Luas Privacy Statement
Transdev Dublin Light Rail Limited (“Transdev”) operates this website on behalf of Transport Infrastructure Ireland (“TII”) and in connection with its operation of the Luas. Both Transdev and TII fully respect your right to privacy, and will not collect any personal data (within the meaning of the Data Protection Acts 1988 and 2003 (the “Data Protection Acts”)) about you on this website without your clear permission. Any personal data which you volunteer to Transdev and/or TII in connection with this website will be treated with the highest standards of security and confidentiality, strictly in accordance with the Data Protection Acts.
Collection And Use Of Personal Information
TII and Transdev do not collect any personal data about you on this website, apart from information which you volunteer, for example by contacting us or subscribing to the TII contact database in order to receive updates and/or to enter competitions.
Information that you provide in connection with any queries, comments or complaints you make through this website, or any information you provide in connection with the purchase of tickets including car parking tickets, and payment or refund of fares, will be processed by Transdev as a “data controller” within the meaning of the Data Protection Acts. Transdev will only use the personal data provided in line with the purpose for which it is provided, including the following purposes:
- in order to reply to queries or comments you make; and
- the provision of TII and Luas information and information relating thereto.
Transdev may disclose such information to TII, in order to enable TII to monitor Transdev’s provision of the services to you. In such circumstances, TII shall use such information for its own monitoring purposes and shall be regarded as the data controller in respect of such information.
In addition, where you provide your personal information for the purposes of subscribing to TII’s contacts database, TII shall be regarded as the “data controller” in respect of such information, and shall use such information to provide you with email updates, and (depending on the preferences you express when subscribing) send you marketing communications or promotional offers by email from TII and trusted third parties.
All marketing materials from trusted third parties will be approved by TII and disseminated by TII or its third party service providers. At no time will personal information provided by you be disclosed to any other third parties for their own marketing purposes. You personal information may be anonymised and used for statistical purposes.
You may choose to unsubscribe from receiving marketing communications from TII at any time by emailing email@example.com.
Your Rights Regarding Data Supplied Via This Website
You have a right to be given a copy of your personal data (for which we may charge you a small fee) which you may have supplied via this website. To exercise this right, you must make a request in writing to:
Transdev at Luas Customer Care, Luas Depot, Red Cow, Clondalkin, FREEPOST, Dublin 22 or e-mail firstname.lastname@example.org.
You should include any personal identifiers which you supplied earlier via the website (e.g. Name; address; phone number; e-mail). Your request will be dealt with within forty days.
You also have a right to have inaccurate information corrected. If you discover that either Transdev or TII holds inaccurate information about you, you have a right to instruct Transdev and/or TII (as appropriate) to correct that information. Such an instruction must be in writing or via e-mail to the relevant address specified above. Your request will be dealt with within forty days.
Complaints About Data Processed Via The Website
If you are concerned about how personal data is processed via this website, please do not hesitate to bring such concerns to the attention of Transdev at the contact details above.
Collection And Use Of Technical Information
Technical details in connection with visits to this website are logged by our internet service provider for our statistical purposes. No information is collected that could be used by us to identify website visitors. The technical details logged are confined to the following items:
- the IP address of the visitor’s web server;
- the top-level domain name used (for example .ie, .com, .org, .net);
- the previous website address from which the visitor reached us, including any search terms used;
- click-stream data which shows the traffic of visitors around this web site (for example pages accessed and documents downloaded);
- type of web browser used by the website visitor.
Transdev will make no attempt to identify individual visitors, or to associate the technical details listed above with any individual. It is the policy of Transdev never to disclose such technical information in respect of individual website visitors to any third party (apart from our internet service provider, which records such data on our behalf and which is bound by confidentiality provisions in this regard), unless obliged to disclose such information by a rule of law. The technical information will be used only by TII or Transdev, and only for statistical and other administrative purposes. You should note that technical details, which we cannot associate with any identifiable individual, do not constitute "personal data" for the purposes of the Data Protection Acts.
Glossary Of Technical Terms Used
Web Browser - The piece of software you use to read web pages. Examples are Microsoft Internet Explorer, Netscape Navigator and Opera.
IP Address - The identifying details for your computer (or your internet company’s computer), expressed in "internet protocol" code (for example 192.168.72.34). Every computer connected to the web has a unique IP address, although the address may not be the same every time a connection is made.
Cookies - Small pieces of information, stored in simple text files, placed on your computer by a web site. Cookies can be read by the web site on your subsequent visits. The information stored in a cookie may relate to your browsing habits on the web page, or a unique identification number so that the web site can "remember" you on your return visit. Generally speaking, cookies do not contain personal information from which you can be identified, unless you have furnished such information to the web site.
Social Media Privacy Statement
This statement relates to the privacy practices of Transdev and TII in connection with Luas social media accounts (e.g. Facebook, Twitter). It sets out the basis on which any personal data that we collect from you, or that you supply to us, in connection with Luas social media accounts will be processed by us, in accordance with Irish data protection legislation. Transdev and TII are not responsible for the content or privacy practices of the social media service providers.
Transdev and TII fully respect your right to privacy, and will not collect any personal information about you without your clear knowledge and permission. Any personal information which you volunteer to us will be treated strictly in accordance with the Data Protection Acts 1988 and 2003.
Collection and use of personal information
We will not collect any personally identifying information about you when you visit Luas social media accounts unless you choose to provide that information to us. The information we collect depends on what you do when visiting Luas social media accounts. For example, if you comment on a post with a complaint or a query we may record the content of your comment on our systems, or if you provide us with personal information such as contact details via a direct message we may record those details.
Disclosure of Information
We may disclose personal data processed by us in connection with Luas social media accounts to third parties when permitted or required by law.
Right of Access
You have the right, subject to certain exemptions, to obtain a copy of any personal data (for which we may charge you a small fee) we hold about you and to correct any inaccuracies in such data. If you wish to avail of any of these rights, please contact us at: email@example.com. Your request will be dealt with as soon as possible and in any event, within 40 days.
Privacy Statement Changes
We may change this Privacy Statement from time to time, and in our sole discretion. We encourage visitors to frequently check this page for any changes to this Privacy Statement. Your continued use of Luas social media accounts after any change in this Privacy Statement will constitute your acceptance of such change.
LUAS TEXT SERVICE
TERMS and FREQUENTLY ASKED QUESTIONS
Use of the Luas Text Service indicates the user’s acceptance of
the Terms and FAQs set out below.
What is the Luas Text Service?
The Luas Text SMS Service (the “Luas Text Service”) is a service which allows customers to discreetly report incidents of anti-social behaviour on board a Luas tram or at a Luas stop.
When should I use the Luas Text Service?
Use the Luas Text Service when you see incidents of anti-social behaviour on board a Luas tram or at a Luas stop that you believe should be reported to improve the overall customer experience.
For safety-related incidents or tram emergencies, always call 999.
How do I use the Luas Text Service?
Text the keyword “LUAS”, along with your report of anti-social behaviour, to 51444.
It’s nt that you use the keyword “LUAS”, as the text number 51444 is a Shared Text Service (see below) – using “LUAS” means that the text is directed to us.
What are examples of an emergency (when I should call 999)?
For safety-related incidents or tram emergencies, always call 999. Examples of emergencies include (but are not limited to) when:
- Someone’s life is at risk;
- A crime is happening now;
- Someone is injured or threatened;
- You need an ambulance urgently;
- There is a fire.
What are some examples of the type of situations that may be reported using the Luas Text Service?
Anti-social behaviour should be reported using the Luas Text Service. Anti-social behaviour occurs when a person acts in a way that causes or may cause another person harassment, significant or persistent alarm, distress, fear or intimidation, or impairs their use or enjoyment of their property, or of Luas services or of Luas property in a significant or persistent way.
Anti-social behaviour that may be reported using the Luas Text Service includes (but is not limited to) public intoxication, disorderly conduct, vandalism, or abusive or insulting behaviour. Example texts that customers might send via the Luas Text Service to report anti-social behaviour are:
- “There are people on the tram blaring loud music and drinking alcohol.”
- “Someone on the tram is swinging on the overhead bar.”
- “People are yelling loudly and being disruptive – it is making me uncomfortable.”
Are there other ways to communicate a safety-related incident at Luas stops or while travelling on the Luas?
Yes. Safety-related incidents may be communicated to Luas by:-
- Pressing the button at the Emergency Help Point (“EHP”) located at every Luas Stop beside the ticket machine to speak with Luas Control.
- Pressing the button beside the tram door to speak to the Luas tram driver.
- Pulling the emergency handle located beside the tram door to bring the Luas tram to a stop. Please note that passengers abusing this service may be subject to a fine of €2,000.
- Was the Luas Text Service introduced to address increased security risks?
No. The Luas Text Service is designed to improve overall customer satisfaction. This will be achieved by responding, when possible, to incidents of anti-social behaviour in real time.
When I use the Luas Text Service, where does my message go / who sees the text?
When you text LUAS to 51444, your text message is received (firstly) by our service provider, Neon Communications, and is passed to or is accessible by designated Luas Staff for investigation. (This is always subject to any system or network issues or time delays.)
- What happens when my text message is received?
- On receipt of your text message, an automated message will be sent to you by Neon Communications to advise you that your text must relate to anti-social behaviour and if your text relates to a safety incident and/or an emergency, you should call the Gardaí on 999.
- If your text is reporting anti-social behaviour, Luas Staff will review the report and will follow Luas protocols to follow-up (including with you if necessary) about the incident.
- How will I know that my text message has been received and responded to?
You will know that your message is received because on receipt of your text message, an automated message will be sent to you to advise you that if your text relates to a safety incident and/or an emergency, you should call the Gardaí on 999.
You do not need to wait on the Luas tram or at a stop to ensure that Luas has responded to the concern raised. All messages related to anti-social behaviour will be responded to in accordance with Luas protocols.
- Can I use the Luas Text Service for purposes other than to report anti-social behaviour (e.g., customer care queries, complaints about Luas Staff, queries regarding lost property, etc.)?
No. Only text messages that relate to anti-social behaviour will be reviewed by Luas Staff.
Customer queries, comments, questions, and complaints may be communicated to Luas Customer Care by any of the following methods:
- Email: firstname.lastname@example.org,
- Phone: Available Monday to Friday between 7am – 7pm and Saturday 10am – 2pm on Lo Call 1850 300 604 or 01 4614911. Closed Sunday and Bank Holidays.
- Twitter: @Luas
- Post: Luas Customer Care, Luas Depot, Red Cow, Clondalkin, Dublin 22, D22 C5P3
- Will the Luas Text Service be used for Luas service disruptions?
No. The Luas Text Service is a reporting system. Information regarding a service disruption will be available from Passenger Information Displays at stops, via on-board tram announcements, via @Luas on Twitter, at Luas.ie, on AA Roadwatch, and/or on media broadcasts
- What hours does the Luas Text Service operate?
The Luas Text Service operates during Luas operational hours.
- Is there a cost to use the Luas Text Service?
Yes. The customer texting Luas must pay for the cost of their text.
The message rate depends on the user's mobile operator and particular price plan to which they are signed up. For information on the standard message rate that applies, contact your mobile operator.
A standard text is 155 Characters.
- Why is the Luas Text Service not free?
The Luas Text Service is not free because Luas was advised that a free text service may have resulted in more hoax / non-genuine texts being received. The aim of the Text Service is to improve the customer experience while not disrupting the Luas service to deal with prank texts.
- Will the Luas driver or Luas Staff identify that it was me on the tram / platform who texted?
Your personal details obtained from the text will not be disclosed to Luas Staff (apart from those who designated to operate the Service) or to third parties. The aim of the text Service is to invite customers to text discreetly, to report an incident of anti-social behaviour.
However, Luas also monitors anti-social behaviour on the Luas and at Luas stops using CCTV. We may check the CCTV footage in relation to any incident reported to us via the Luas Text Service, and this footage may include footage of you, and it may identify you.
- Can the Gardaí access my message and number?
Depending on the nature of the incident, Luas may be required to pass your information to the Gardaí, particularly if the Gardaí are investigating criminal activity on the Luas or at Luas stops and you are a witness to the commission of a crime.
- What types of behaviours are prohibited on the Luas?
All passengers are expected to comply with the Light Railway (Regulation of Travel and Use) Bye-Laws 2015. The Bye-Laws prohibit:
- (a) Acting in a manner that is abusive, threatening or offensive to any person;
- (b) Acting in a manner that is a nuisance or a danger to any person;
- (c) Using any threatening, obscene or offensive language or make any threatening, obscene or offensive gestures;
- (d) Discarding any litter or rubbish other than in a container provided for that purpose;
- (e) Writing on, scratching, burning, painting on, drawing on, or making in any way a light rail vehicle or light railway or affixing anything to a light rail vehicle or light railway;
- (f) Damaging or attempting to damage any part of a light rail vehicle or light railway or the property of any person thereon;
- (g) Causing undue soil to a light rail vehicle or light railway, or the property or any person thereon;
- (h) Throwing anything or spitting in, at or from a light rail vehicle or light railway;
- (i) Being intoxicated (within the meaning of section 4 of the Public Order Act 1994 (No 2 of 1994)) or be in possession of any open bottle or container of intoxicating liquor or a controlled drug (within the meaning of section 2 of the Misuse of Drugs Act 1977 (No 12 of 1977));
- (j) Being in possession of any gun, knife, explosive device, or other weapon or other dangerous item.
- (k) Smoking any cigarette, cigar or pipe, or be in possession of any lighted material or use any nicotine inhalation device or electronic cigarette;
- (l) Using any skateboard, roller blades, roller skate, or similar articles;
- (m) Leaving baggage, goods or property unattended;
- (n) Opening the door of a light rail vehicle, or board or alight from a light rail vehicle, other than at a place designated by an operator as a place where passengers can board and alight from a light rail vehicle and when the light rail vehicle is stationary;
- (o) Boarding or alighting from or attempting to board or alight from a light rail vehicle when a warning tone indicating that the doors of the light rail vehicle are about to close is sounding;
- (p) Boarding or alighting from or attempting to board or alight from a light rail vehicle when it might be unsafe to do so, including when the light rail vehicle is fully occupied;
- (q) Boarding or attempting to bard a light rail vehicle with a bicycle unless it is folded and fully encased;
- (r) Entering or attempting to enter any part of a light rail vehicle or light railway that is not designated for the use of passengers;
- (s) Queueing in a disorderly way;
- (t) Distracting or attempting to distract the driver of a light rail vehicle without reasonable and sufficient cause;
- (u) Placing any object on a light rail vehicle or light railway in a manner that is or may become a danger to life or health, the operation and maintenance of a light rail vehicle or light railway, or would otherwise interfere with the proper operation of a light rail vehicle or light railway.
In addition, the Bye-Laws prohibit the following unless a person has been given permission by or on behalf of an operator: -
- (a) Distributing or displaying any leaflet, poster, advertisement, free newspaper or other document;
- (b) Soliciting, touting or plying for alms, reward, custom or employment;
- (c) Selling or offering for sale any goods or services;
- (d) Singing or performing with or without musical instruments or other equipment;
- (e) Using any radio or television or any form of equipment for replaying recorded sound or images so as to interfere with any other person;
- (f) Carrying on any form of gambling;
- (g) Being in possession of any animal (other than a guide dog or a Peata therapy dog);
- (h) Loitering or remaining on a light railway without reasonable and sufficient cause;
- (i) Conducting or taking part in any public meeting or demonstration.
- Will the Luas service be stopped if someone reports anti-social behaviour via the Luas Text Service?
We do not envisage stopping the service as a result of reported anti-social behaviour. However, in the event of an emergency or safety related incident, the Luas will follow normal protocols and a service or services may be disrupted.
- What personal information will be kept about me if I use the Luas Text Service?
Your mobile phone number and the text you send will be collected and processed by both Transdev (as operator of the Luas Light Rail Service in Dublin) and by our data processor, Neon Communications. When a text message is received via the Luas Text Service, Transdev may also check the CCTV footage on the tram and/or at the tram stop for the time of the reported incident, and this footage may include footage of you and may identify you (as well as customers at Luas stops and/or travelling on the Luas at the time of the reported incident, and the person(s) alleged to be responsible for the reported anti-social or other behaviour).
For all text messages received, and unless we are otherwise required to retain the personal data for legal purposes (for example to allow the Gardaí to investigate criminal offences and to contact you as a witness to a crime or as evidence for our insurers or as part of a civil legal claim by us) we will delete the text message and your number at the end of the month following the month in which the text was sent. Otherwise, we will retain the number and text message until advised by the Gardaí, or our insurers or our legal advisers that we are no longer required to hold the data.
- Why is my personal information being collected and processed when I use the Luas Text Service?
- What is the legal basis for processing my personal information when I use the Luas Text Service?
Please note that at all times, personal data will be processed lawfully, fairly and in a transparent manner in accordance with all applicable data protection legislation.
- Will anyone other than
Transdev receive my personal information if I use the Luas Text Service?
Our text service provider, Neon Communication Solutions Limited, will receive your data to assist us in operating the Luas Text Service.
Depending on the nature of the incident, Luas may be required to pass your information to the Gardaí, particularly if the Gardaí are investigating criminal activity on the Luas (or at Luas stops) and you are a witness to the commission of a crime. In addition, we may need to pass your information to our insurers or legal advisers as part of any claim in relation to the reported incident.
- What can I do if I have
questions regarding the collection and processing of my personal information?
- What if I don’t want my
personal information to be processed, or if I want my personal information
You have the right to information about, and (separately) to access, your personal data and in certain circumstances to correct or erase your personal data, “to be forgotten”, to object to the processing (including profiling), rights against automated decision-making and rights to data portability. Please contact us in writing if you wish to exercise any of these rights, preferably please by email at email@example.com.
- Will Luas use my personal
information for sales or marketing purposes?
Luas may share customer information across Luas-owned business entities and companies working on our behalf. However, the information you provide as part of the Luas Text Service will not be used for the purposes of marketing to you.
As identified in these Terms and FAQs, Luas contracts with third-party service providers to assist with the Luas Text Service. Our service providers are required to keep confidential the information received on behalf of Luas and may not use it for any purpose other than to carry out the services they are performing for Luas. These service providers may change or we may contract with additional service providers to better accommodate our customers.
- What if the Service does not work for any reason?
Luas, on its own behalf and the behalf of any contractor, subcontractor, agent or partner of Luas, does not accept any responsibility for any technical failure or malfunction or any other problem in any network, system, server, provider, or otherwise which may result in any text sent via the Service being lost or not properly sent/received or responded to. Customers and other users of the Service hereby waive any claim whatsoever against Luas for any liability, loss, costs, damages and expenses arising from any such problems or arising as a result of or in connection with using the Service.
- What is the Luas Text Service usage policy?
Our usage policy for the Luas Text Service is set out below.
The Luas Text Service should be used only to report genuine incidents of anti-social behaviour on board a Luas tram or at a Luas stop.
Luas reserves the right to apply a message block to some and/or all messages sent to Luas from mobile phone numbers which send messages deemed by Luas to be threatening, abusive or offensive in nature. In instances where a block is applied, text messages will continue to be charged for by network operators, but these messages will no longer reach Luas for review.
As part of this process, Luas will send a text message to the mobile phone number from which the threatening, abusive or offensive message(s) originate, requesting that the sender cease and desist from sending messages of this nature in future and informing them that, if not, a message block will be applied which will result in some/all of their messages no longer reaching Luas for review and outlining that, irrespective of this, network operators will continue to charge for these messages.
Should messages of a threatening, abusive or offensive nature continue to be received from the mobile phone number in question, Luas will send one further text message to the offending number confirming that a message block has now been applied.
Luas’ decision in relation to message blocks and the duration of such blocks is final and no correspondence will be entered into.
Where it deems appropriate, Luas also reserves the right to pass sender and message data to the appropriate authorities for investigation and follow-up action.
- What is a Shared Text Message?
We use the number 51444 as our text number. This number is provided to us for use by Neon Communications. Other services use the 51444 number, meaning that it is a shared number. However, by using the keyword “LUAS” in your text, this designates your text as belonging to the Luas Text Service, and it means that your text is directed to us (and specifically to the designated Neon Communications and Luas Staff teams who will review and act on it).