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Data Protection Notice

eFlow you first
Introduction
a) About eFlow

eFlow is the operator of the barrier-free tolling system on Dublin’s M50 motorway and a provider of electronic tags for use on all toll roads in the Republic of Ireland. eFlow is a registered business name of Transport Infrastructure Ireland (“TII”). Turas Mobility Services is currently contracted by the TII to operate the M50 tolling system (eFlow) on their behalf. Turas Mobility Services is an Irish company based in Dublin.

b) About TII

eFlow is the operator of the barrier-free tolling system on Dublin’s M50 motorway and a provider of electronic tags for use on all toll roads in the Republic of Ireland. eFlow is a registered business name of Transport Infrastructure Ireland (“TII”). Turas Mobility Services is currently contracted by the TII to operate the M50 tolling system (eFlow) on their behalf. Turas Mobility Services is an Irish company based in Dublin.

Purpose of Notice
The purpose of this notice is to inform you of the personal data relating to you that eFlow may collect and process in order to provide toll road services and the uses (including disclosures to third parties) we may make of such personal data. eFlow fully respects your right to privacy and is committed to protecting your personal data. Any personal data that is processed in relation to the eFlow business is processed in accordance with the applicable data protection laws.
Contacting eFlow

We can be contacted as follows:

By post: Data Protection Officer, Block 8, Harcourt Centre, Charlotte Way, Dublin, D02 K580
 
Personal Data Processed by eFlow

The processing of personal data is required in order to provide toll road services to eFlow customers. We may collect and process some or all of the following personal data in relation to you:

Registered accounts – your full name, postal address, email address, contact telephone number, licence plate number, journey reference number, tag provider, tag number and credit card, debit card or direct debit details. We also process eFlow passage information, payment history, your correspondence and telephone conversation recordings.

Unregistered account – your full name, postal address and licence plate number. We also process eFlow passage information, payment history, your correspondence and telephone conversation recordings.

When you contact eFlow by phone, email or through the website services, we record details of those communications (e.g. correspondence records, web message, letter/fax correspondence, phone call recordings including logs of phone calls, etc.) and any other details you may choose to provide us with. For the purpose of processing payments, eFlow may collect credit card or debit card details from road users.

Sources of Personal Data

As well as collecting information from you directly, eFlow may receive or collect information about you and your vehicle from the following sources:

  • The National Vehicle Driver File, in accordance with specific legislative authority;
  • Foreign Vehicle Licensing Authorities, in the countries in which the vehicle is registered;
  • The Vehicle Rental Company, to enable eFlow contact you and request the payments for your passage;
  • Compatible Operators in connection with the provision of interoperable toll transactions in Ireland;
  • Toll passage photographic and video recordings for all vehicles that use the M50 toll road; and
  • Cameras/CCTV at M50 toll infrastructure.
Purpose of Processing and Legal Basis

eFlow processes personal data in order to:

  • ensure that payment is obtained from all road users using eFlow services in accordance with TII’s statutory obligations;
  • receive services from third party service providers;
  • respond to queries and complaints; and
  • comply with TII’s other statutory obligations.

TII as data controller is required to ensure that there is a legal basis for the processing of your personal data. TII’s legal basis for collecting and using this information is that such processing is necessary to comply with TII’s legal and regulatory obligations and to carry out its tasks in the public interest and/or in the exercise of official authority vested in TII, including the right to demand, charge, collect and recover toll payments and all other amounts due as consequence of the use of the toll road. In certain limited circumstances, processing your personal data may be on the basis of your consent – where this is the case you will be asked to give a positive indication of that consent.

The legal basis on which we collect, process and transfer special categories of data relating to you (e.g. if you claim exemption from the payment of tolls on the grounds of modified vehicle/driver disability status, proof that the vehicle is modified and information about your disability status may be requested) in the manner described above are that:

  • this is necessary for reasons of substantial public interest, and
  • you have given your explicit consent to such processing.
Transfers Abroad

In connection with the above, eFlow may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that eFlow does so, eFlow will ensure that appropriate measures are in place to comply with its obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission and/or other transfer obligations/arrangements as may be specified by the Commission. Further details of the measures that eFlow has taken in this regard are available from the eFlow Data Protection Officer, using the contact details indicated above.

Recipients of Data

We may disclose your personal data to other organisations in connection with the above purposes, in the following circumstances:

We may share personal data with our agents, contractors and service providers who assist us with the operation of aspects of our services and functions, such as our payment card processor, banking and printing/postal correspondence contractors, eFlow enforcement entity, Foreign Vehicle Licensing Authorities, and law enforcement agencies.

Where we appoint a new operator of eFlow, we may share personal data with this new operator inorder to facilitate successful transition to the new operator and ensure continuity of service foreFlow customers during any transition period.

If you send us a comment, complaint or query in relation to a matter that we are not responsible for, we will ask for your permission to pass on your communication to the relevant third party.

Where we are under a duty to disclose or share personal data in order to comply with any legal obligation, or to protect the rights, property or safety of eFlow, our customers, or others. We may also share information about the way you conduct your account with credit reference agencies.

Where required or permitted by law, we may share your personal data with other public authorities and bodies, such as the Gardaí or other law enforcement authorities for the purposes of the prevention, investigation or detection of crime.

In connection with the provision of interoperable toll transactions in Ireland, we may disclose your personal data to a relevant compatible operator.

We may share toll passage data with key stakeholders, e.g. the Department of Transport, for the purposes of research and statistical analysis.• For the purpose of operating competitions on behalf of TII we may disclose, with your consent, your name, email address and marketing preferences provided to us by you.

Where we are otherwise permitted by law.

Retention

We will only retain your personal data for as long as necessary for the purpose or purposes for which it was obtained, including for the purposes of satisfying any legal, accounting, or reporting requirements. The retention periods differ depending on the type of categories of personal data held.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security of Your Information
The personal data which we process is held on secure servers hosted by Turas Mobility Services. eFlow has adopted appropriate technical and organisational security measures to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction or damage. We will also ensure that our agents or third-party service providers who process your data are required to keep your data safe and secure.
Your Rights

You have the following rights, in certain circumstances, in relation to your personal data:

  • the right to access your personal data;
  • the right to request the rectification and/or erasure of your personal data;
  • the right to restrict the use of your personal data;
  • the right to object to the processing of your personal data;
  • the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transit that data to another data controller, and
  • where our processing of your personal data is based on you having provided consent, the right to withdraw your consent to the processing at any time.

In order to exercise any of the rights set out above, please contact the eFlow Data Protection Officer, using the contract details indicated above.

Questions and Complaints

If you have any questions or complaints about our use of your personal data, please contact us using the contact details above. Alternatively, TII’s Data Protection Officer may be contacted as follows:

by post
Data Protection Officer
Transport Infrastructure Ireland,
Parkgate Business Centre,
Parkgate Street,
Dublin 8, D08 DK10
 
 
by email

Further information about data protection can be found on the Data Protection Commission’s website: www.dataprotection.ie

You also have the right to lodge a complaint with the Data Protection Commission if you are not happy with the way we have used your information or addressed your rights.

Details of how to lodge a complaint can be found on the Data Protection Commission’s website.