Freedom Pass Privacy Statement

  • By London Councils

What information do we collect?

We collect the following information about you;

Name, address, date of birth, age, address, photograph, email address, phone number, gender, title, national insurance number, ethnic origin, evidence relating to address and identity, medical information, redacted card payment details for replacement passes and journey data (used only for settlement purposes and to detect and prevent crime as part of a fraud investigation).

If you telephone the Freedom Pass helpline your call will be recorded for training and quality purposes.

Why do we need it?

We use the information to assess if you are eligible for a Freedom Pass and, if you are eligible, to manage the scheme. We may also use it to prevent fraud, to promote and achieve equal opportunities and to improve the scheme.

Who do we share your information with?

Your information will be shared with the London borough in which you reside and with our contractor, ESP Group, which provides the Freedom Pass application processing, card production and contact centre services. Your information will only be shared with other organisations (e.g. other local authorities, Transport for London, government departments and law enforcement agencies) to provide the services or where it is legal to do so (e.g. to detect and prevent crime and protect public funds). Your information may be matched with data from other sources, including CCTV or ticket usage data. Your information will not be used for marketing.

While London Councils does not routinely transfer Freedom Pass data outside of the European Union, we use a sub-processor located in the US for certain mailing functions. The company is a certified member of the EU-US Privacy Shield scheme, which requires them to provide similar protection to personal data as given for data processed within the EU. More information about Privacy Shield can be found here.


How long do we keep your information for?

We keep successful application information for as long as you are a Freedom Pass holder and up to 2 years afterwards.

Hard copy documents that are capable of being held electronically are destroyed immediately once processed.

Electronic copies of documents are deleted up to 2 years after your record is deactivated on our database.

Your record will be deleted up to 2 years after your record is deactivated on our database.

All audio recordings (of telephone calls) and emails are deleted after 6 months.

Who is responsible for your information?

London Councils and the London borough in which you reside are separately responsible for making sure your information is managed properly.

What you can do with your information?

You can ask what information we have about you.

You can ask us to change anything that is inaccurate.

Can I get some more information?

A GDPR policy document is available on London Councils website, or please call 0300 330 1433 if you would like a copy posted to you.

You can also email [email protected] if you have any questions or concerns about how your information is used.

Where can I complain if I feel my information is not being used correctly?

If you wish to complain to London Councils, you can do so by email to [email protected]. You can also complain to the Information Commissioner’s Office (ICO)