Privacy Policy
Privacy Policy
Last updated: October 2026
GoBus ("we", "us", "our") is committed to protecting and respecting your privacy.
This policy explains how we collect and use personal data about you when you travel with us, pay for travel, use our websites or apps, or contact us. Please read it carefully to understand how we treat your personal data.
Who we are
For the purpose of data protection law, the data controller is:
Go-Coachhire Limited, trading as GoBus
Company number 06490924
Registered office: Bus Depot, London Road, Swanley, Kent BR8 8BY
ICO registration number: ZB163506
Data protection contact: Operations Director (data protection lead), [email protected]
What personal data do we collect?
Information provided by you.
You may give us information about you by filling in forms on our website www.gobus.uk or in the GoBus app, using the Go2 / CrossBus app, creating an account on the GoBus Passenger Portal, or corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our websites, apps or portal, subscribe to our services, purchase tickets, register to receive email updates, enter a competition, promotion or survey, and when you report a problem or make a complaint.
The information you give us may include, but is not limited to:
your name
email address
phone number
payment card information (handled by our payment providers, see "Contactless payments and Tap & Cap" below)
Information we collect about you.
Each time you visit our websites or use our apps, we may automatically collect the following information:
Geographical location, IP address or details regarding your use of your mobile device or computer (specifically when you launch and use the GoBus app or the Go2 / CrossBus app).
Technical information, including the Internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our sites (including date and time); products you viewed or searched for; 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 our customer service number.
We do not record phone calls.
When you pay for travel by tapping a contactless bank card, phone or watch on our buses, we also collect the payment and journey information described under "Contactless payments and Tap & Cap" below.
When you travel on our buses or visit our depot, your image may be recorded by our CCTV cameras, as described under "CCTV" below.
Information we receive from other sources.
We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers and search information providers) and may receive information about you from them.
Sensitive personal data.
We will not intentionally or systematically seek to collect, store or otherwise use information about you classed as "special category data" (for example, information relating to trade union membership, ethnic origin or health), except for the information about mobility needs held for Kent Karrier passengers, described under "Kent Karrier" below. CCTV footage may occasionally show information of this kind, or evidence of a crime; where it does, we use it only for the purposes described under "CCTV" below, such as passing evidence to the police.
Contactless payments and Tap & Cap
Since October 2026 you can pay for travel on GoBus services by tapping a contactless bank card, phone or watch on the ticket machine when you board. Our Tap & Cap fare capping works out the best fare for the journeys you make, so you are never charged more than the relevant fare cap. To do this we, through our ticketing partner Ticketer (Corvia Limited), process:
a masked version of your card number (the first 6 and last 4 digits), its expiry date and sequence number, the type of device used (card, phone or watch), a Payment Account Reference and payment tokens;
the times and bus stops at which you tapped, the fares calculated and the amounts charged to your card.
Your full card number is encrypted at the card reader and sent directly to our payment provider (Monet or Shift4). Neither GoBus nor Ticketer can see or store your full card number. You do not need an account to tap and benefit from fare capping; if you tap without an account, no name or contact details are linked to your journeys.
GoBus Passenger Portal
You can choose to create an account on the GoBus Passenger Portal, which is provided for us by Ticketer. The Portal lets you view your journey and payment history, see how fare caps have been applied, raise support queries and manage your cards. To create an account we collect your name, email address and password. Full details of how your data is used in the Portal are set out in the GoBus Passenger Portal Privacy Notice, which is available within the Portal.
Concessionary passes and Kent Travel Saver
When you travel using an English National Concessionary Travel Scheme bus pass or a Kent Travel Saver pass, our ticket machines record that a pass was used, with the date, time, route and stop. We send this journey data to Kent County Council so that we can be reimbursed for carrying pass holders. The data we send does not include your name, contact details or your full pass number. Your pass itself is issued and managed by Kent County Council, whose own privacy notice explains how it uses your details.
Kent Karrier
Kent Karrier is a Kent County Council door-to-door transport service for people who find it difficult to use regular buses, which we operate as part of our Go2 service. To use Kent Karrier you register in advance. As part of registration we hold your name, address and contact details, and information about your mobility needs (for example, whether you use a wheelchair or need help boarding), so that we can send a suitable vehicle and give you the help you need.
Information about your mobility needs is health information, which the law treats as special category data. We only use it to provide your Kent Karrier journeys, we only collect it with your explicit consent given when you register, and it can only be seen by staff and drivers who need it to arrange and carry out your journeys. You can withdraw your consent at any time, but we may then be unable to provide Kent Karrier journeys for you. We keep this information only while you are registered for Kent Karrier, and delete it when your registration ends, unless we need to keep it for an open complaint or claim.
CCTV
Our buses and our depot at Swanley are fitted with CCTV cameras. Signs on our buses and at the depot tell you that CCTV is in use. We use CCTV to:
protect the safety and security of our passengers, staff and members of the public;
prevent and detect crime and antisocial behaviour;
investigate accidents, incidents and complaints, and deal with insurance and legal claims; and
protect our vehicles, depot and property.
Cameras on our buses may record passengers on board and people and vehicles near the bus. Our legal basis for using CCTV is our legitimate interests in keeping people and property safe and in dealing with incidents and claims; where we share footage with the police, we may also rely on our legal obligations.
Recordings are kept securely and can only be viewed by a small number of authorised staff. Footage is automatically overwritten after 30 days, unless we need to keep it for longer to investigate an incident, complaint or claim, or because the police or another authority has asked for it. In that case we keep it only for as long as needed for that purpose.
We only share CCTV footage where necessary: with the police and other law enforcement bodies, with our insurers, legal advisers and claims handlers, and, where a contract requires it, with Kent County Council in relation to services we run for them.
You have the right to ask for a copy of CCTV footage of yourself. Please tell us the date, approximate time, route or location, and give a description of yourself so that we can find the footage. If other people can be identified in the footage, we may need to blur or edit them out before providing it.
Cookies
Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve it. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy at www.gobus.uk/cookie-policy. The GoBus Passenger Portal does not use tracking cookies.
How do we use your personal data and what is the legal basis for such processing?
Some of the personal data described above is needed to provide our services to you; if it is not provided, we may not be able to provide the information, products or services you have asked for. Where providing personal data is optional, we will tell you this when we collect it, and what the consequences of not providing it are.
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it. We will normally process your personal data only:
where we have your consent to do so;
where the processing is necessary to perform our contract with you;
where the processing is in our legitimate interests or those of a third party, and those interests are not overridden by your data protection interests or fundamental rights and freedoms; or
where we have a legal obligation to process your personal data.
Information provided by you. We use your personal data as follows:
Purchasing tickets, rides or passes in our apps: performance of a contract
In-app messages about your journey: performance of a contract
Marketing relating to GoBus, Go2 or CrossBus: consent
Contacting you about your enquiry or booking: performance of a contract
Providing your GoBus Passenger Portal account: performance of a contract
Contactless payments and Tap & Cap. We use your personal data as follows:
Charging your fares and calculating fare caps: performance of a contract
Showing your journey and payment history, and handling your queries, refunds and complaints: performance of a contract
Keeping the payment and ticketing systems secure and preventing fraud: our legitimate interests
Revenue reconciliation, financial audit and record keeping: legal obligation and our legitimate interests
Producing anonymous, aggregated patronage and revenue statistics (for example for Kent County Council or the Department for Transport): our legitimate interests. These statistics do not identify you.
Concessionary passes and Kent Karrier. We use your personal data as follows:
Recording pass journeys and claiming reimbursement from Kent County Council: performance of our contract with Kent County Council and our legitimate interests
Registering you for and providing Kent Karrier journeys: performance of a contract, and our contract with Kent County Council
Using information about your mobility needs to provide suitable Kent Karrier transport: your explicit consent
Information we collect about you. We use your personal data as follows:
Provision of services, customer service, and prevention of fraud and integrity of our systems: necessary for the purposes of our contract with you, and our legitimate interests
Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes), improving service functionality and efficiency, and developing new features, pricing, routing and dispatching (for example on Go2 and CrossBus): our legitimate interests
Optimising and personalising your experience of our apps: our legitimate interests
Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
If you have questions about the legal basis on which we collect and use your personal data, please contact us using the details under "Questions about this Privacy Policy" below.
Sharing your information
We may disclose your personal data to the following categories of recipient for the purposes described in this Privacy Policy:
Ticketer (Corvia Limited), our ticketing provider, which runs our ticket machines, Tap & Cap fare capping and the GoBus Passenger Portal on our behalf, and handles data protection requests relating to the Portal;
Monet and Shift4, payment service providers, which process contactless card payments;
Via, which provides the booking and dispatch system for our Go2 and CrossBus demand-responsive services, including the Go2 / CrossBus app;
Braintree, which processes card payments in the Go2 / CrossBus app;
Passenger (Masabi), which provides our website www.gobus.uk, including the GoBus app;
Stripe, which processes card payments for tickets bought on our website and in the GoBus app.
We also share information with Kent County Council where needed for the services we run with them: journey data for concessionary and Kent Travel Saver pass reimbursement (which does not identify you), and registration and booking details for Kent Karrier passengers.
These providers act on our behalf and may only use your personal data in line with our instructions. We do not sell your personal data.
We may share CCTV footage with the police and other law enforcement bodies, our insurers, legal advisers and claims handlers, as described under "CCTV" above.
We may also disclose your personal data to any competent law enforcement body, regulator, government agency or other third party where we believe disclosure is necessary:
as a matter of applicable law or regulation;
to exercise, establish or defend our legal rights; or
to protect your vital interests or those of any other person.
We will only release journey information to a third party (for example the police) where there is a proper legal basis to do so and we have verified the request.
We may also transfer your personal data to a buyer or potential buyer (and its agents and advisers) in connection with any reorganisation, restructuring, merger or sale, or other transfer of assets, provided that we inform any receiving party that it must use your personal data only for the purposes disclosed in this Privacy Policy.
Where we run a service under contract (for example for Kent County Council) and that service passes to another operator, we may pass relevant passenger data to the incoming operator where the contract requires it.
Finally, we may disclose your data to any other person to whom you ask us to disclose it, or if you consent to the disclosure.
Data retention
We will not keep your personal data for longer than is necessary to fulfil the purposes for which we collected it, unless the law permits or requires us to keep it for longer. The list below explains how long we keep different types of information.
Contactless payments and the GoBus Passenger Portal
Passenger Portal account and profile data: while your account is active, plus 12 months of inactivity. We will then email you, and delete your account 3 months later if we do not hear from you (15 months in total from your last activity).
Journey and travel history: up to 12 months. Once your Portal account is deleted, your travel history can no longer be linked back to you. The Portal itself shows the last 3 months.
Payment tokens and masked card details: 6 years, to meet financial audit requirements.
Technical and security logs: 6 months.
Support records: up to 24 months from when your query is closed.
Records of a security incident: 6 years.
Backups: up to 2 months.
Kent Karrier
Registration details and information about your mobility needs: while you are registered for Kent Karrier, and deleted when your registration ends, unless needed for an open complaint or claim. Journey and booking records are kept in line with the Go2 periods below.
CCTV
CCTV recordings from our buses and depot: automatically overwritten after 30 days, unless kept for longer to investigate an incident, complaint or claim, or at the request of the police or another authority.
Go2 / CrossBus app and other services
Passenger details given within the Go2 / CrossBus app (requested, completed and cancelled rides; current and lapsed passengers): 6 years, unless you ask us to remove your data.
Passenger account data: while you are registered with us, and then for 6 years after the end of the year in which you last bought travel from us. After this we anonymise the data and use only location data for statistical analysis and research.
Your acceptance of our terms and conditions: for as long as we process your personal data, and up to 6 years afterwards.
Passenger service enquiries: 3 years.
Statistical reports and marketing data: 6 years.
Register of complaints: reviewed after 10 years.
Correspondence and papers, including emails: reviewed after 6 years (or 10 years if they relate to a complaint or investigation).
Information security
We apply appropriate administrative, technical and organisational security measures to protect the personal data under our control from unauthorised access, collection, use, disclosure, copying, modification or disposal. Personal data is stored on secure servers. We train our employees on our data protection policies and procedures and allow only authorised employees to access personal data, on a need-to-know basis for their role, using individual accounts with multi-factor authentication where available. We also take steps to ensure that any service provider we engage to process personal data on our behalf takes appropriate technical and organisational measures to safeguard it.
Transferring information internationally
Some of our service providers process personal data outside the UK.
Ticketer hosts our contactless ticketing and the GoBus Passenger Portal on Microsoft Azure servers in Sweden, with reports stored in the Netherlands, and our contactless payment provider Monet is based in the Czech Republic. These countries are in the European Economic Area, which the UK recognises as providing an adequate level of data protection.
Some other service providers, such as those supporting our website, apps and online payments (for example Via, Braintree and Stripe), may process personal data in the United States. Where this happens and UK adequacy regulations do not apply, we put appropriate safeguards in place, such as the ICO's International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. Further details are available on request.
Children
Many young people travel with us, including on our school services. We do not knowingly use children's personal data for marketing. Journey and payment data relating to younger passengers is handled with the same care and safeguards as described in this policy, and we will not share it with anyone, including schools, without a proper legal basis. A parent or guardian may contact us about a child's personal data.
Automated decision-making
Tap & Cap works out your fares automatically, based on the journeys you make, so that you pay no more than the relevant fare cap. This only ever reduces what you pay. We do not make any decisions that have a legal or similarly significant effect on you based solely on automated processing. If you think a fare has been calculated wrongly, please contact us and a member of staff will review it.
Updates to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update it, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where this is required by data protection law.
You can see when this Privacy Policy was last updated by checking the "Last updated" date at the top of this policy.
Your data protection rights
Under data protection law you have the right to:
ask for access to the personal data we hold about you;
ask us to correct inaccurate or incomplete data;
ask us to delete your data, subject to any legal requirement to keep it;
ask us to restrict how we use your data in certain circumstances;
object to our processing of your data where we rely on legitimate interests, and at any time to direct marketing;
ask for your data in a portable, machine-readable format; and
withdraw your consent at any time, where we rely on consent. Withdrawing your consent will not affect the lawfulness of any processing we carried out before you withdrew it, nor processing we carry out on other lawful grounds.
To exercise any of these rights, please contact us at [email protected]. For requests about contactless payments or your GoBus Passenger Portal account, you can also contact Ticketer, which handles these requests on our behalf, at [email protected]. You can update your own name and email address in the Portal at any time.
We will respond to your request within one month, as required by data protection law. We may need to ask you to confirm your identity first.
Questions about this Privacy Policy
If you have any questions, concerns or complaints about this Privacy Policy or our handling of your personal data, please contact our data protection lead:
By email: [email protected]
By phone: 01732 469800
By post: Data Protection, Go-Coachhire Limited (GoBus), Bus Depot, London Road, Swanley, Kent BR8 8BY
If you are unhappy with how we have handled your personal data, you also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk or on 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
The controller of your personal data is Go-Coachhire Limited, trading as GoBus.
Last updated: October 2026
GoBus ("we", "us", "our") is committed to protecting and respecting your privacy.
This policy explains how we collect and use personal data about you when you travel with us, pay for travel, use our websites or apps, or contact us. Please read it carefully to understand how we treat your personal data.
Who we are
For the purpose of data protection law, the data controller is:
Go-Coachhire Limited, trading as GoBus
Company number 06490924
Registered office: Bus Depot, London Road, Swanley, Kent BR8 8BY
ICO registration number: ZB163506
Data protection contact: Operations Director (data protection lead), [email protected]
What personal data do we collect?
Information provided by you.
You may give us information about you by filling in forms on our website www.gobus.uk or in the GoBus app, using the Go2 / CrossBus app, creating an account on the GoBus Passenger Portal, or corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our websites, apps or portal, subscribe to our services, purchase tickets, register to receive email updates, enter a competition, promotion or survey, and when you report a problem or make a complaint.
The information you give us may include, but is not limited to:
your name
email address
phone number
payment card information (handled by our payment providers, see "Contactless payments and Tap & Cap" below)
Information we collect about you.
Each time you visit our websites or use our apps, we may automatically collect the following information:
Geographical location, IP address or details regarding your use of your mobile device or computer (specifically when you launch and use the GoBus app or the Go2 / CrossBus app).
Technical information, including the Internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our sites (including date and time); products you viewed or searched for; 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 our customer service number.
We do not record phone calls.
When you pay for travel by tapping a contactless bank card, phone or watch on our buses, we also collect the payment and journey information described under "Contactless payments and Tap & Cap" below.
When you travel on our buses or visit our depot, your image may be recorded by our CCTV cameras, as described under "CCTV" below.
Information we receive from other sources.
We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers and search information providers) and may receive information about you from them.
Sensitive personal data.
We will not intentionally or systematically seek to collect, store or otherwise use information about you classed as "special category data" (for example, information relating to trade union membership, ethnic origin or health), except for the information about mobility needs held for Kent Karrier passengers, described under "Kent Karrier" below. CCTV footage may occasionally show information of this kind, or evidence of a crime; where it does, we use it only for the purposes described under "CCTV" below, such as passing evidence to the police.
Contactless payments and Tap & Cap
Since October 2026 you can pay for travel on GoBus services by tapping a contactless bank card, phone or watch on the ticket machine when you board. Our Tap & Cap fare capping works out the best fare for the journeys you make, so you are never charged more than the relevant fare cap. To do this we, through our ticketing partner Ticketer (Corvia Limited), process:
a masked version of your card number (the first 6 and last 4 digits), its expiry date and sequence number, the type of device used (card, phone or watch), a Payment Account Reference and payment tokens;
the times and bus stops at which you tapped, the fares calculated and the amounts charged to your card.
Your full card number is encrypted at the card reader and sent directly to our payment provider (Monet or Shift4). Neither GoBus nor Ticketer can see or store your full card number. You do not need an account to tap and benefit from fare capping; if you tap without an account, no name or contact details are linked to your journeys.
GoBus Passenger Portal
You can choose to create an account on the GoBus Passenger Portal, which is provided for us by Ticketer. The Portal lets you view your journey and payment history, see how fare caps have been applied, raise support queries and manage your cards. To create an account we collect your name, email address and password. Full details of how your data is used in the Portal are set out in the GoBus Passenger Portal Privacy Notice, which is available within the Portal.
Concessionary passes and Kent Travel Saver
When you travel using an English National Concessionary Travel Scheme bus pass or a Kent Travel Saver pass, our ticket machines record that a pass was used, with the date, time, route and stop. We send this journey data to Kent County Council so that we can be reimbursed for carrying pass holders. The data we send does not include your name, contact details or your full pass number. Your pass itself is issued and managed by Kent County Council, whose own privacy notice explains how it uses your details.
Kent Karrier
Kent Karrier is a Kent County Council door-to-door transport service for people who find it difficult to use regular buses, which we operate as part of our Go2 service. To use Kent Karrier you register in advance. As part of registration we hold your name, address and contact details, and information about your mobility needs (for example, whether you use a wheelchair or need help boarding), so that we can send a suitable vehicle and give you the help you need.
Information about your mobility needs is health information, which the law treats as special category data. We only use it to provide your Kent Karrier journeys, we only collect it with your explicit consent given when you register, and it can only be seen by staff and drivers who need it to arrange and carry out your journeys. You can withdraw your consent at any time, but we may then be unable to provide Kent Karrier journeys for you. We keep this information only while you are registered for Kent Karrier, and delete it when your registration ends, unless we need to keep it for an open complaint or claim.
CCTV
Our buses and our depot at Swanley are fitted with CCTV cameras. Signs on our buses and at the depot tell you that CCTV is in use. We use CCTV to:
protect the safety and security of our passengers, staff and members of the public;
prevent and detect crime and antisocial behaviour;
investigate accidents, incidents and complaints, and deal with insurance and legal claims; and
protect our vehicles, depot and property.
Cameras on our buses may record passengers on board and people and vehicles near the bus. Our legal basis for using CCTV is our legitimate interests in keeping people and property safe and in dealing with incidents and claims; where we share footage with the police, we may also rely on our legal obligations.
Recordings are kept securely and can only be viewed by a small number of authorised staff. Footage is automatically overwritten after 30 days, unless we need to keep it for longer to investigate an incident, complaint or claim, or because the police or another authority has asked for it. In that case we keep it only for as long as needed for that purpose.
We only share CCTV footage where necessary: with the police and other law enforcement bodies, with our insurers, legal advisers and claims handlers, and, where a contract requires it, with Kent County Council in relation to services we run for them.
You have the right to ask for a copy of CCTV footage of yourself. Please tell us the date, approximate time, route or location, and give a description of yourself so that we can find the footage. If other people can be identified in the footage, we may need to blur or edit them out before providing it.
Cookies
Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve it. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy at www.gobus.uk/cookie-policy. The GoBus Passenger Portal does not use tracking cookies.
How do we use your personal data and what is the legal basis for such processing?
Some of the personal data described above is needed to provide our services to you; if it is not provided, we may not be able to provide the information, products or services you have asked for. Where providing personal data is optional, we will tell you this when we collect it, and what the consequences of not providing it are.
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it. We will normally process your personal data only:
where we have your consent to do so;
where the processing is necessary to perform our contract with you;
where the processing is in our legitimate interests or those of a third party, and those interests are not overridden by your data protection interests or fundamental rights and freedoms; or
where we have a legal obligation to process your personal data.
Information provided by you. We use your personal data as follows:
Purchasing tickets, rides or passes in our apps: performance of a contract
In-app messages about your journey: performance of a contract
Marketing relating to GoBus, Go2 or CrossBus: consent
Contacting you about your enquiry or booking: performance of a contract
Providing your GoBus Passenger Portal account: performance of a contract
Contactless payments and Tap & Cap. We use your personal data as follows:
Charging your fares and calculating fare caps: performance of a contract
Showing your journey and payment history, and handling your queries, refunds and complaints: performance of a contract
Keeping the payment and ticketing systems secure and preventing fraud: our legitimate interests
Revenue reconciliation, financial audit and record keeping: legal obligation and our legitimate interests
Producing anonymous, aggregated patronage and revenue statistics (for example for Kent County Council or the Department for Transport): our legitimate interests. These statistics do not identify you.
Concessionary passes and Kent Karrier. We use your personal data as follows:
Recording pass journeys and claiming reimbursement from Kent County Council: performance of our contract with Kent County Council and our legitimate interests
Registering you for and providing Kent Karrier journeys: performance of a contract, and our contract with Kent County Council
Using information about your mobility needs to provide suitable Kent Karrier transport: your explicit consent
Information we collect about you. We use your personal data as follows:
Provision of services, customer service, and prevention of fraud and integrity of our systems: necessary for the purposes of our contract with you, and our legitimate interests
Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes), improving service functionality and efficiency, and developing new features, pricing, routing and dispatching (for example on Go2 and CrossBus): our legitimate interests
Optimising and personalising your experience of our apps: our legitimate interests
Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
If you have questions about the legal basis on which we collect and use your personal data, please contact us using the details under "Questions about this Privacy Policy" below.
Sharing your information
We may disclose your personal data to the following categories of recipient for the purposes described in this Privacy Policy:
Ticketer (Corvia Limited), our ticketing provider, which runs our ticket machines, Tap & Cap fare capping and the GoBus Passenger Portal on our behalf, and handles data protection requests relating to the Portal;
Monet and Shift4, payment service providers, which process contactless card payments;
Via, which provides the booking and dispatch system for our Go2 and CrossBus demand-responsive services, including the Go2 / CrossBus app;
Braintree, which processes card payments in the Go2 / CrossBus app;
Passenger (Masabi), which provides our website www.gobus.uk, including the GoBus app;
Stripe, which processes card payments for tickets bought on our website and in the GoBus app.
We also share information with Kent County Council where needed for the services we run with them: journey data for concessionary and Kent Travel Saver pass reimbursement (which does not identify you), and registration and booking details for Kent Karrier passengers.
These providers act on our behalf and may only use your personal data in line with our instructions. We do not sell your personal data.
We may share CCTV footage with the police and other law enforcement bodies, our insurers, legal advisers and claims handlers, as described under "CCTV" above.
We may also disclose your personal data to any competent law enforcement body, regulator, government agency or other third party where we believe disclosure is necessary:
as a matter of applicable law or regulation;
to exercise, establish or defend our legal rights; or
to protect your vital interests or those of any other person.
We will only release journey information to a third party (for example the police) where there is a proper legal basis to do so and we have verified the request.
We may also transfer your personal data to a buyer or potential buyer (and its agents and advisers) in connection with any reorganisation, restructuring, merger or sale, or other transfer of assets, provided that we inform any receiving party that it must use your personal data only for the purposes disclosed in this Privacy Policy.
Where we run a service under contract (for example for Kent County Council) and that service passes to another operator, we may pass relevant passenger data to the incoming operator where the contract requires it.
Finally, we may disclose your data to any other person to whom you ask us to disclose it, or if you consent to the disclosure.
Data retention
We will not keep your personal data for longer than is necessary to fulfil the purposes for which we collected it, unless the law permits or requires us to keep it for longer. The list below explains how long we keep different types of information.
Contactless payments and the GoBus Passenger Portal
Passenger Portal account and profile data: while your account is active, plus 12 months of inactivity. We will then email you, and delete your account 3 months later if we do not hear from you (15 months in total from your last activity).
Journey and travel history: up to 12 months. Once your Portal account is deleted, your travel history can no longer be linked back to you. The Portal itself shows the last 3 months.
Payment tokens and masked card details: 6 years, to meet financial audit requirements.
Technical and security logs: 6 months.
Support records: up to 24 months from when your query is closed.
Records of a security incident: 6 years.
Backups: up to 2 months.
Kent Karrier
Registration details and information about your mobility needs: while you are registered for Kent Karrier, and deleted when your registration ends, unless needed for an open complaint or claim. Journey and booking records are kept in line with the Go2 periods below.
CCTV
CCTV recordings from our buses and depot: automatically overwritten after 30 days, unless kept for longer to investigate an incident, complaint or claim, or at the request of the police or another authority.
Go2 / CrossBus app and other services
Passenger details given within the Go2 / CrossBus app (requested, completed and cancelled rides; current and lapsed passengers): 6 years, unless you ask us to remove your data.
Passenger account data: while you are registered with us, and then for 6 years after the end of the year in which you last bought travel from us. After this we anonymise the data and use only location data for statistical analysis and research.
Your acceptance of our terms and conditions: for as long as we process your personal data, and up to 6 years afterwards.
Passenger service enquiries: 3 years.
Statistical reports and marketing data: 6 years.
Register of complaints: reviewed after 10 years.
Correspondence and papers, including emails: reviewed after 6 years (or 10 years if they relate to a complaint or investigation).
Information security
We apply appropriate administrative, technical and organisational security measures to protect the personal data under our control from unauthorised access, collection, use, disclosure, copying, modification or disposal. Personal data is stored on secure servers. We train our employees on our data protection policies and procedures and allow only authorised employees to access personal data, on a need-to-know basis for their role, using individual accounts with multi-factor authentication where available. We also take steps to ensure that any service provider we engage to process personal data on our behalf takes appropriate technical and organisational measures to safeguard it.
Transferring information internationally
Some of our service providers process personal data outside the UK.
Ticketer hosts our contactless ticketing and the GoBus Passenger Portal on Microsoft Azure servers in Sweden, with reports stored in the Netherlands, and our contactless payment provider Monet is based in the Czech Republic. These countries are in the European Economic Area, which the UK recognises as providing an adequate level of data protection.
Some other service providers, such as those supporting our website, apps and online payments (for example Via, Braintree and Stripe), may process personal data in the United States. Where this happens and UK adequacy regulations do not apply, we put appropriate safeguards in place, such as the ICO's International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. Further details are available on request.
Children
Many young people travel with us, including on our school services. We do not knowingly use children's personal data for marketing. Journey and payment data relating to younger passengers is handled with the same care and safeguards as described in this policy, and we will not share it with anyone, including schools, without a proper legal basis. A parent or guardian may contact us about a child's personal data.
Automated decision-making
Tap & Cap works out your fares automatically, based on the journeys you make, so that you pay no more than the relevant fare cap. This only ever reduces what you pay. We do not make any decisions that have a legal or similarly significant effect on you based solely on automated processing. If you think a fare has been calculated wrongly, please contact us and a member of staff will review it.
Updates to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update it, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where this is required by data protection law.
You can see when this Privacy Policy was last updated by checking the "Last updated" date at the top of this policy.
Your data protection rights
Under data protection law you have the right to:
ask for access to the personal data we hold about you;
ask us to correct inaccurate or incomplete data;
ask us to delete your data, subject to any legal requirement to keep it;
ask us to restrict how we use your data in certain circumstances;
object to our processing of your data where we rely on legitimate interests, and at any time to direct marketing;
ask for your data in a portable, machine-readable format; and
withdraw your consent at any time, where we rely on consent. Withdrawing your consent will not affect the lawfulness of any processing we carried out before you withdrew it, nor processing we carry out on other lawful grounds.
To exercise any of these rights, please contact us at [email protected]. For requests about contactless payments or your GoBus Passenger Portal account, you can also contact Ticketer, which handles these requests on our behalf, at [email protected]. You can update your own name and email address in the Portal at any time.
We will respond to your request within one month, as required by data protection law. We may need to ask you to confirm your identity first.
Questions about this Privacy Policy
If you have any questions, concerns or complaints about this Privacy Policy or our handling of your personal data, please contact our data protection lead:
By email: [email protected]
By phone: 01732 469800
By post: Data Protection, Go-Coachhire Limited (GoBus), Bus Depot, London Road, Swanley, Kent BR8 8BY
If you are unhappy with how we have handled your personal data, you also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk or on 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
The controller of your personal data is Go-Coachhire Limited, trading as GoBus.