General
Privacy Policy
DELAINE BUSES LTD
PRIVACY POLICY
Last updated: September 2026
Delaine Buses Ltd (“Delaine Buses”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal information.
This Privacy Policy explains how we collect, use, store and share personal information when you travel with us, purchase tickets or travel products, contact us, visit our website or otherwise interact with Delaine Buses.
For the purposes of UK data protection law, Delaine Buses Ltd is the data controller.
Delaine Buses Ltd
8 Spalding Road
Bourne
Lincolnshire
PE10 9LE
Email: office@delainebuses.com
Data Protection Lead: Mark Delaine-Smith
PERSONAL INFORMATION WE MAY COLLECT
Depending on how you interact with us, we may collect information including:
your name, address, telephone number and email address;
payment and transaction information;
ticket, pass and journey information;
concessionary travel information;
proof of age or identity where this is reasonably required;
information connected with Student Season Tickets, including the name of the cardholder and, where applicable, evidence relevant to eligibility for a sibling discount;
information provided where a passenger is unable to pay a fare or penalty fare;
information contained in enquiries, comments and complaints;
information provided by a parent, guardian or representative;
CCTV images and audio recordings;
information relating to accidents, incidents and injuries;
accessibility, health or safeguarding information where relevant;
information relating to insurance or legal claims;
information provided in connection with lost property;
information supplied by passengers, witnesses or other people involved in an incident or investigation; and
technical information relating to your use of our website, including IP addresses.
We seek to collect only information that is relevant and necessary for the purpose for which it is required.
HOW WE COLLECT PERSONAL INFORMATION
We may collect information directly from you when you:
travel on one of our services;
purchase or use a ticket, pass or travel product;
provide proof of age, identity or eligibility;
make a payment;
contact us by email, telephone, letter or in person;
submit an enquiry, complaint or request;
report an accident, injury or incident;
make a lost-property enquiry;
use our website; or
are recorded by CCTV systems on our vehicles or premises.
We may also receive information from other appropriate sources, including:
parents, guardians or representatives;
our employees and drivers;
passengers and witnesses;
local authorities;
concessionary travel authorities;
schools and colleges;
ticketing and payment providers;
insurers, insurance brokers and claims handlers;
solicitors;
the police;
DVSA; and
other regulatory or enforcement bodies.
HOW WE USE PERSONAL INFORMATION
We may use personal information to:
provide and operate our bus services;
issue, administer and verify tickets and travel products;
verify the validity and correct use of tickets and passes;
verify age or eligibility for discounted travel where appropriate;
administer Student Season Tickets;
administer concessionary travel;
process payments and deal with unpaid fares or penalty fares;
investigate suspected ticket or pass misuse or fraud;
respond to enquiries, comments and complaints;
identify and return lost property;
investigate accidents, incidents and injuries;
maintain passenger and employee safety;
protect our vehicles, premises and property;
investigate anti-social behaviour, vandalism or suspected criminal activity;
investigate suspected fraudulent claims;
respond to insurance claims;
establish, exercise or defend legal claims;
meet legal and regulatory requirements;
maintain appropriate operational and business records;
improve our services; and
maintain the security and operation of our website and systems.
OUR LAWFUL BASES FOR USING PERSONAL INFORMATION
We only process personal information where we have a lawful basis under data protection law.
Depending on the circumstances, this may include:
Contract – where processing is necessary to provide a ticket, travel product or other service requested from us.
Legal obligation – where we need to process information to comply with a legal or regulatory requirement.
Legitimate interests – where processing is necessary for our legitimate interests or those of another person and those interests are not overridden by your rights and freedoms.
Our legitimate interests may include:
operating a safe, secure and efficient bus service;
providing customer service;
verifying tickets, passes and travel entitlement;
preventing and investigating fraud or misuse;
investigating enquiries, complaints, accidents and incidents;
protecting passengers, employees, vehicles and property;
managing lost property;
maintaining appropriate operational records; and
establishing, exercising or defending legal claims.
Where appropriate and permitted by law, we may also rely on a recognised legitimate interest, including in certain circumstances involving crime prevention, safeguarding, emergencies or providing information to organisations carrying out public functions.
Vital interests – in limited circumstances where processing is necessary to protect somebody's life or physical safety.
Consent – where consent is the appropriate lawful basis. Where we rely on consent, it may be withdrawn at any time.
CCTV AND AUDIO RECORDING
All Delaine Buses vehicles are fitted with digital CCTV.
Audio recording is used in the cab area.
Appropriate signage is displayed on our vehicles to inform passengers and intending passengers that CCTV is in operation.
CCTV and audio recordings are used for purposes including:
passenger and employee safety and security;
reducing and investigating anti-social behaviour and vandalism;
investigating accidents and incidents;
investigating customer complaints;
clarifying the actions of our drivers and other circumstances surrounding events on our services;
protecting Delaine Buses and its employees from fraudulent claims;
preventing and investigating crime; and
supporting criminal and civil investigations.
Footage will generally only be retrieved where it is required for an investigation or other legitimate purpose.
Depending on the circumstances, footage may be viewed by or provided to organisations including:
the police and other enforcement agencies;
schools and colleges;
local authorities;
insurers;
insurance brokers and claims handlers;
solicitors; and
regulatory bodies.
Any disclosure will only be made where there is an appropriate and lawful reason.
We do not routinely provide CCTV images to members of the general public.
Where appropriate during an investigation, a person with a legitimate interest may be permitted to view relevant footage at our office, subject to data protection requirements and the rights of other individuals.
Images of individuals suspected or known to be involved in anti-social behaviour, vandalism or attempted fraud may, where appropriate and lawful, be used internally for identification by our employees.
Recordings that are not retrieved are automatically overwritten in the normal course of operation.
Where footage is retrieved in connection with an accident, complaint, investigation, insurance matter, criminal or civil investigation or legal claim, it may be retained for as long as reasonably necessary for that purpose.
Individuals may have the right to request access to CCTV footage containing their personal information. This right is subject to the rights of other individuals and any applicable legal exemptions.
TICKETS, PASSES AND PROOF OF ELIGIBILITY
Passengers may be required to present a valid ticket or pass for inspection.
Where a discounted fare is claimed, we may ask for reasonable proof of age or entitlement.
Where a ticket or pass is suspected of being altered, misused, fraudulently used or used by somebody other than the person entitled to use it, information may be collected and used to investigate the matter.
Student Season Tickets are issued for use by the named cardholder.
Where a sibling discount is requested, we may ask for reasonable evidence that the applicants meet the eligibility requirements.
PENALTY FARES AND UNPAID FARES
Where a passenger is required to pay a penalty fare but is unable to pay it when requested, we may collect their:
name;
address; and
evidence of identity.
This information may be used to correspond with the passenger, recover sums owed and, where necessary, establish, exercise or defend legal rights.
CONCESSIONARY TRAVEL
Where a passenger travels using an English National Concessionary Travel Scheme pass, we may process information associated with the pass and journey where necessary to:
verify that the pass is valid;
confirm entitlement to concessionary travel;
issue the appropriate travel record;
investigate suspected misuse; and
meet requirements connected with concessionary fare reimbursement.
CHILDREN AND YOUNG PEOPLE
Children and young people regularly use our bus services and we therefore process children's personal information where necessary.
This may include information relating to:
Child or Young Person fares;
Student Season Tickets;
school or college travel;
proof of age or eligibility;
enquiries and complaints;
CCTV recordings;
accidents and incidents;
safeguarding or welfare matters; and
suspected ticket or pass misuse.
We recognise that children's personal information requires particular protection and take their rights and interests into account when processing it.
Where appropriate, we may communicate with a parent, guardian or person with parental responsibility.
ACCIDENTS AND INJURIES
If an accident or injury occurs on one of our services, we may ask for information including:
your name and contact details;
the date, time and journey involved;
where you were travelling or sitting;
a description sufficient to assist us in identifying you on CCTV;
details of the incident; and
details of any injury sustained.
This information may be used to investigate the incident and may, where appropriate, be shared with insurers, claims handlers, solicitors, regulators, law enforcement agencies or other relevant organisations.
Information about an injury or medical condition may constitute special category personal information and will only be processed where the additional requirements of data protection law are satisfied.
LOST PROPERTY
Where you contact us about lost property, we may ask for information to help us identify the item and the relevant journey, including:
a description of the item;
the journey on which you travelled;
where and when you boarded;
where you were sitting; and
your contact details.
Where property is claimed directly from a driver in circumstances covered by the applicable lost-property regulations, the driver's record may include the claimant's name and address together with details of the property.
Bags, packages or other containers found on our vehicles may be opened where permitted for the purpose of identifying the owner or establishing how the item should be dealt with.
PAYMENTS
Card payments may be processed using third-party payment providers.
Where payment card information is provided directly to a payment processor, Delaine Buses does not ordinarily retain complete card details.
We do not sell personal or financial information.
WHO WE MAY SHARE PERSONAL INFORMATION WITH
Where necessary and lawful, we may share personal information with:
ticketing and payment providers;
IT, website and communications providers;
local authorities and concessionary travel authorities;
schools and colleges;
insurers, insurance brokers and claims handlers;
solicitors and other professional advisers;
the police and other law enforcement agencies;
DVSA and other regulators;
courts and tribunals;
emergency services;
auditors and accountants; and
other organisations providing services to us.
We may also disclose information where required or permitted by law.
Where another organisation processes personal information on our behalf, appropriate data protection arrangements will be used where required.
INTERNATIONAL TRANSFERS
Some organisations providing services to us may process personal information outside the United Kingdom.
Where this occurs and additional safeguards are required by data protection law, an appropriate lawful transfer mechanism or safeguard will be used.
HOW LONG WE KEEP PERSONAL INFORMATION
We retain personal information only for as long as reasonably necessary.
Different information will be retained for different periods depending on why it is held.
We may take account of:
legal and regulatory requirements;
accounting and insurance requirements;
applicable limitation periods;
whether an enquiry or complaint remains open;
whether information relates to an accident or incident;
whether an investigation remains ongoing; and
whether an insurance or legal claim is anticipated or ongoing.
CCTV footage not retrieved for an investigation is overwritten in the normal course of operation.
Information connected with an accident, complaint, investigation, insurance claim or legal matter may be retained for longer where necessary.
When information is no longer required, it will be securely deleted, destroyed or anonymised as appropriate.
WEBSITE INFORMATION
When you visit our website, technical information such as your IP address may be collected.
This may be used to operate and secure the website, diagnose technical problems, prevent fraud or misuse and understand how the website is used.
Where cookies or similar technologies are used, appropriate information and controls will be provided where required.
DATA SECURITY
We use appropriate technical and organisational measures designed to protect personal information against unauthorised access, accidental loss, inappropriate disclosure, alteration or destruction.
Access to personal information is restricted to people who require it for an appropriate purpose.
No electronic transmission or storage system can, however, be guaranteed to be completely secure.
YOUR DATA PROTECTION RIGHTS
Depending on the circumstances, you may have the right to:
request access to personal information we hold about you;
ask us to correct inaccurate or incomplete information;
ask us to erase personal information in certain circumstances;
ask us to restrict processing in certain circumstances;
object to certain processing, including processing based on legitimate interests;
receive or transfer certain information where the right to data portability applies; and
withdraw consent where we rely on consent.
These rights are not absolute and legal exemptions may apply.
We may need information to confirm your identity before dealing with a request.
Requests should be sent to office@delainebuses.com.
COMPLAINTS ABOUT PERSONAL INFORMATION
If you are concerned about the way we have collected or used your personal information, please contact us first so that we can investigate.
Delaine Buses Ltd
8 Spalding Road
Bourne
Lincolnshire
PE10 9LE
Email: office@delainebuses.com
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator.
Further information is available at www.ico.org.uk.
OTHER WEBSITES
Our website may contain links to websites operated by other organisations.
Delaine Buses is not responsible for the privacy practices of those organisations. We recommend reviewing their privacy information before providing personal information.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy where necessary to reflect changes to our services, systems, suppliers, legislation or data protection requirements.
The latest version will be published on our website.
Where a change would materially affect the way we use personal information, we will take appropriate steps to notify affected individuals where required.
CONTACT US
Questions, requests or concerns relating to this Privacy Policy or our use of personal information should be directed to:
Delaine Buses Ltd
8 Spalding Road
Bourne
Lincolnshire
PE10 9LE
Email: office@delainebuses.com
Data Protection Lead: Mark Delaine-Smith