Services Members

If you register with us as a charity, community group or voluntary organisation in order to benefit from subsidised minibus services (with or without a driver), we will collect and record personal contact information for individual(s) at the organisation (such as name, address, email contact details and telephone number).

We will only collect and use personal information in this way if:

  • it is necessary to enter into, or perform, a contract with you; or
  • if we are satisfied that we have a legitimate interest to record and retain this information for the purposes of delivering our services to you.

If we provide minibus services with a driver we may also obtain personal information about your passengers such as their name, address and telephone numbers for pick-up and drop-off purposes. In this regard, we will be acting as a data processor on behalf of the organisation and it is the responsibility of the organisation to ensure that it has appropriate consents or authorisations for individuals to transfer this information to us. We will not retain this passenger list information any longer than is necessary to fulfil the transport booking (s).

5. Training

When you register to take part in our training services we will collect your name, address, email contact details and telephone number. For certain training courses, you will also need to provide us with your date of birth, national insurance number, driving licence information. This information is necessary in order for us to enter into or perform our contract with you to provide the training. We will ask for your consent to collect information about any medical conditions that may affect your ability to drive.

We will share your details with the following third-parties when you undertake certain training courses with us:

  • Driver Certificate of Professional Competence – the Joint Approvals Unit for Periodic Training (JAUPT)
  • Minibus Driver Awareness Scheme (MiDAS), Car & MPV Training & Passenger Assistance Training (PATS) – the Community Transport Association (CTA)
  • First Aid Training – Pro-Trainings

We may also ask for information about your ethnicity where there is a substantial public interest to do so, in order to monitor equality of opportunity and treatment. We will always store this information in an anonymised format.

6. Marketing

Emails

We would like to keep in touch with you about the work that we do and the services we provide.

We will only send you marketing communications by email with your consent. We use a third party, Dotmailer, to deliver our e-communications. This company is a data processor for us and only processes personal information in line with our instructions. If you want more information, you can view Dotmailer’s privacy notice.

If you consent to receive email marketing communications from us, we will add your name and email contact details to our marketing database and we will share this information with Dotmailer in order to send the emails to you.

You can opt out of email marketing by clicking the ‘unsubscribe’ link in any of our emails or you can contact us at data@westway.org.uk or on 020 8964 4928 at any time to opt out, change or update your contact details or to update your communication preferences.

We keep information about our contacts on the cloud system, HubSpot. You can find more information in HubSpot’s privacy policy.

Post

We may send marketing information by post if we are satisfied that we have a legitimate interest, for example, sending our newsletter to service users or sending special offers to members.  You can contact us by email at data@westway.org.uk by post at 240 Acklam Road, London, W10 5YG, or by telephone on 020 8964 4928, at any time to tell us that you no longer wish to receive marketing by post or to update your contact details.

Telephone

From time to time, we may make marketing telephone calls to you but we never use automated calling systems. We will only contact you in this way if we are satisfied that we have a legitimate interest to do so and we will always check the telephone preference service and our own marketing preference records before we make any telephone marketing calls to you.  You can contact us on 020 8964 4928 or by email to data@westway.org.uk at any time to tell us that you no longer wish to be contacted by telephone for marketing purposes.

7. Monitoring and Development

We use anonymised information to carry out research into the use of our services and our effectiveness.  In some circumstances, we may share the results of this research with third parties such as organisations that fund our work but this information will always be anonymised so that it can no longer be associated with you

8. Visitors to our website

We collect personal information that you provide when you fill in a form on our website. We will only collect and use your personal information in this way if:

  • it is necessary to enter into, or perform, a contract with you (or to take steps, at your request, to enter into a contract with you); or
  • if we are satisfied that we have a legitimate interest to record and retain this information for the purposes of responding to queries or complaints, or for internal quality monitoring.

We may also collect information about how you use our website, and our Cookies Policy has information about how we use cookies on our website.

When you make a payment to us via our website we use a third-party Global Payments to process the payment. You can find information on their privacy notice at Global Payments.

We use a third-party website support provider, Codekbyte, to help maintain the security and performance of our website. To deliver this service Codekbyte may process the IP addresses of visitors to our website.

9. People who contact us via social media

If you send us a private or direct message via social media, we may share this information with other personnel within our organisation if we are satisfied that we have a legitimate interest to do so, for example, in order to respond to a specific query or to pass on information. We will not share any personal information that you provide in a message with any other organisations without your consent.

10. Queries and complaints

If you send a query or complaint to us, we will use the personal information you provide to us (for example, your name and the name(s) of any other individuals involved) in order to process your query or complaint and respond to you. Where we consider it necessary or appropriate, we will share this information with third parties such as our insurers, the Information Commissioner’s Office, the Financial Conduct Authority, a relevant Local Authority, the Department of Transport and/or the Transport Commissioner.

 

Sharing personal information

We only ever use your personal data if we are satisfied that it is lawful and fair to do so. We will never sell your personal data or share it with third parties who might use it for their own commercial purposes.

We will only disclose your personal information to third parties if:

  • where you have given us consent to share the information with the specific third party;
  • where information such as your email address is passed to Computer Network Consultants Ltd who provide technical support to us;
  • where we use cloud software providers Sage 50 for our accounting records and Shaunsoft Community Transport Software to store information about our service users;
  • where we use Dropbox Business to share information;
  • if we are under a legal duty to disclose or share your personal information, for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime;
  • in order to enforce any terms and conditions or agreements between us;
  • as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation (we will always notify you in advance and we will aim to ensure that your privacy rights will continue to be protected); or
  • to protect our rights, property and safety, or the rights, property and safety of others (this includes exchanging information with other companies, organisations, legal advisers and regulators for the purposes of fraud protection and credit risk reduction).

Data Security

We have appropriate security measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

  • We hold data electronically in our secure Shaunsoft Community Transport Software booking system and on our on-site file servers, which are protected by both hardware and software firewalls.
  • We have off-site backup servers in secure locations.
  • We regularly back up all of the data we hold.
  • We store papers in lockable cabinets in our offices when not being actively used and we have a secure off-site storage facility for archived papers.
  • When necessary, we dispose of or delete your data securely.
  • We ensure that our employees, agents and contractors are aware of their privacy and data security obligations and we take reasonable steps to ensure that employees of third parties working on our behalf are aware of their privacy and data security obligations.
  • We limit access to your personal information to those employees, agents, contractors and other third parties who have a need to know.

The transmission of information via the internet is never completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your electronic information transmitted to us and any transmission is at your own risk.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Transferring your personal information outside the EEA

We may transfer the personal information you give us to countries outside the European Economic Area (EEA), specifically when we use Dotmailer, Global Payments and HubSpot services.

If we transfer your information outside of the EEA in this way, and the country in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. If you would like more information about the safeguards we put in place, please contact data@westway.org.uk

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Our default retention period for personal data is 7 years from the date we receive the information unless otherwise specified by law. We keep children’s personal data for 7 years from the date of their 18th birthday and we keep personal data that may be required for safeguarding purposes for 35 years from the date of collection (as considered reasonable by High Court ruling 2015).

These retention periods may be extended or reduced if we deem it necessary, for example, to defend legal proceedings or if there is an on-going investigation relating to the information.

We review the personal data (and the categories of personal data) we hold on a regular basis to ensure the data we are holding is still required and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take steps to correct or delete the data.

11. Your rights

Under certain circumstances, by law, you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Ask us to correct any information that we hold about you which is incorrect, incomplete or inaccurate.
  • Ask us to erase your personal information from our files and systems where there is no good reason for us continuing to hold it.
  • Object to us using your personal information to further our legitimate interests (or those of a third party) or where we are using your personal information for direct marketing purposes.
  • Ask us to restrict or suspend the use of your personal information, for example, if you want us to establish its accuracy or our reasons for using it.
  • Ask us to transfer your personal information to another person or organisation.

If you want to access, correct or request restriction or erasure of your personal information, or to object to us using your personal data, or request that we transfer a copy of your personal information to another party, please contact data@westway.org.uk or 020 8964 4928. We may ask you to put your request in writing to us.

If you have given your consent to us processing your personal information, you have the right to withdraw your consent at any time. To withdraw your consent, please contact data@westway.org.uk or 020 8964 4928. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your data securely.

 

Queries and Complaints

Andrew Kelly, the Director, oversees compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Andrew:

  • by email to Andrew Kelly.
  • by post at 240 Acklam Road, London, W10 5YG
  • by telephone on 020 8964 4928.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

 

Published: 16/05/2018 By Westway Community Transport.


Terms & Conditions

By entering our Website, you agree to these terms and conditions (the “Terms”). Please review these carefully prior to making any purchases. By using this site, you agree to comply with these Terms.

Westway CT is an exempt Charity and Registered Society no27317R.

When entering this website, you agree not to impersonate any other person or entity or to use a false name or a name that you are not authorised to use.

Westway CT may modify these Terms at our sole discretion. If you do not agree to the changes to these Terms, you should stop using this website. By using this website after any such change(s), you agree to comply with the Terms as changed. Any changes made after you have placed an order with us, will not affect that order unless we are required to make the change by law.

When you purchase through the Westway CT website, you are offering to buy Services(s) for the price stated, subject to these Terms.

All orders are subject to acceptance and availability.

The Website contains an instructive guide that will walk you through the process of placing an order. You place your order by clicking on the [Payment] button in the order process.

Once you have made full payment, you will receive an email acknowledging the exact details of your order, providing you with a payment reference code and the value of your order that will be debited from your Payment Card.

Please note that while the Website lists only ‘available’ Services (i.e. any item/course/booking sold through the website), there may be occasions due to circumstances beyond Westway CT’s control, where a Service is not available. In this case, a refund of any unavailable Services booked will be made.

Unless otherwise notified, Westway CT’s acceptance of your order occurs when you receive an email notifying you that we have received payment for the Service booked by you and noted on that communication. Acceptance will be deemed to have occurred at the sending of this communication, regardless of technical problems you may experience, where the reasons are outside of Westway CT’s control, which may result in you receiving that email in a timely manner.

If you require any information regarding your booking(s), please contact us on 020 8964 4928 during our office hours of 9.00 am to 5.00 pm weekdays.

Westway CT may not accept your order if:

  • A Service you have booked is out of stock.
  • We are unable to obtain authorisation for your payment.

We reserve the right to reject any offer to purchase by you at any time and at our sole discretion.

 

Payments

Payment will be debited and cleared from your account upon confirmation of your booking through the Westway CT website.

By booking, you confirm that the Payment card that is being used is yours or that you have been specifically authorised by the owner of the Payment card to use it. All Payment cardholders are subject to validation checks and authorisation by the card issuer.

If the issuer of your payment card refuses to authorise payment, Westway CT will not be liable for a booking being cancelled.

The Westway CT website is fully secure. All Payment card transactions are processed using a secure online payment gateway that encrypts your card details in a secure host environment. The current secure host is Global Payments.

All reasonable care, as it is in Westway CT’s power to do so, to keep the details of your order and payment secure. In the absence of negligence on our part, Westway CT cannot be held liable for any loss you may suffer if a third party procures unauthorised access to any data you provide when accessing or ordering from the Website.

 

Refunds

Cancellations and Refunds

Westway CT reserves the right without notice to cancel or rearrange training dates when deemed necessary.

Westway CT shall where at all possible, use best endeavours to give prior notice of all course cancellations and offer an alternative date if applicable.

Prices and quotes are valid for 30 days only.

Failure to attend a training course without the relevant I.D documents, i.e: either a valid Photocard Licence, (or paper licence and valid passport), a valid Digital Tachograph Card or a valid Driver Qualification Card (DQC), will result in the termination of that booking and no refund of fees or re-arrangement of the day will be available.

Payment must be made in full at the time of booking.

Training cancellation refunds are determined by the number of working days’ notice given to Westway CT prior to course commencement.

Percentage Refund Formula:

  • 11 + working days 85%
  • 6 – 10 working days 50%
  • 0 – 5 working days 0%

Please note that if you have booked 5 dates training and have received the 5-day discount, this discount will not apply if a refund is requested for a cancellation. For example, if 5 dates are booked and you cancel 1 or more of the dates booked, you will be charged the full amount for the remaining dates and refunded the difference owed.

DEPOSITS ARE NON-REFUNDABLE

Please feel free to address any additional questions you may have to our team by email.

 

Help with your booking

If you require help when booking or would like to provide feedback on our service, please email us. You may also call us on 020 8964 4928 during our office hours of 9.00 am to 5.00 pm weekdays.

 

Copyright and Trade Marks

All content available on the this website, including, but not limited to, text, graphics, logos, buttons, icons, images, audio clips, data compilations, and software, and the compilation thereof (the “Content”) is the property of Westway CT, our affiliates, our partners or our licensors.

 

Content

By posting on any of our social media channels, you agree to be solely responsible for the content of all information you contribute. You also grant to Westway CT the right to use any content you provide for its own purposes including republication in any form or media. Comments may be moderated and may take up to72 hrs to be displayed, but Westway CT does not commit to checking all content and will not be liable for third-party posts. If you have a complaint about any post/s, please contact us.

Westway CT reserves the right at its sole discretion not to publish or to remove any comment including those that it believes may be unlawful, defamatory, racist or libellous, incite hatred or violence, detrimental to people, institutions, religions or to people’s privacy, which may cause harm to minors, is detrimental to the trademarks, patents and copyrighted content, contains personal data, improperly uses the medium for promoting and advertising businesses. This site is available to the public; information you consider confidential should not be posted to this site.

 

Third Party Links

Westway CT is not responsible for the content of any off-Website pages or any other websites linked to or from the Website. Links appearing on the Website are for convenience only and are not an endorsement by Westway CT, affiliates or partners of the referenced content, product, service, or supplier. Linking to or from any off-Website pages or other websites is at your own risk. We are in no way responsible for examining or evaluating, and we do not warrant the offerings of, off-Website pages or any other websites linked to or from the Website, nor does Westway CT assume any responsibility or liability for the actions, content, products, or services of such pages and websites, including, without limitation, their privacy statements and Terms. You should carefully review the Terms and privacy policies of all off-Website pages and other websites that you visit.

 

General

You acknowledge and agree that these Terms, together with Westway CT’s Privacy Notice, constitute the complete and exclusive agreement between us concerning your use of the Website, your data and any purchase by you of any Westway CT Services, and supersede and govern all prior proposals, agreements, or other communications.

If any provision of these Terms is held to be illegal, invalid or unenforceable in whole or in part, then these Terms shall continue to be valid as to the other provisions and the remainder of the affected provision. Any waiver of any of the provisions of these Terms by Westway CT shall not be deemed a waiver of any subsequent breach or default and shall in no way affect the other provisions of these Terms.

Shall not be deemed a waiver of any subsequent breach or default and shall in no way affect the other provisions of these Terms.

Nothing contained in these Terms shall be construed as creating any agency, partnership, or another form of joint enterprise between us.

Westway CT reserves the right to change these Terms at any time, and we encourage you to revisit these Terms periodically to ensure that you are at all times fully aware of our Terms. Any changes are effective immediately upon posting to the Website. Your continued use of the Website constitutes your agreement to all such Terms.

If you have any questions regarding these Terms, please contact us.

Please check back frequently to see any updates or changes to our Terms and/or Privacy Notice.

 

Published: 16/05/2018 By Westway Community Transport.