Skyss Travel app - Privacy policy

Purpose

In this privacy policy you will find information about any of your personal data that is collected and/or processed by Vestland County Council (VLFK) in its Skyss Reise app, why this personal data is collected and/or processed and your rights in relation to the processing of personal data.

Personal data is any form of information that can be directly or indirectly
connected to an identifiable person. Any processing of personal data carried out by VLFK is subject to the Norwegian Personal Data Act under the EU GDPR Regulation.

The processing of personal data described in this privacy policy is
necessary to enable VLFK to test a new method in the Skyss app for recording anonymous travel data (position and movement data) and to capture feedback from passengers in order to improve the travel offering. It is also necessary to record telephone numbers in order to carry out the draw used to reward participants.

Responsibility and scope

VLFK, represented by the Managing Director of Skyss, is the data controller for your personal data.
The statement describes the items of your personal data that VLFK processes in the Skyss app, cf GDPR Articles 24 to 31, and general information about how we handle personal data.

VLFK may process one or more of the following categories of personal data or user data, in specific work processes and systems.

 

	Processing
Telephone numbers	Processed in a separate system from responses and position/movement data. Deleted after max three months when prizes are drawn.
Position	Processed in a separate system from telephone numbers and thus not personal data.
Response from the respondent/registered person	Processed in a separate system from telephone numbers and thus not personal data.
Movement data	Processed in a separate system from telephone numbers and thus not personal data.

 

Target audience

All passengers who consent to take part in the survey and/or consent to share anonymised travel and movement data with Skyss.

Data processing requirements

VLFK takes all necessary technical and organisational steps required to ensure that your personal data is processed securely, pursuant to VLFK's security guidelines and current statutory requirements for integrity, confidentiality and accessibility. We store your personal data for as long as necessary to complete the purpose for which the personal data were collected, in this case with the Skyss Reise app.

Processing of personal data

Neither response, position data or movement data are linked to any personal data. Telephone numbers are recorded in a separate system and are processed as personal data, without any link to responses or registered travel/movement data.

Processing of user data that are that are not personal data

Responses, and position and movement data, are processed by Skyss in a way that ensures anonymity. Position and movement data recording approximate positions of basic statistical units, stops or terminals that mark the end points of journeys are processed locally on the device (e.g. the mobile telephone), before this data is available to Skyss. It is not possible for Skyss to link these data, either directly or indirectly, to individual persons.

Logging of user activity

No user activity is logged in the Skyss Reise app. The legal basis for such logs is described in GDPR Article 6 a, consent.

Rights

As a person registered in the app you have a right of access to your personal data, cf GDPR Article 15. You are also entitled to ask for incorrect or incomplete information to be rectified or erased, cf GDPR Articles 16 and 17. A request from a registered person shall be answered free of charge and at the latest within 30 days. The Skyss Reise app also contains a self-service option for accessing and erasing the position and movement data processed on your device (e.g. your mobile telephone).

Database

The basic data is collected from mapping of processing activities.

Transfer of personal data to third parties

The main rule is that the data shall not be transferred to persons or enterprises other than VLFK. In the case of the Skyss Reise app, no such transfers take place.

Drawing winners

At the end of the project (around December 2021) Skyss will draw 12 winners of a monthly season ticket, from those who consent to take part in the survey. The winners will be contacted.

Storage and erasure

Storage of the personal data (the telephone number) takes place in accordance with official requirements and VLFK's guidelines for processing personal data. Data will be erased at latest after three months, once winners have been drawn.

Contact information

Please contact VLFK's Data Protection Officer if you want more information about VLFK's processing of personal data.

Email: personvernombud@vlfk.no