18-25 Care Leaver Oyster photocard

Personal information we hold

• The personal information we hold about you includes:
• Title, name, address, email address, telephone number
• Date of birth
• Photograph
• Login credentials for your TfL photocard account
• Login credentials for your Oyster web account (where held)
• Your marketing and contact preferences
• Your journey history
• Transaction history
• Payment card details
• Enquiries, complaints or other correspondence from you

When you sign in to your online account, TfL will collect the IP address used by your device for the purpose of fraud prevention and detection.

Legal basis for using your information

Under privacy and data protection legislation, TfL is only allowed to use personal information if we have a proper reason or 'legal basis' to do so. In the case of the 18-25 Care Leavers Bus & Tram Discount scheme (18-25 CL Discount), there are a number of these 'legal grounds' we rely on, which are:

Our statutory and public functions

• To undertake activities to promote and encourage safe, integrated, efficient and economic transport facilities and services, and to deliver the Mayor's Transport Strategy

Where you have given your consent to TfL

• Where you have opted in to receive marketing messages from us; or
• You have asked the contact centre to resolve an issue or complaint for you

For the 'performance of a contract'

• In connection with the terms and conditions of the 18-25 CL Discount
• Where you have created a web account so we can provide additional services to you

Obtaining and using your information

Most of the personal information we hold is directly provided by you when you apply for your 18-25 CL Discount photocard.

As part of the application process, to confirm your identity and ensure that you are eligible, we verify some of that information using data received from your Responsible Borough, via an information sharing agreement with London Councils.

The information we verify is your name, your date of birth, and the name of your Responsible Borough.

Your Responsible Borough should have made you aware of this data sharing when discussing the 18-25 CL Discount with you before you made an application. This process replaces the need for you to provide or upload separate verification documents when you apply for the 18-25 CL Discount.

When you create a photocard account to apply for and manage your 18-25 CL Discount, from time to time we will send you certain messages by email. These messages are necessary in relation to your Discount and we are obliged to send these to you (you cannot opt out from these). These messages might include:

• Updates about your application
• Reminders if your card is close to expiry 
• Confirmation of updates you have made to your account (e.g. change of personal details)
• Important changes to the terms and conditions of the 18-25 CL Discount scheme

If you contact TfL Customer Services, we will need to collect information from you so that we can respond to your query or request. If you phone us, we may record your call and this allows us to train staff, review call quality and have access to a verbal record of what has been said in the event of a subsequent complaint. At the end of your contact with us, we may email you to take part in a customer satisfaction survey about your experience with Customer Services. This will help us to monitor our performance, improve quality and plan for future services.  

We sometimes also undertake analysis or research into the types of subjects that commonly cause customer concerns and complaints. For example, we might look for key words or themes and this helps us improve and plan our services for the future. Pseudonymisation, or other appropriate data minimisation techniques are applied so that we can analyse the subject matter without needing to know the identity of the person themselves. This is a way of protecting people's privacy in line with the Information Commissioner's Anonymisation Code of Practice.

When you travel, TfL's ticketing system records the location, date and time an Oyster card (including the 18-25 CL Discount) is used to make a journey on TfL's network, affiliated National Rail services or London River Services on which Oyster cards are accepted.

If you add your 18-25 CL Discount to an Oyster web account from time to time, we will send you travel related information by email. These messages might include:

• Important changes to the services you use
• New travel services
• Travel disruption
• Information about fares
• Consultations on TfL's plans for transport in London

We appreciate that you don't always want to be contacted in this way, so these emails will include a hyperlink so you can opt out from receiving future service messages at any time.

If you create an Oyster web account you can opt in to receive marketing from us. We will only send you messages about TfL's offers and promotions if you have chosen to receive them and you can change your marketing preferences at any time.

On occasion we may also send you details of surveys for you to participate in. Some of these surveys will be sent to you based on your use of TfL services (e.g. journey information, services used, frequency of use, etc). Such emails will also include a hyperlink so you can opt out of future surveys.

TfL will never pass your personal information to any other organisation for marketing purposes without your prior consent.

TfL will use aggregated or depersonalised Oyster journey information to carry out research and analysis, for example, to look at travel demand, provide customers with information on how busy stations are at particular times and to make improvements to our transport services. Individuals will not be identified using this information.

Length of time we keep information

TfL will retain personal information in line with its data retention policies. This means that we will not hold information for longer than is necessary for the purposes we obtained it for.

We usually retain data about the individual journeys for between eight and nine weeks after the card is used. The journey data in the ticketing system is then disassociated from your card during the ninth week (that is pseudonymised). This period is considered reasonable to enable customers to verify or make enquiries concerning their journeys (for example, for refund purposes). As a temporary measure to assist customers, following the cyber incident TfL experienced in September 2024, we will be extending the length of time we keep information about individual journeys made using an Oyster card beyond nine weeks, to support future customer refunds and access to journey history.  

Some journey information is also stored on the Oyster card itself; this comprises the last eight journeys and related charges, up to three season tickets (generally the most recent three tickets, including future dated), and the last two incomplete journeys, if any. If you don't use your card very often, the data stored on the card may be older than eight weeks. However, no other data is stored on the card itself (e.g. name or address).

The information we collect as part of the application process and records relating to the administration of your 18-25 CL Discount will be retained for three years after the expiry date of your photocard.

Call recordings made when you contact Customer Services are kept for 6 months.

Keeping personal information secure

We take the privacy of our customers very seriously and a range of robust policies, processes and technical measures are in place to control and safeguard access to, and use of, personal information associated with Oyster data. This includes payment card data which is securely handled by a specialist payment processing company in accordance with the Payment Card Industry Data Security Standard ('PCI DSS').

Anyone with access to personal information held in TfL's systems is required to complete TfL's privacy and data protection training on an annual basis.

We also publish guidance on the steps you can also take to protect your personal information.

Automated processing and profiling

Under data protection legislation we have to let you know when we use your personal information to do something 'automatically' using our computers or other systems, or make an automated decision (without human intervention) that significantly affects you.

When you enter your address as part of your application, we automatically verify your postcode is within a London borough and that your date of birth falls within the relevant age range for the Discount. This is used to determine whether you are eligible for the Discount and can proceed with your application.

Simple data matching rules are also used to check whether your data matches against the data provided by your Responsible Borough. If a positive match is made your 18-25- CL Discount will be issued. This uses a data table uploaded by London Councils into the application system.

We may use your journey history, travel patterns, or frequently used stations as the basis for sending service messages. For example, if you regularly use a specific bus route, we might use this information to help decide that messages about service alterations on that route would be helpful for you to know. 

Similarly, we may use postcode information to decide that it would be useful for you to know about changes to travel services near where you live, such as a station or bus stop closure or a road closure or diversions.

The purpose of this type of profiling is to make sure that we send only information to people who will actually find it relevant and useful. You are able to opt out from receiving these kinds of messages at any time.

We analyse application data, journey patterns and transaction history to inform measures to protect TfL against fare evasion and fraudulent transactions. We use this data in different ways, including identifying 'hotspots' so we can deploy Revenue Inspectors in certain London Underground stations or on particular bus routes.

We may also use the outcome of our analysis to contact you with advice to touch in and out at the correct stages of a journey.

We may also suspend or withdraw concessionary Oyster photocards based on their initial purchases, or subsequent top ups and disable web accounts based on online activities.

Part of our statutory responsibilities includes a duty to do all we reasonably can to reduce crime and disorder on and around the transport system, and we work together with our local authority, policing, and other law enforcement partners as part of this.

We may use aggregated or depersonalised Oyster journey data to undertake intelligence, analysis and research activities to identify and inform responses to a number of issues including:

• Reducing all crime and anti-social behaviour on and around the public transport network
• Creating crime and anti social behaviour strategies
• Targeting crime and disruption hotspots to better coordinate and deploy policing resources
• Reducing fear of crime and improving public confidence in the safety of the journeys they make in the capital

Sharing personal information

TfL uses an external service provider to process your application, issue your photocard and operate the photocard scheme on a day to day basis, including Customer Services support. TfL also uses external service providers to operate 'back office' technical services, secure payment processing and customer database management.

When you apply for your 18-25 CL Discount, we verify your name, date of birth and details of your Responsible Borough using data received from your Responsible Borough, via an information sharing agreement with London Councils, who share that data with us on behalf of all the London Local Authorities. 

After you have completed your application for the 18-25 CL Discount, we will confirm to your Responsible Borough whether your application has been successful and your Discount has been issued.

If we withdraw your 18-25 CL Discount due to misuse, we may share details of this with your Responsible Borough on a case by case basis.

If you add other travel products to the Oyster photocard issued for your 18-25 CL Discount (for example Pay As You Go credit) and use your Oyster photocard on National Rail services, TfL may share your personal data with the relevant train operating companies for the purposes of customer administration and fraud prevention and detection. The same applies if you use your Oyster photocard on river services operated by other companies.

If you appeal against a penalty fare notice issued on a National Rail service and you state that you used your Oyster photocard for that journey, the independent appeals body may verify the information you provide against journey data held in our ticketing systems. This is strictly for the purpose of assessing your appeal, and any information sharing is managed in accordance with relevant privacy and data protection legislation.

We have partnerships with a number of academic institutions in the UK and overseas (e.g. USA), who work with us to analyse journey patterns and undertake travel modelling to help us understand the way our customers travel so we can improve and plan our services for the future.

To do this we provide them with journey data derived from our Oyster ticketing systems that has been processed, replacing data, where required, with alternative identifiers (pseudonyms) so that it isn't possible to identify an individual customer.

All academic research is carried out in accordance with privacy and data protection legislation and protected by robust confidentiality agreements.

In some circumstances, disclosures of personal data to the police (and other law enforcement agencies) are permitted by data protection legislation, if they relate to the prevention or detection of crime and/or the apprehension or prosecution of offenders. Before any such disclosure takes place, the police are required to demonstrate that the personal data concerned will assist them in this respect. Each police request to TfL is dealt with on a strictly case-by-case basis to ensure that any such disclosure is lawful and in accordance with data protection legislation.

TfL may also receive or disclose personal information about customers in relation to certain emergency situations or other incidents that require an immediate response. Such events may include those involving public health, public safety or national security matters, when access to personal information is necessary to manage the incident. In some situations, we may also be required by law to disclose your personal data to the police or other enforcement, regulatory or Government body, upon a valid request to do so. These requests will be assessed on a case-by-case basis and take into account privacy considerations before a disclosure is made.

Overseas processing

TfL, its service providers and academic research partners currently process personal information relating to Oyster cards (including the 18-25 CL Discount) within the UK, the European Economic Area (EEA) and the USA. Any such processing is subject to appropriate contractual safeguards and carried out in accordance with the requirements of UK and EU privacy legislation.

Data Protection Impact Assessment

The 18-25 CL Discount is a new concessionary travel scheme launched by TfL in January 2024. To ensure that our approach to administering the scheme has properly considered all the privacy and data protection issues, we completed a Data Protection Impact Assessments (DPIA), which is published below.