National Entitlement Card privacy notice

Find out how Stirling Council uses personal data by checking the Council’s website at the following address:

https://www.stirling.gov.uk/privacy-statement/

Our website contains a Register of Data Processing which lists all the different ways
in which the Council uses personal data.

This Privacy Notice provides more information about just one of those processes.

The Council has a Data Protection Officer to make sure it is complying with data protection laws.

They can be contacted at:

Data Protection Officer
Stirling Council
Old Viewforth
14-20 Pitt Terrace
Stirling
FK8 2ET

Email: dataprotection@stirling.gov.uk
Telephone: 01786 404040

To issue National Entitlement Cards (NEC) to elderly, disabled residents and young people aged 5-25 of the Stirling Council area. The scheme provides free travel on registered local and long-distance bus services throughout Scotland, at any time of day for any number of journeys, for those aged 60 and over, as well as for eligible disabled people who live in Scotland. This also includes free concessionary travel for young people under the age of 22.

Members of the public who believe themselves to be eligible for a National Entitlement Card submit applications to the Council consisting of a completed application form, a recent photograph, proof of age or disability and proof of current address. Council staff carry out a desk-based assessment in relation to qualification criteria stipulated by Transport Scotland for disabled and elderly concessionary cards on behalf of the Scottish Government. Applicants are then informed whether or not they have been successful. 

Young people aged 5-22 can apply online for the NEC free travel card at: freebus.scot or for those who do not have the required identification to apply online can apply direct to the council. The Young Scot element is added automatically to the card for all young people aged 11-25 which offers additional services, membership, rewards and discounts (young.scot).

Personal data is about applicants who believe themselves to be eligible for issue of a National Entitlement Card:

Person Data (Title, Name, Gender, Date of Birth, Photo,

Death Indication and Date, UCRN-Unique Citizen

Reference Number)

Address Data (Address, Postcode, Local Authority,

UPRN-Unique Property Reference Number; Delivery

Address, Delivery Postcode)

Person and Residence Proof Data (Indicator that proofs seen (including disability), Type of proofs seen, Photo referee details)

Contact Details Data (Phone Numbers, Email Address)

Photograph (for the purpose of school applications taken from the school stored photograph data base)

We process personal data necessary to comply with a national scheme.

UK GDPR Article 6(1)(e) - processing is necessary for the performance of a task carried out in the public interest

Application forms submitted by Stirling Council residents who believe themselves eligible for issue of a National Entitlement Card.

Information may be requested from Social Security Scotland in order to support an individual’s disability benefit entitlement.

Information will be taken from the school database in order to verify a young person’s identity for the purpose of processing their application.  

Personal data is recorded electronically in the secure national Card Management System (CMS) 

Paper copies of the applications are kept and stored securely.

Electronically stored on council secured network.

Proof of entitlement are retained and stored securely until the application is processed. After the application is processed the application form is retained and proofs of eligibility are destroyed with confidential waste. If the application is on the grounds of disability the proof of entitlement is retained for records for the duration of the pass.

For the purpose of the young person’s card aged 5-22, information will be securely stored for 2 years on the council’s network. Thereafter it will be deleted.  

Data is shared as below:

• Data is shared and processed in order to provide and administer a personalised smartcard – the National Entitlement Card (NEC) - that may be used to allow efficient and customer-friendly access to various Scottish public sector services.
• Data is shared and processed in order to provide a means that an individual may use to assist in confirming who they are.
• Data is shared and processed to allow costeffective access with the NEC to local concessionary travel schemes. Data is used to administer these schemes, including assessing eligibility, reimbursing transport operators for concessionary travel made using the NEC, developing improvements, monitoring the effectiveness of the schemes and preventing misuse.
• Where local concessionary travel is claimed on health grounds, any details about disability are processed to administer the appropriate travel concessions.
• Data is shared and processed to provide an accredited proof of age smartcard for young people (a Young Scot card carrying the PASS - The National Proof of Age Standards Scheme - logo as a hologram).
• Data is shared and processed to allow a Local Authority to maintain the accuracy of the data they are responsible for.
• Data is processed on behalf of Transport Scotland to allow cost-effective access with the NEC to national concessionary travel schemes. Data is processed to administer these schemes, including assessing eligibility, monitoring the effectiveness of the schemes and preventing misuse.
• Where national concessionary travel is claimed on health grounds, any details about disability are processed on behalf of Transport Scotland to administer the appropriate travel concessions.
• Data is processed on behalf of Transport Scotland to allow cost-effective access to commercial Scottish smart transport ticket solutions set up by Transport Scotland as part of the saltirecard scheme.

You have the following rights under data protection laws. If you have a request under any of these rights, you can make a subject access request.

Access to your information

You have the right to request a copy of the personal information that we hold about you. This is known as a subject access request and is free of charge.  We must respond within one month, although this can be extended to three months if the information is complex.

Correcting your information

We want to make sure that your personal information is accurate, complete and up to date. Therefore you may ask us to correct any personal information about you that you believe does not meet these standards.

Deleting your information

You have the right to ask us to delete personal information about you where:

• you think that we no longer need to hold the information for the purposes for which it was originally obtained
• we are using that information with your consent and you have withdrawn your consent - see the 'withdrawing consent to using your information' section below.  Please note that in general we do not rely on consent as the legal basis for processing your personal information
• you have a genuine objection to our use of your personal information - see 'objecting to how we may use your information' below
• our use of your personal information is contrary to law or our other legal obligations.

Objecting to how we may use your information

You have the right at any time to tell us to stop using your personal information for direct marketing purposes, profiling or research purposes. 

Restricting how we may use your information 

In some cases, you may ask us to restrict how we use your personal information.  This right might apply, for example, where we are checking the accuracy of personal information that we hold about you or we are assessing the objection you have made to our use of your information. 

This right might also apply if we no longer have a basis for using your personal information - but you don't want us to delete the data.  Where this right is realistically applied will mean that we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

Withdrawing consent to use your information

Where we use your personal information with your consent, you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.

Your request to transfer your data

If we are processing your personal information with your consent or as part of a contract with you, and it is held in an accessible and machine-readable format, you have a right to ask us to transmit it to another organisation. This is known as the right to data portability.

Our profiling or automated decision-making processes

We make some use of automated decision-making processes but very little use of profiling.  Where these techniques are used, this will be explained in the specific privacy statements relating to those functions, together with a description of the reason involved in any automated decision-making.

If you want to complain about or comment on how we have processed your personal information, you should email dataprotection@stirling.gov.uk

If you are still unhappy with how the council handled your complaint, you can contact the UK Information Commissioner's Office at:

The Information Commissioner,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire SK9 5AF

Phone: 0303 123 1113

You can find further information on the Information Commissioners Office website.