e+ card privacy notice
1. Name of the Data Controller
Bracknell Forest Council
Time Square, Market Street, Bracknell, RG12 1JD
2. Contact for Data Protection Officer
Data Protection Officer
Bracknell Forest Council
Phone: 01344 352000
3. Purpose and lawful bases for the personal data that you process
Your personal data will be used to process your e+ card application and join you to the services you require under your e+ card account, including the following if selected:
‘Legal obligation' stated in
- the Cabinet Office Guidance relating to the National Fraud Initiative to provide Concessionary Travel bus pass rights
- FSA and money laundering requirements required to provide Prepaid Debit card services
- ‘Consent’ when joining the e+ card scheme, providing your photograph, accessing recycling reward points and e+ discounts and offers
- ‘Public interest’ when providing access to the library services
- ‘Performance of a contract’ when providing leisure services with our external provider Everyone Active
4. Basis of processing for special categories of data
Your photograph is processed to be held with your other personal data and printed onto your e+ card to uniquely identify you as the person entitled to access the services associated with your own e+ account. It is shared with the e+ services you select to join.
Special Categories data (if you provide it) on your gender, racial and ethnic origin, religious belief, disability and/or sexual orientation is being processed for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in line with *Article 89(1) based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
5. Recipients of the personal data that is collected and processed
We will need to share your personal data with third parties to deliver our services. You can ask us for more information on our third party service providers. We will not sell your personal data to any party.
Third parties with e+ include the following (this is not an exhaustive list):
- our e+ data management system is managed by SmartCitizen Ltd
- our contracted suppliers for the recycling incentive scheme are Suez and their processor, AMCS
- data for concessionary travel (bus passes) are shared with The Fraud Office
- leisure service data is shared with our contractor Everyone Active/Sports and Leisure Management Ltd
- for the library service we use Alto/Capita
- for the direct payments prepaid service we use Allpay Ltd and their processor Carta
6. International transfers and if applicable any safeguards in place
Your personal data may be stored securely in a cloud based system within the European Union. The council will seek to make sure that an adequate standard of security is obtained if personal data is stored on a system outside the European Union.
7. Retention periods for the data and the criteria for setting that period
The retention period is set in legislation or as required for the services you select that are being provided in connection with your e+ card account. Your data will not be kept for longer than is necessary. It will be retained by the e+ system as long as you hold an e+ card account.
8. Individual rights
The GDPR provides the following rights for individuals:
- The right to be informed.
- The right of access.
- The right to rectification.
- The right to erasure.
- The right to restrict processing.
- The right to data portability.
- The right to object.
- Rights in relation to automated decision making and profiling.
9. Right to withdraw consent
If we ask you for your consent when providing our service you have the right to withdraw consent.
10. Right to complain to the ICO
If you are not satisfied with the way that Bracknell Forest Council is holding your data, you can contact the Information Commissioner:
Information Commissioner's Office
Phone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Fax: 01625 524 510
You can view directions to the Information Commissioner's head office.
11. Existence of profiling and/or automated decision making
Bracknell Forest Council uses e+ system data in anonymised reports to monitor how we reach all population groups with e+ services.
Bracknell Forest Council does not need to collate your e+ related personal data for automated decision making.