School Transport Service

Privacy Notice

Why do we collect and use this information?

Hampshire County Council is the Data Controller for the purpose of collecting and using information to assess whether you or your child meet the eligibility criteria to receive transport to their educational establishment. Hampshire County Council will also use information you provide to appropriately manage journeys to and from educational establishments to always ensure a child’s safety. This includes making an assessment on the type of transport that is required and whether a Passenger Assistant is required for the journey.

We collect personal information about you, including details of any special or medical needs which we may need to take into account when considering eligibility for and planning a child’s transport. We hold this personal data securely and use it to:

  • determine eligibility for transport provision;
  • understand a family’s circumstances to determine whether an exception to Policy applies;
  • where necessary manage the appeals process where an application has been refused including managing your attendance at the hearing itself;
  • provide safe and appropriate transport;
  • identify and allocate a spare seat on a transport route for your child;
  • establish a list of emergency contact numbers should there be a need to contact them whilst your child is on transport provided by Hampshire County Council;
  • share the emergency contact information with schools, transport operators and Passenger Assistants;
  • invoice parent or carer for contributions towards transport (where applicable);
  • provide financial reimbursement for the costs of transporting your child to school where appropriate;
  • verify mileage to support any claims for financial reimbursement;
  • determine whether you have an exemption from payment for School Transport due to parental receipt of applicable benefits and communicate with you about this;
  • establish if your child has any medical conditions that require additional management and to hold relevant medical information about managing such conditions whilst your child is receiving school transport;
  • establish if your child is travelling in or transporting a wheelchair whilst using school transport and ascertain any relevant travel requirements to ensure that the student and wheelchair are transported safely;
  • contribute to the core education record of your child;
  • undertake statistical forecasting and planning;
  • monitor and evaluate the effectiveness of our services;
  • receive and respond to correspondence relating to your child’s transport;
  • share your personal information with schools and transport operators to confirm the identity of those using transport and to provide safe and appropriate transport;
  • share any relevant information with schools and transport providers regarding incidents that occur whilst the child is receiving school transport which may include if the transport is damaged in any way and the provider is entitled to financial reimbursement;
  • respond to complaints or queries regarding the School Transport Service;
  • ensure compliance with our obligations under the accuracy principle of the UK General Data Protection Regulation (Article (5)(1)(d)), making sure our records about you and your family are up to date.

The following sections provide further detail around the information we process setting out what allows us to do this (lawful basis), who we may share it with, how long we keep it for (the retention period), alongside identifying any rights you may have and who to contact if you think we’re not handling your information in the right way.

The categories of information that we collect, hold and share

The following personal and special category information is processed:

  • personal information about the child applying for transport such as name, address, date of birth, school or educational setting details;
  • personal information of the individual submitting the transport application such as name, address, contact details, driving information, relationship to the child and parental responsibility of individual submitting transport application;
  • special category data about your child such as medical conditions, looked after status medication prescribed, treatments received and any relevant contact details of medical professionals;
  • special category data such as medical information that relates to individuals in the household or family which may be taken into consideration when determining eligibility for transport or granting an exception to Policy;
  • any relevant siblings personal information such as name, date of birth, educational establishment name;
  • financial information where applicable about the individual submitting the transport application such as whether you are in receipt of benefits and bank details;
  • your bank details in order to provide you with any relevant allowances;
  • personal information about emergency contacts such as name and contact information;
  • Information on incidents whilst a child is on school transport such as incidents between children or accidents.

The lawful basis on which we use this information

We collect and use the information ensuring that we comply with the UK General Data Protection Regulation (UKGDPR) and the Data Protection Act 2018 (DPA2018) requirements for processing through:

  • Article 6(1)(e) – the processing is necessary to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law;
  • Article 9(2)(g) – Necessary for reasons of substantial public interest on the basis of Union or Member State law which is proportionate to the aim pursued and which contains appropriate safeguarding measures; and
  • Sch.1, Pt.2, 1 – Substantial public interest conditions, for processing under the DPA2018.

These articles under the GDPR and the DPA2018 are supported by the following specific legislation:

  • Section 509A (2), (3) and (7)(a) of the Education Act 1996.

Under this lawful basis we do not require your consent to process personal information, but we are required, through this privacy notice, to ensure you are fully informed of why we are collecting this information and what we will do with it.

Storing and securing data

The information provided to us will be held within the County Council’s CAPITA One system, which we use to support the provision of school transport. The information held within CAPITA One will be kept in line with our retention schedule and then disposed of as appropriate. The County Council’s CAPITA One system is hosted by CAPITA plc in secure data centres based in the UK. No information leaves the European Economic Area (EEA) and the information is encrypted when in transit between County Council users of the system and the data centre the information is hosted within.

Documentation and Information will also be stored within the County Council’s Document Management System (DMS. These documents will be linked to the record created in CAPITA One for reference. The information held within the County Council’s DMS will be kept for in line with our retention schedule and then deleted as appropriate. The County Council’s DMS is hosted by the County Council in secure UK based data centres. No information leaves the European Economic Area (EEA).

Information will also be processed on the County Council’s C4C system which is used to manage your correspondence with the County Council. The information held within this system will be kept for in line with our retention schedule and then deleted as appropriate. The C4C system is hosted in secure UK based data centres. No information leaves the European Economic Area (EEA).

The County Council takes its data security responsibilities seriously and has policies and procedures in place to ensure the personal data held is:

  • prevented from being accidentally or deliberately compromised;
  • accessed, altered, disclosed or deleted only by those authorised to do so;
  • accurate and complete in relation to why we are processing it;
  • continually accessible and usable with daily backups; and
  • protected by levels of security ‘appropriate’ to the risks presented by our processing.

The County Council also ensures its IT Department is certified to the internationally recognised standard for information security management, ISO27001.

Who do we share information with?

We do not share information with anyone unless there is a lawful basis that allows us to do so.

CAPITA plc is a data processor for personal information held acting on our instructions for the purpose of delivering a contract to the County Council around the hosting and supporting of the CAPITA One system, which the County Council uses to store the information provided to us, as identified under this privacy notice. This includes accessing the CAPITA One system to fix any technical issues to ensure the system is fit for use.

Personal information will be shared with schools, Passenger Assistants and our contracted transport providers for the safe delivery of school transport services. Personal information about your child may also be shared with emergency contacts, medical professionals or emergency services in the event of an emergency whilst using the school transport service.

Requesting access to your personal data and your rights

Under data protection legislation, individuals have the right to request access to information about them that we hold. To make a request for your personal information, or someone you have responsibility for, please contact the Children’s Services Department’s Subject Access Request (SAR) Team.

You also have the right to:

  • prevent processing for the purpose of direct marketing
  • object to decisions being taken by solely automated means
  • in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed
  • claim compensation for damages caused by a breach of the Data Protection regulations

Please note that under the UK GDPR, there is also a right to erasure but the right to erasure does not provide an absolute ‘right to be forgotten’. Where the data being processed is for the purpose of ‘performing a task in the public interest or for our official functions, and the task or function has a clear basis in law’ (Article 6(1)(e))’, this right does not automatically apply.

Contact Details

If you would like more information about this service please visit our website.

Further information

The above information is the specific privacy notice for this service. For more information about your rights in relation to your personal data, see the County Council’s general privacy notice.

You have some legal rights in respect of the personal information we collect from you. See our Data Protection page for further details.

You can contact the County Council’s Data Protection Officer by email [email protected].

If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office.