The Fleet Operator Recognition Scheme (“FORS”) is operated by AECOM Limited (Company Number 01846493) (“AECOM”) on behalf of Transport for London (TfL).
In the regular course of operating FORS, FORS acquires personal data by interaction and communication with various third parties (including individuals). AECOM takes seriously its obligations to protect such personal data. As evidence of its commitment to privacy, AECOM has established this Privacy Statement to articulate the privacy and data protection principles that guide AECOM in the operation of FORS.
This Privacy Statement (together with the FORS Terms and Conditions, any additional data protection policy we may issue from time to time and any other related documents we provide to you) are designed to accomplish the following specific objectives:
- Increase awareness of regulatory, legal, and corporate requirements for handling and protecting personal data
- Set forth minimum guidelines for the collection, use, sharing, protection and other processing of personal data
- Enable FORS to meet business, legal, and regulatory responsibilities relating to personal data.
For the purpose of the General Data Protection Regulation (GDPR) (EU) 2016/679 (the “Regulation”) TfL is the Data Controller and AECOM is the Data Processor of the personal data provided to us about you.
This Privacy Statement does not create legal rights for third parties and is not a contract.
Collection of Personal Data
FORS will directly collect personal data of individuals who:
- Browse the FORS website
- Request FORS accounts on the FORS website
- Contact us (including through social media)
- Register their organisations for FORS membership
- Are the nominated contact for FORS audits
- Are customers of FORS professional training
- Are customers of other services FORS provides either directly or through the FORS Affinity Partners
The personal data you give us/that we will process may include:
- Your name and job title
- Contact details including your postal address, email address, phone number
- Payment details including your financial/bank and credit card information
- Driving details, including your driver licence number
- Training records
By visiting the FORS website we will automatically collect the following information:
- Technical information, including the Internet protocol address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, information through platforms you use; and
- Information about your visit to the FORS website, including the full Uniform Resource Locators, clickstream to, through and from the FORS website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the FORS Helpline.
We work closely with third parties to whom we may provide and receive information about you. These third parties include:
- FORS Affinity Partners (whom you register with or purchases services from)
- Training providers delivering FORS approved training
- Training providers appointed to deliver FORS Professional Training
- Technical, payment and delivery services including PayPal, MailChimp, EventBrite and Gotowebinar
- Analytics and search information providers
- Telematics companies and system providers
- FORS Champions and specifiers
- The Chartered Institute of Logistics and Transport
- Fleet Source Limited
We will not collect personal data from persons under the age of 16.
Purposes of Processing Personal Data
We will use the information you give to us or that we collect about you to:
- Carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us
- Ensure we comply with our reporting and legal requirements
- Provide you with information about other goods and services we offer that are similar
to those that you have already purchased or enquired about
- Notify you about changes to our service
- Ensure that content from the FORS website is presented in the most effective manner for you and for your computer
- Administer the FORS website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- Improve the FORS website to ensure that content is presented in the most effective manner for you and for your computer
- Allow you to participate in interactive features of our service, when you choose to do so
- Measure or understand the effectiveness of advertising we serve to you and others, and
to deliver relevant advertising to you
- Make suggestions and recommendations to you and other users of the FORS website about
goods or services that may interest you or them
Legal Basis for Processing of Personal Data
We process your personal data because:
- It is necessary to do so to perform the services we are to provide to you
- We have your express consent
FORS obtains consent from or provides other choices to individuals regarding the processing of their personal data when required by applicable law. FORS also appropriately communicates any choices available to individuals with respect to FORS’s sharing of their personal data with third parties or access to their personal data by third parties.
Specifically, when consent or choice is required or otherwise determined to be appropriate, FORS:
- Requests the consent of the individual using a type of consent (opt-out or opt-in, implicit or explicit) or other choice mechanism that is appropriate in light of applicable requirements
- As appropriate, informs individuals of the consequences for failing to consent or to provide their information
- As appropriate, informs individuals regarding how they can change their consent decisions or choices
- Processes an individual’s personal data in a manner that is consistent with consent or other choices exercised by the individual
Disclosure of Personal Data
FORS may share personal data with third parties as required for reasonable business purposes (in accordance with applicable legal requirements) including:
- FORS Community Partnership
- FORS publication partners and mailing houses
- FORS workshop, conference, training course, webinar and other event sponsors
- FORS certification bodies
- FORS Champions
- FORS Affinity Partners
- Environment Agency
- The police (on a case by case basis for prevention and detection of crime)
- Suppliers/sub-contractors for the performance of any contract we enter into with you or them (including third parties who deliver e-mails to you on our behalf)
- Advertisers and advertising networks that require the data to select and serve relevant
adverts to you and others or those who run events
- Analytics and search engine providers that assist us in the improvement and optimisation
of the FORS website
- Credit reference agencies for the purpose of assessing your credit score where this is a
condition of us entering into a contract with you.
FORS will display the training record of individuals on the FORS website.
Duration of Retention of Personal Data
We will not hold your personal data for longer than we consider necessary for reasonable business purposes or as authorised by an individual.
FORS will hold personal data for the duration of membership and for six months from the date at which an organisation is made dormant within FORS. Dormant means that a company (or other body) is no longer an active member of FORS. For dormant members membership data will be retained but anonymised.
FORS will hold training data for the duration of the course’s validity and for six months thereafter, following which the training record will be retained but anonymised.
FORS will remove user accounts after fourteen months of inactivity.
FORS data removed/anonymised either due to expiry or user request will be present in system backups for a further 3 months before it is completely irrecoverable.
You have the right to ask us to stop using your personal data in relation to marketing at any time by contacting us in accordance with our contact details below.
The Regulation gives you the right to access information held about you. Where required by applicable law or otherwise appropriate, FORS provides individuals with appropriate access to the personal data about them that is maintained by FORS and the ability to correct the data, as applicable. Further to this, FORS will:
- Respond to requests for access to personal data made through appropriate channels in a timely manner.
- Authenticate individuals requesting access before allowing access to or providing personal data.
- If applicable, provide a reason to the individual for denying access, with a point of contact for further inquiry.
Your right of access can be exercised in accordance with the Regulation by email request to firstname.lastname@example.org
In some situations you will have the right to ask us not to process your information for any purpose. Where relevant you can exercise this right at any time by contacting email@example.com
We take appropriate technical and organisational security measures to prevent unauthorised access and to ensure that the personal data we hold as Data Processor is kept secure.
All information you provide to us is stored on our secure servers, or those of our sub-contractors, within the European Economic Area (“EEA”).
Any electronic payment transactions will be encrypted, and conducted by our third party payment providers in accordance with their terms.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the FORS website, you are responsible for keeping this password confidential.
The FORS website may, from time to time, contain links to and from the websites of our partner networks, advertisers and Affinity Partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
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Changes to this Privacy Statement
Any changes we make to this Privacy Statement in the future will be posted on this page and, where appropriate, notified to you by email or through the FORS eNews.
Complaints, Questions and Comments
If you have a complaint about the way in which we collect, process and store your personal data which you do not feel can be resolved by contacting us, you have the right to complain to the Information Commissioners Office.