Keolis Amey Luas
This is the Privacy Notice of Keolis Amey Luas. It provides information about what personal data (personal information) we collect and use about individuals outside our organisation, including users of our websites (www.luas.ie) and about customers of Luas.
We are Keolis Amey Luas (referred to as “we”, “us”, our” in this Privacy Notice). We are the operators of the Luas Light Rail Service in Dublin. We provide the service under contract from the National Transport Authority (“NTA”, see www.nationaltransport.ie) and Transport Infrastructure Ireland (“TII”, see www.tii.ie).
Our contact details are: Keolis Amey Luas, Luas Depot, Red Cow Roundabout, Clondalkin, Dublin 22, D22 C5P3. More information about our functions and services is available on our website at www.luas.ie.
Please read this Privacy Notice in conjunction with our Terms and FAQs relating to Luas Services, and with the Luas Bye-Laws, all available at www.luas.ie.
We have appointed a Data Protection Officer (DPO) to oversee our compliance with data protection rules. More information about our DPO, including contact details, is provided in Section 16.
Keolis Amey Luas collects and uses personal data (personal information) about individuals who come in contact with us, for a variety of purposes, including about Luas customers and about app and website users. In circumstances where we are responsible for deciding how we hold and use personal data about individuals, we are a “data controller”.
This Privacy Notice provides information about the personal data that we collect about customers of the Luas Light Rail Service and related services (including Park+Ride services, Luas TaxSaver and the Luas Text Service) (“Luas Services”) and about users of our app and websites (www.luas.ie and www.transdevireland.ie). The Luas Text Service is a service that allows Luas customers and members of the public to discreetly report incidents of anti-social behaviour that they witness on board Luas trams or at Luas stops.
We use cookies on our websites, and for more information about this, please see our Cookie Notices on our websites.
This Privacy Notice also provides information about other personal data that we collect and use about individuals who are external to our business.
As outlined the About Us section above, we operate the Luas Services under contract from the National Transport Authority (“NTA”, see www.nationaltransport.ie) and Transport Infrastructure Ireland (“TII”, see www.tii.ie). We are a data controller of personal information collected on our websites including in relation to Luas Standard Fares and Luas TaxSaver and for the Luas Car Park Payment System, as well as of CCTV footage captured at Luas stops and on Luas trams and in relation to the operation of the Luas Text Alert Service. We provide more information in this Privacy Notice about these data processing activities.
The NTA and TII are the data controllers of certain of the personal information that we process in relation to the Luas Services. In particular, they are responsible for personal information that is collected and used for the purposes of issuing Leap cards and they operate the websites www.leapcard.ie and www.studentleapcard.ie. For example, we process applications for Leap cards, and where we do so, we are data processors of this personal information on behalf of the NTA and TII.
It’s also very important to note that the NTA and TII have certain rights under our contract with them to access Luas customer information and, when the contract between us ends, to have that Luas customer information transferred to them and/or to a succeeding service provider for the Luas.
Where we refer to our data processing activities in this Privacy Notice in relation to the Luas Services, please note that we are also doing so in relation to data processing that we are undertaking for and on behalf of the NTA and TII, as identified above.
The primary data protection legislation that applies to us is the EU General Data Protection Regulation (the GDPR) effective from 25 May 2018, and Irish legislation that supplements the GDPR (being the Data Protection Acts 1988 – 2018 and the ePrivacy Regulations 2011). One of our obligations under the GDPR is to be transparent with you about our collection and use of personal information about individuals.
Data protection law provides rights to individuals with regard to the use of their personal information (personal data) by organisations, including Keolis Amey Luas. Irish and EU laws on data protection govern all activities we engage in with regard to our collection, storage, handling, disclosure and other uses of personal data.
Compliance with the data protection rules is a legal obligation. In addition, our compliance with the data protection rules helps individuals to have confidence in dealing with us and helps us to maintain a positive reputation in relation to how we handle personal information.
The data protection rules that apply to us are contained in the EU General Data Protection Regulation (the GDPR) effective from 25 May 2018, and in Irish legislation that supplements the GDPR (being the Data Protection Acts 1988 – 2018 and the ePrivacy Regulations 2011).
The data protection rules require that the personal data (personal information) that we (as data controller) collect and use about you must be:
There are “special categories” of more sensitive personal data which require a higher level of protection, such as information about a person’s health or about commission of criminal offences, prosecution for criminal offences, criminal convictions and/or sentencing for criminal convictions.
We collect, store, and use the various categories of personal information about Luas customers, app and website users and other individuals who are external to Transdev Ireland (that is, outside our organisation). We have prepared a table (available at the Appendix of this Privacy Notice) which sets out the main categories of personal information we collect about individuals (including but not just Luas customers), why we collect this personal information, our legal basis for collecting and using this personal information, where we got the personal information from and who receives the personal information from us.
Keolis Amey Luas will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
We may also use your personal information in the following situations, which are likely to be unusual:
If you fail to provide certain information when requested by Transdev Ireland, then we may not be able to respond or deal with a request that you have made to us (for example, to deal with a complaint that you have made to us or to subscribe to a service that we provide).
Yes, for some uses of your personal information. Please see the table in the Appendix to this Privacy Notice for more information. For some uses that Keolis Amey Luas makes of the personal information that is described in this Privacy Notice, we do not require your consent. For example, for Luas customers, our collection and use of personal information is mainly based on our contractual obligations.
For marketing communications, we only communicate to individuals who have asked to receive these updates or where we are entitled to rely on “opt-out consent” which are provided for under the rules on direct marketing (for example, for marketing to existing customers who we have transacted with in the previous 12 months or for business-to-business communications).
Please also see our Cookie Notices on our websites (www.luas.ie), which explains how and why we use cookies and other information-gathering devices on our websites, and how you can prevent cookies being used.
(Right to withdraw consent) In the circumstances where you may have provided your consent to the collection or use of your personal information for a specific purpose, you have the right to withdraw your consent for that specific use at any time. To withdraw your consent, please contact our Data Protection Officer (DPO) – please see the section below which provides contact details for our DPO (see Section 16 of this Privacy Notice below). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify affected individuals if this position changes.
