Privacy Policy

TRANSDEV WELLINGTON PRIVACY STATEMENT

 This Privacy Statement provides an overview of how Transdev Wellington Ltd collects, uses, retains and discloses personal information, and has been prepared in accordance with our obligations and your rights set out in the Privacy Act 1993.

 For the purposes of this Privacy Policy, "us", "our" and "we" means Transdev Wellington Ltd of Level 3, 77 Thorndon Quay, Pipitea, Wellington, 6011 New Zealand and our related entities (including the Transdev group entities). "You” means anyone who uses our services (including provision of passenger transport services, advertising services, websites, applications, competitions, enquiries and complaints and customer surveys) (“Services”) or visits our websites.  We may modify this Privacy Statement from time to time by posting an updated version on our website (at https://www.transdevwellington.co.nz/footer-pages/privacy-disclaimer/). By continuing to use our Services or our website, you consent to any such modifications.

 This Privacy Statement explains:
  • what kind of personal information we collect;
  • how we collect personal information;
  • our use of CCTV footage;
  • how we use personal information;
  • how we use data obtained from body worn cameras;
  • how we store personal information;
  • how we disclose personal information;
  • our use of cookies;
  • our use of Google Analytics;
  • how you can access/correct your personal information;
  • how long we hold personal information; and
  • how you can contact us for further information.

 

COLLECTION OF PERSONAL INFORMATION

Personal Information we may collect

The personal information we collect about you will depend on the circumstances of our dealings with you, the type of Service(s) you may request and the payment methods chosen for the Service(s). We will only collect personal information in connection with our provision of the Services. Personal information collected may include:

  • your first and last name;
  • your contact phone number and email address;
  • your credit card or other payment details;
  • your billing address;
  • any information you give to us with respect to your use of our Services (which may include information such as comments, likes, tweets, status comments, profile information and complaint details); and
  • any images and audio from Body Worn Cameras, as described below.

By providing this information to us, unless you indicate otherwise, we will assume that you have given your consent to the collection of such personal information.

How we may collect Personal Information

We may collect personal information:

  • directly from you when you deal with us in person, including on the telephone, through our websites, or by other correspondence, including by letter, fax or email;
  • in the course of us providing Services to you;
  • when you participate in competitions and customer surveys relating to the Services; and  
  • from CCTV and Body Worn Cameras when you are in or around railway stations and rail vehicles on the Metlink Rail Network (“Network”).
Surveillance and CCTV

Transdev has controlled access to Greater Wellington Regional Council’s (“GWRC”) closed circuit television (“CCTV”) system as set out in GWRC’s Privacy Statement, which can be found here – https://www.metlink.org.nz/customer-services/security/.  All use, access and disclosure of CCTV data by Transdev is in accordance with GWRC’s Privacy Statement.

 We also operate a Body Worn Camera closed circuit television (“BWCCTV”) surveillance system across the Network.  The BWCCTV devices we operate record visual and audio data.  Wearers of BWCCTV wear a label on their upper body indicating that BWCCTV is in operation, whenever they are deployed with BWCCTV.

 USE, RETENTION AND DISCLOSURE OF PERSONAL INFORMATION

Use of Your Personal Information

We use the personal information we collect from and about you to:

  • provide the Services to you, including public transport services;
  • measure and improve the Services, including through research and data analysis by us and our service providers;
  • improve your customer experience with our transport Services;
  • allow you to comment on the Services;
  • allow you to participate in competitions or rewards programs;
  • provide you with customer support; and
  • respond to your inquiries.

We use BWCCTV Data for the purposes described below.

Use of BWCCTV Data

We may use the video and for audio data obtained from the BWCCTV (“BWCCTV Data”):

  • as evidence to support criminal investigations;
  • for investigating incidents and complaints in relation to our Services;
  • to ensure ticket revenue is appropriately collected; and
  • for maintenance and operation checks to ensure the BWCCTV system is operational.

BWCCTV Data will only be viewed by authorised people in accordance with the purpose it was collected for. No attempt is made to identify individuals from BWCCTV Data except in relation to a reported or suspected incidents requiring investigation.

Storage of Personal Information

Your personal information will be stored by us in accordance with our privacy procedures, and may be stored electronically or in paper copy on computer servers or on files under our control or on our behalf by third party data storage providers. By way of example, personal information provided in the course of lodging a complaint regarding the Services may be included in software hosted by third party service providers under contract to us.

We will take reasonable administrative, technical and procedural steps to protect your personal information from misuse, interference and loss, or from unauthorised access, use, modification or disclosure.

If it is necessary for your personal information to be given to a person in connection with the provision of the Services, we will do everything reasonably within our power to prevent unauthorised use or disclosure of the information.

Disclosure of Personal Information

We may disclose your personal information to:

  • third parties, for example to GWRC, the local government entity on whose behalf we provide the Services;
  • our contractors for the purposes of helping us provide certain Services;
  • transport carriers;
  • travel service providers;
  • data processing companies to complete a payment transaction on your behalf or provide you with a Service that you requested; and
  • related entities where necessary to fulfil our business purposes (and other purposes specified in this policy). This may include the provision of your personal information to our related entities overseas (including Australia and France) where considered by us as necessary to perform the Services.
Disclosure of BWCCTV Data

In the event of unlawful activity being recorded, we may disclose BWCCTV Data that records the incident to the New Zealand Police for the purpose of a criminal investigation.  Likewise, if the New Zealand Police believe some unlawful activity was carried out then they may view, or ask us to hand over, any BWCCTV Data that may assist in their investigation.

We may share BWCCTV Data with GWRC (which owns the Network) to enable it to:

  • investigate incidents;
  • ensure ticket revenue is appropriately collected; or
  • audit our compliance with our contractual obligations under our service agreement with GWRC.

We will not share BWCCTV Data with any other party, unless required to do so for law enforcement purposes.

 HOW WE USE COOKIES AND LOG FILES

 We may use cookies and analytics tools on our website and applications:

  • for session authentication purposes; and
  • to collect information about how you use our website or applications.

A cookie is a small data file that the website or applications sends to your browser or mobile device (as the case may be), which may then store it for later retrieval by the website or application. Some cookies we use last only for the duration of your website or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to the website or mobile application and will last for longer.

We may use analytics tools that track information about your use of the website or mobile application. We do not use cookies to track your internet activity before or after you leave our website or mobile applications. If you reject cookies, you may still use our website or mobile applications, but your ability to use some of their features or functionality may be limited.

Use of Google Analytics

We use the Google Analytics service, which will issue cookies from its own servers and which will be able to track visitors throughout our website and mobile applications. For more information on how Google Analytics collects and processes data, please click here. Please refer to Google's Privacy Policy for more information. To opt-out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

 HOW CAN YOU ACCESS AND CORRECT YOUR PERSONAL INFORMATION

 We are committed to complying with our obligations under the Privacy Act 1993. If you would like to access your personal information, or have a question about the collection or use of your information, please contact us via the details below.

You may also request that the personal information we hold about you be corrected by contacting us.  If we do not agree to your request for a correction, you may then request that we take reasonable steps to attach to the information a statement of the correction sought but not made.

We will provide you with a response as soon as reasonably practicable, but within 20 business days.

 HOW LONG WE HOLD YOUR PERSONAL INFORMATION

 When your personal information is no longer required for the purposes for which it was collected, we will take reasonable steps to destroy the information or to ensure that the information is de-identified.

 HOW TO MAKE A COMPLAINT

 If you would like to make a complaint about the collection or use of your information please contact us using the details below.  We will provide a response as soon as reasonably practicable, but within 20 business days.

If you are not satisfied with our response to your complaint, or at any time during the process, you may refer your complaint to the Office of the Privacy Commissioner (www.privacy.org.nz).

 HOW TO CONTACT US 

Please write to us at:

Privacy Officer - Transdev Wellington Ltd
GPO Box 5092
Melbourne
Victoria, Australia 3001

 Alternatively, please email: tda.privacy@transdev.com.au