Data protection declaration — Ticket inspections

Hordaland County Authority, represented by Skyss, is responsible for storing and using your personal data that is collected for the imposition of a penalty charge for invalid travel documents. 

Personal data is all information that can be used to identify you. Below, you will find more information on how Skyss processes personal data and about your rights in relation to Skyss.

Purpose

Customers who cannot present a valid travel document shall pay a penalty charge. This follows from Section 4 of Skyss’s Transport Regulations, cf. Section 33 of the Commercial Transport Act. The purpose of Skyss’s processing of personal data is to ensure collection of the penalty charge by sending an invoice – issued either via Vipps or in paper format.

Grounds for processing personal data

Skyss’s processing of your personal data for the purpose of imposing a penalty charge requires a legal basis for the processing.

The legal basis for Skyss’s processing is a justifiable interest, cf. General Data Protection Regulation, Article 6, No. 1 f); cf. Transport Regulations, Section 4.

What personal data does Skyss process?

If an inspection reveals that you have an invalid travel document, and you do not pay the penalty charge on the spot, Skyss will process the following personal data about you: name, address, telephone number, date of birth, place of inspection, time of inspection and imposition of penalty charge. 

For inspectees under 15 years of age travelling without a valid travel document, the names of their guardians will also be processed.

If you submit a complaint about the imposed penalty charge, Skyss will also process any personal data that emerges from your complaint and any enclosures to your complaint.

Sources of personal data

All personal data processed in connection with the imposition of a penalty charge and complaint are collected from you.

The Processor

Securitas AS carries out inspections and registers penalty charges on behalf of Skyss.

Lindorff AS issues invoices and collects imposed penalty charges on behalf of Skyss.

Both Securitas AS and Lindorff AS process your personal data on behalf of Skyss and are therefore considered to be data processors. Processing of your personal data by Securitas AS and Lindorff AS is regulated in separate data processing agreements. The data processing agreements ensure that your personal data are processed in compliance with this data protection declaration.

Disclosure to third parties

Skyss does not disclose your personal data to third parties unless there are legal grounds for such disclosure, for example a ruling or written order from the prosecuting authorities.

Access to personal data

The personal data processed about you will be accessible to authorised personnel with an official need at Securitas AS, Lindorff AS and Skyss.

Storage and erasure

All data are stored in Norway and Finland. The servers are operated by personnel in Norway and Finland. All data stored are kept in accordance with applicable legislation. Skyss works in accordance with the principles for automatic data protection and data protection as a default setting. This implies among other things that your personal data are not stored for longer than necessary to fulfil the purpose of the service.

Personal data processed in connection with issuing invoices and collecting penalty charges are stored according to Section 13 and pertaining regulations of the Bookkeeping Act.

Personal data processed in connection with complaints on imposed penalty charges are stored in compliance with the Freedom of Information Act and the Archives Act.

Security

Securitas AS, Lindorff AS and Skyss have implemented data security measures and internal procedures to verify that no personal data fall into the wrong hands or are used for other purposes than those described in this data protection declaration.

Your rights in relation to Skyss

You have the right to be informed of Skyss’s processing of your personal data. This data protection declaration is therefore available at all times on our website.

Right of access

You may request information on how Skyss processes your personal data, including information on why Skyss processes your personal data, from where we have obtained your personal data, what categories of personal data Skyss processes, to whom Skyss discloses your personal data and how long Skyss stores your personal data.

All the information mentioned above is found in this data protection declaration. You may also request access to the personal data that Skyss processes about you.

Right to correct

You may request that incorrect or incomplete personal data be corrected or supplemented.

Right of erasure

You may request that Skyss erase your personal data if the terms for this are met, for instance if Skyss has processed your personal data in an unlawful way or for longer than necessary.

Right of limited processing

You may request that the processing of your personal data be limited if you contest the accuracy of the personal data, the legality or necessity of the processing or if you have objected to the processing and Skyss has accepted your objection.

The processing will be limited from the time the objection is submitted and during the period of time it takes Skyss to assess the objection. If the processing shall be limited, Skyss is only allowed to store the limited personal data, and any other processing can only happen with your consent. This applies unless Skyss is required to process personal data in connection with judicial matters, to protect the rights of others, or if the processing is of public interest.

Right to object

You may object to the processing of your personal data if you believe Skyss does not have the right to process your personal data. In such cases, Skyss may only continue processing the data if Skyss can substantiate a justifiable interest that carries more weight than your interests, rights or liberties. The personal data may in any case be processed if Skyss is legally obligated to do so or if processing is necessary in order to establish, assert or defend a legal claim.

Right to complain to the Norwegian Data Protection Authority

You can complain to the Norwegian Data Protection Authority if you are dissatisfied with Skyss’s reply or believe that Skyss is processing your personal data in breach of the applicable data protection regulations. Information on the complaint procedure is available here.

Contact information

If you have any questions relating to Skyss’s processing of your personal data or you would like to request access, correction, erasure or limited processing, please use the contact form here