Making cycling e-asier privacy notice

Making cycling e-asier privacy notice

Cycling UK privacy notice for users of Making Cycling e-asier (the e-cycle rental scheme/e-cycle loan scheme)
Cycling UK funded by the Department for Transport

This privacy notice (Notice) explains how Cycling UK (we, our, us) collects, uses and shares your personal data in respect to the National E-Cycle Scheme (scheme), and your rights in relation to the personal data we hold.  

For details on Cycling UK’s other data processing please see our privacy policy.

Updating the Notice

We may modify this Notice at any time. We will endeavour to update you to any significant changes to this Notice. This Notice was last updated in January 2023. 

Data controller and contact details:

The Cyclists Touring Club (trading as Cycling UK with company number 25185 and registered as a charity in England and Wales with charity number 1147607 and in Scotland with charity number SC042541) is the data controller of your personal data. 

If you have any questions about this Notice, or if you would like to exercise any of your legal rights in respect of your personal data, please contact our Data Protection Officer using the following details: 

  • Email: dpo@cyclinguk.org 
  • ​Post: FAO Data Protection Officer, Parklands​, Railton Road, Guildford, Surrey GU2 9JX 

Department for Transport (DfT) and personal data collected through Scheme surveys

Please note that the DfT (and not Cycling UK) is the data controller for personal data collected in respect to any surveys you complete in connection to the Scheme. The DfT’s privacy notice can be viewed here. If you have any questions in respect to the DfT’s processing please contact the DfT; further details can be found here.

Please note that the DfT (and not Cycling UK) is the data controller for personal data collected in respect to any surveys you complete in connection to the Scheme and the geolocation data collected by trackers on the E-cycle (except as covered below).  

Cycling UK also shares personal data collected through the booking system with the DfT (and its processors) for the purposes of monitoring and evaluating the Scheme (see below).

How we collect your information

We may collect your personal information: 

  • From the information you provide to us when you fill in the form on our e-booking system 
  • When you correspond with us by phone; email, or by other means in respect to the Scheme 
  • ​From our Scheme partner Tier who provide us with geolocation data and battery level data in respect to their E-cycles 
  • From third parties, such as our Scheme partners (e.g bike retailers) or the police, if they provide information to us about your participation in the Scheme (for example, details of misuse, non-compliance with our terms, accidents or unlawful activity)   

The types of information we collect and our legal basis for using your information

We may collect and process the following personal information about you: 

  • When you use our e-booking system we collect your name, postcode, contact details (address, email address and phone number) and details concerning your hire or attendance at our short-term sessions (including any mobility/access requirements). We will process this information because it is necessary for the performance of our E-Cycle hire agreement with you or to take steps at your request prior to entering into the hire agreement with you, and – in the case of access requirements – to establish and comply with our legal duty of care  
  • If you are applying to hire an E-Cycle as part of our dedicated support for disadvantaged groups then we will collect information and evidence concerning your employment status and any relevant physical and mental health conditions. We process this information for our legitimate interests in confirming your eligibility for the support scheme. Where we process information concerning physical and mental health conditions we will do this with your explicit consent 
  • If you are applying to hire an adapted E-Cycle or anticipate in session with adapted e-cycles then we will collect information concerning any disabilities or access requirements. We collect this information because it is necessary for the performance of our E-Cycle hire agreement and to establish and comply with our legal duty of care  
  • We use geolocation and battery level data provided by Tier to analyse use of the E-Cycle. We may also contact you if the battery level is too low to remind you to the charge the battery which is important for maintaining the battery. Our legal basis for this processing is our legitimate interest in operating and improving the Scheme and ensuring that the E-Cycle you hire remains in good condition  
  • We will analyse the information collected for our legitimate interests to improve our operations and the Scheme 

Who we share your information with

Information processed in respect to the Scheme is shared with: 

  • The DfT who receive the information identified in the section above that we collect from you for the purpose of monitoring and evaluating the Scheme. Where this information contains special categories of personal data concerning any health issues you disclose to us, this information is shared with DfT for the purpose of monitoring equality of opportunity with a view to enabling such equality to be promoted or maintained 
  • ​Our partners (e.g. bike retailers) who will receive information from our e-booking system so that they can deliver the Scheme in accordance with the E-Cycle hire agreement 
  • Our insurers where this is required (for example, we may need to share your information in the case of an accident) to comply with our legal obligations or to exercise or defend a legal claim 

Legal obligations

We process your personal data for our compliance with our legal obligations including for charity regulatory reporting requirements, to report crimes and serious incidents, and to comply with our legal duty of care. In this respect and only if required, we will share your data with the Charity Commission, the police and other competent authorities. 

Direct marketing and consent

We also process your personal data where we have your specific consent to do so (for example, where we have sought and obtained your consent to send you direct marketing by email. If you have given your consent and you wish to withdraw it, please contact us using the contact details set out above or click the “unsubscribe” link in the emails we send. 

How long your information is kept

We will retain your personal data for as long as is required for legal purposes and our legitimate business purposes after the termination of our agreement with you. In particular: 

  • In relation to personal data relating to your use of the Scheme, we will retain that data for a period of seven years after the E-Cycle hire agreement has concluded in case any legal claims arise out of your use of the Scheme 
  • ​We will retain your details on our marketing database until you inform us that you no longer wish to receive our marketing communications. However, where you do unsubscribe from our marketing communications we will keep your details on a suppression list to ensure that we do not send you information you have asked not to receive 

Your rights

Under UK data protection law you have the following rights in relation to our processing of your personal data: 

  • To obtain access to, and copies of, the personal data that we hold about you 
  • To require us to correct the personal data we hold about you if it is incorrect 
  • To require us to erase your personal data in certain circumstances 
  • To require us to restrict our data processing activities in certain circumstances (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal) 
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for transmitting that personal data to another data controller 
  • To object, on grounds relating to your situation, to any of our processing activities where you feel this has a disproportionate impact on your rights 
  • To complain about the processing of your data to the Information Commissioner’s Office (ICO), although the ICO recommends that you first try and resolve the complaint with us  

Please note that the above rights are not absolute, and we may be entitled to refuse your requests where exceptions apply.

We may modify this Notice at any time. We will endeavour to update you to any significant changes to this Notice. This Notice was last updated in January 2023.

 

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