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Privacy Policy

Caledonian Sleepers Privacy Policy

Last updated: October 2017

Serco Caledonian Sleepers Limited (“SCSL”) is committed to protecting your privacy and personal information, and takes its responsibilities regarding the security of customer information very seriously. This Privacy Policy (“Policy”) explains how and why we collect and process your personal data during the course of providing our services.

By visiting www.sleeper.scot, www.newtrains.sleeper.scot (our Websites) or providing us with information, you are accepting and consenting to the practices described in this Policy and also agree to be bound by our Terms and Conditions.

Please read this Policy carefully to understand our views and practices regarding your personal data, how we treat it and to whom it may be shared.

The Policy may be subject to amendment at any time and all such developments will be notified to you by updating the Policy on our Websites directly.

For the purposes of the Data Protection Act 1998 and all applicable laws, including (from 25 May 2018) the EU Data Protection Regulation (EU) 2016/679, Serco Caledonian Sleepers Limited is the data controller.  Our registered company address is Basement and Ground Floor Premise, 1-5 Union Street, Inverness, IV1 1PP.

Please contact our Guest Service Centre for any matters relating to your personal information or this Privacy Policy via the “Contact us” details on our www.sleeper.scot website.

What personal information do we collect?

We may collect and process the following data:

  • Information you provide to us by filling in forms on our Websites including when you make a booking;

  • Information provided by corresponding with us by telephone, email or otherwise;

  • Information provided when using the mobile application.

  • Social media interactions;

  • Wireless internet services and Station Information Points provided by SCSL;

  • Information you provide when you subscribe to our marketing list;

  • CCTV when at our stations, lounges or on-board;

  • Information you provide to us by entering competitions;

  • Technical information from using our website including internet protocol (IP) address and other statistical data about your browsing actions.

  • Information provided from other sources, such as business partners, agents, industry bodies, and subcontractors in payment and service delivery, which we work with and we may receive information from;

  • Any other information you decide to share with us.  

The information you give us may include:

  • Name

  • Date of Birth

  • Sex

  • Age

  • Address

  • Email

  • Phone Number (including mobile phone number)

  • Financial and credit card information

  • Personal description and photograph

Please also refer to our Cookie policy, available at www.sleeper.scot.

What do we use your personal information for?

  • For operational purposes such as processing your booking, confirming your travel itinerary, alerting you as to any changes to your journey and any other obligation arising in connection to our agreement with you.

  • To personalise your travel experience.

  • To provide you with marketing and offers from us (where we have your permission to do so).

  • To improve our services including carrying out customer surveys and related activities.

  • To notify you about changes to our services or operations.

  • To deal with complaints, refunds and other ticketing and travel issues.

  • To contact you regarding participation in potential media opportunities.

  • For security purposes including crime prevention.

Who do we share your personal information with?

Your privacy is important to us and we will never sell your personal information or disclose this information to a third party for other purposes than those described in this Policy. When personal data is disclosed by us, there is a requirement for the third party recipient to also adhere to applicable data protection legislation.

We may disclose your personal information to third parties:

  • If they are within the group of companies controlled by our parent company, Serco Limited, which includes Serco NorthLink Ferries.

  • Business partners, suppliers and sub-contractors for the performance of any part of the contract we entered into with you. For instance, for the purposes of processing payments and delivery also for marketing, advertising and strategic development to improve our services and your guest experience, however you will not receive direct advertising material unless we have your permission.

  • In order to effectively facilitate your travel arrangements, including station, operators, industry bodies and other train operators and companies who offer onward or connecting travel such as a rail replacement services.

  • If we cease to operate the Caledonian Sleepers franchise, in which case we may transfer your personal data to the alternative operator appointed to enable them to use that information in line with the consent you have provided;

  • If we choose to sell or buy any business assets or our parent company Serco Limited is taken over, however the terms of this Policy will continue to apply to the use of this data.

  • If we are under a duty to disclose or share your personal data in order to comply with any legal and regulatory obligation; or in order to enforce or apply our terms and other agreements; or to protect the rights, property or safety of SCSL, our customers, or others. This includes passing information about you to other companies or the organisations specialising in the prevention of fraud and credit risk reduction or debt collection and tracing agencies.

CCTV

We may use CCTV in our lounges, stations, Guest Service Centre and on our trains for the primary purposes of public and staff safety, crime prevention, detection and deterrence and to assist and improve customer service. For these reasons, the information processed may include visual images, personal appearance and behaviours of staff, guests and general members of the public who were in the immediate vicinity of the area under surveillance.

We will only retain this CCTV information for the reasonable period of time necessary to assist internal monitoring or as long as legally required by regulatory bodies and law enforcement agencies. This information is kept in secure environments and access is restricted to SCSL designated security trained staff.

Telephone Call Recording

We may record telephone conversations of calls which come into the Guest Service Centre telephone system, it currently does not record the content of any telephone conversations outside of this system.

We use reasonable efforts to communicate that calls may be recorded, by including this notification in this Policy and advising all incoming callers to the Guest Service Centre by recorded message that they are being recorded.

The telephone call recording system in operation can record all incoming telephone calls and recordings may be used:

  • for training purposes;

  • to support the investigation of complaints;

  • to ensure we are complying with regulatory procedures and to provide evidence for any regulatory investigation;

The recordings shall be stored securely, with access to the recordings controlled and managed by the Guest Experience Director and Guest Service Centre Manager. Access to the recordings is only allowed to satisfy a clearly defined business need and reasons for requesting access must be formally authorised by the Guest Service Centre Manager. Browsing of recordings for no valid reason is not permitted.

Data Security and Storage

We employ strict administrative, electronic and physical procedures to securely retain the personal information we receive from you and to try to prevent accidental, unauthorised or unlawful access, disclosure, processing, destruction or damage by organisations or individuals.

All personal data you provide to us is stored on our servers. At present we have servers located within the EEA (European Economic Area). If circumstances arise that some of your information may be transferred out of the EEA, we will make every effort to ensure that your information is protected to the same data protection standards as if it were processed within the EEA and shall take all reasonable steps to ensure compliance with this Policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Websites; any transmission is at your own risk.

Third Party Privacy Policies

Our website may contain links to websites or contact details belonging to third parties. These third parties have their own privacy policies which you should familiarise yourself with prior to submitting any personal information. SCSL accepts no responsibility or liability for these polices or third parties’ compliance with them.

Direct Marketing and Advertising

You will only be contacted directly by marketing about any offers or promotions if you choose to subscribe to our marketing list on our website. Currently, any such communication will only occur by email.

If you no longer wish to be contacted, you can be removed from our marketing list by selecting the ‘unsubscribe’ button at the bottom of any SCSL offer or promotions email. Otherwise, you can write to us at: Marketing Department, Caledonian Sleepers Limited, 1 Union Street, Inverness, IV1 1PP or via email at communications@sleeper.scot. Please ensure you correspondence is marked ‘Unsubscribe: Marketing Contact List’ and include your full name, email and telephone number to ensure your details are fully deleted from our direct marketing system.

Access to your information

You have the right to access the personal information SCSL holds about you. If you wish to do so, please submit a request in accordance with the following guidelines:

i. Make your request, in writing and marked ‘Subject Access Request’, to our Subject Access Request Officers in the first instance:

Email: GSC@sleeper.com
Postal Address: Subject Access Request Officers, Legal Department, Caledonian Sleepers Limited, 1 Union Street, Inverness, IV1 1PP 

ii. You are not required to state WHY you require the information, but to ensure efficient location and retrieval of your data, the request should include as much detail as possible regarding the information you wish to access (such as dates of travel, dates of booking and other specific details of information required).
iii. You will also be required to provide two forms of identification to prove who you are (such as a copy of the applicants driving licence and passport), and where required, an appropriate data subject consent authority or court order will need to accompany the request.
iv. Subject to future amendment of UK Data Protection legislation, any access request may incur a fee of £10 to meet our costs in providing you with details of the information we hold about you, as permitted under the current Data Protection Act 1998.
v. Once a Subject Access Request Officer receives a Subject Access Request, all efforts will be made to fully comply within 28 days subject to receipt of all required information from you. In any event, you will receive all the information that has been located and can be released within 30 days and an explanation for any information that cannot be provided at that time.
vi. In accordance with data protection requirements, SCSL will not release information held about individuals without their consent including details of third parties which may be contained in the requested information. If this is the case, SCSL shall seek appropriate consents or otherwise anonymise and redact the information. If this is not possible, SCSL may decide not to release the information or that it is prohibited from doing so.

Need to correct or update your records?

Please direct all such requests to the Subject Access Request Officers at the same contact details listed above. Your correspondence should be marked ‘Data Protection - Personal Information Update’.  We are under a legal obligation to ensure all information we process about you is accurate and kept up to date.

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