GDPR policy for customers in the metro

When your personal information is processed in connection with your use of the metro, Metroselskabet I/S and Metro Service A/S are responsible for the processing. In the following, you can read about how your personal information is processed and by whom.

Metroselskabet owns the metro and Metro Service handles the operations, customer service and issuance and collection of fare evasion tickets as contractor for Metroselskabet. Therefore, Metroselskabet is the responsible data controller for the processing of personal data when you use the metro, while Metro Service functions primarily as Metroselskabet’s data processor. In certain, specific cases, Metro Service acts as data controller, for instance when it comes to video surveillance and information about accidents. Read more about these special cases in the separate section below.

In this policy, you can read more about the processing of your personal information and your rights in accordance with current legislation.

Responsibility and security

Metroselskabet and Metro Service aim to protect your personal information, so you can feel at ease about our processing of the information while we handle your case. It is important to us that your personal information is treated securely and confidentially. We have procedures for the collection, safe keeping, deletion, update, and transmission of personal data, so we can always live up to current legislation.  

Questions must be directed to Metro Customer Service

If you have questions about our processing of your personal information in relation to the metro, please contact Metro Customer Service, regardless of the specifics of your inquiry. To ensure that all inquiries are registered and handled correctly, you cannot send us an e-mail but are requested to use the inquiry form which can be found here at dinoffentligetransport.dk.

This link will guide you to a list of different subjects to choose from, depending on the content of your inquiry. Choose the subject that is relevant for your case and send in your inquiry. The input from you goes directly to Metro Customer Service, who will reply to your inquiry as quickly as possible.

 

Metroselskabet I/S – Data controller

Metroselskabet owns the metro and is responsible for the data processing mentioned in the following part of the policy document. Practical information about Metroselskabet:

Metroselskabet I/S, Metrovej 5, 2300 København S
CVR-number.: 30823699
For more information about Metroselskabet, please see persondatapolitik.

 

 

 

 

Metroselskabet processes your personal information in the following contexts

When you use the metro, your personal information is registered for various reasons. In the following, you can see the specific purposes for processing your personal information, as well as the legislative grounds for the processing and how long data is kept etc. The processing mentioned in this section, is all handled by Metro Service on behalf of Metroselskabet, and questions must therefore be directed to Metro Service through Metro Customer Service.

Fare evasion tickets

When you receive a fare evasion ticket, the issuing steward creates it on his or her handheld device. To create the fare evasion ticket, your name, address, Social Security Number (CPR) and sometimes telephone number is registered. The steward will use your supplied details to find you in the central CPR register, to ensure that the fare evasion ticket is issued to the right person. In connection with the issuance of the fare evasion ticket, a photo will be taken of any travel documents and personal ID (driver’s license, sundhedskort (the yellow national health service medical card) or the like for use in case handling. The photos lend extra security in making sure that the correct information is registered when issuing the fare evasion ticket, and it is helpful in cases where personal identity and CPR-numbers are misused by a third person.

Purpose:
We process personal information to issue fare evasion tickets for travel without a ticket or with an invalid ticket, and to manage cases about fare evasion tickets.

Basis for processing:
Our legal basis for data processing is:
- the Railways Act § 14
- GDPR article 6.1.e
- the Data Protection Act § 11 section 1 (CPR-number)
- the Accounting Act §10.

Recipients:
We may share your personal data with:
- The Danish Debt Collection Agency if the fare evasion ticket is not paid.
- the Police, if identity theft or misuse is suspected.
- The Appeal Board for Bus, Train, and Metro as well as Rejsekort and DOT, if you appeal the case.

Data retention:
If a case is ongoing, case handling is unfinished or the fare evasion ticket is unpaid, data will not be deleted.
The CPR-number and photos of tickets and ID are deleted 3 years after the case has been closed, or no later than the statute of limitations, as there is a time limit of 3 years in which to bring a case before the Appeal Board. Data pertaining to payment is kept for 5 years + running year in accordance with the Accounting Act

Travel guarantee

If the Metro is delayed for more than 30 minutes, we cover your expenses for alternative transportation. To get reimbursement for your travel expenses, you must either fill in a form on DOT’s website or fill in a physical form and send it to us by mail, so we can handle the case and transfer the money to you. Required information on the form is your name, address, e-mail, travel information, bank account details and/or your CPR-number for transfer via NemKonto.

Purpose:
We process your personal data to enable the management of your travel guarantee case.

Basis for processing:
Our legal basis for data processing is:
- the Railways Act and Danish Transport Companies Act summarized in the Joint National Travel Regulations.
- GDPR article 6.1.e
- the Data Protection Act § 11 section 1 (CPR-number)
- the Accounting Act §10.

Recipients:
We may share your personal data with:
- The Appeal Board for Bus, Train, and Metro as well as Rejsekort and DOT, if you appeal the case.  

- Other public transport operators like DSB, Movia or Arriva, and Rejsekort and DOT.

Data retention:
If a case is ongoing data will not be deleted. The statute of limitations is 3 years, as there is a time limit of 3 years in which to bring a case before the Appeal Board. Data pertaining to reimbursement is kept for 5 years + running year in accordance with the Accounting.

Lost property

Items found on the metro are brought to the Metro Service head office, where we attempt to identify and contact the owner. If this is not possible, the lost item is kept for 10 days before being handed over to the police. Depending on the type of item, it may contain personal data of various kinds. When we are contacted by customers looking for lost items, the customer’s name, address, e-mail, and telephone number is registered.

Purpose:
To make sure that lost items are either handed back to the owners or handed over the police.

Basis for processing:
Our legal basis for data processing is:
- GDPR article 6.1.e

Recipients:
We may share your personal data with:
- the police
- The Appeal Board for Bus, Train, and Metro as well as Rejsekort and DOT, if you make a complaint and subsequent appeal.

Data retention:
The statute of limitations is 3 years, as there is a time limit of 3 years in which to bring a case before the Appeal Board.   

Customer surveys

If you have been in contact with Metro Customer Service, you will be asked to answer a survey either over the phone or in writing. When you call us, you are asked to decide whether you wish to contribute and if you accept, you will be called by the survey-service after your call with Customer Service has ended. If you have filled in a form on DOT’s website, you will receive an e-mail containing a link to a written survey. For the purpose of the survey your name, telephone number/e-mail will be registered along with your responses.

Purpose:
To examine the customer’s satisfaction with Customer Service and to serve as statistical basis for further improvement of the service level.

Basis for processing:
Our legal basis for data processing is:
- GDPR article 6.1.e

Recipients:
We may share your personal data with:
- No information is shared

Data retention:
All survey responses are anonymized after 6 months. Subsequent identification of the respondent is not possible.

General inquiries to Metro Customer Service

By filling in the form on DOT’s website, it is possible to send general inquiries to Metro Customer Service. Name, address, e-mail, telephone number and content of the inquiry is recorded.

Purpose:
We treat your personal data to be able to manage your inquiry.

Basis for processing:
Our legal basis for data processing is:
- GDPR article 6.1.e

Recipients:
We may share your personal data with:
- The Appeal Board for Bus, Train, and Metro as well as Rejsekort and DOT, if you make a complaint and subsequent appeal.

- Other public transport operators like DSB, Movia or Arriva, and Rejsekort and DOT.

Data retention:
Simple inquiries are kept for 6 months. If the case evolves or changes subject, the statute of limitations is 3 years, as there is a time limit of 3 years in which to bring a case before the Appeal Board.

Inquiries concerning GDPR

Inquiries regarding the right of access, the right to erasure, the right to rectification etc. must be directed at Metro Service. When you make an inquiry regarding the exertion of your rights, we handle your name, address, e-mail, possibly phone number as well as the content of the inquiry. In some cases, we may also handle further documentation to determine your identity, for instance copies of driver’s license, ’sundhedskort’ (the yellow national health service medical card) or the like.

Purpose:
We process your data in compliance with the GDPR articles 15 through 22.

Basis for processing:
Our legal basis for data processing is:
- GDPR article 6.1.e

- GDPR articles 15 through 22
- The Data Protection Act §11 section 1

Recipients:
We may share your personal data with:
- Other public transport operators like DSB, Movia or Arriva, and Rejsekort and DOT.

- The Danish Data Protection Agency

Data retention:
Case data is kept for 3 years after the latest dialogue, to enable us to document legal compliance and to defend ourselves against legal claims.  

Metro Service A/S – Data controller

In some cases, Metro Service processes your personal data in connection with use of the metro for its own purposes, making Metro Service the data controller for the processes described in this section.

Practical information about Metro Service:

Metro Service A/S, Metrovej 3, 2300 København S
CVR-number.: 21263834
Telephone: +45 7015 1615
www: https://metroservice.dk

Questions must be directed to Metro Customer Service

If you have questions about our processing of your personal information in relation to the metro, please contact Metro Customer Service, regardless of the specifics of your inquiry. To ensure that all inquiries are registered and handled correctly, you cannot send us an e-mail but are requested to use the inquiry form which can be found here at dinoffentligetransport.dk.

This link will guide you to a list of different subjects to choose from, depending on the content of your inquiry. Choose the subject that is relevant for your case and send in your inquiry. The input from you goes directly to Metro Customer Service, who will reply to your inquiry as quickly as possible.

If you have general questions about the processing of your personal data and GDPR, you can contact Metro Customer Service’s Data Protection Officer (DPO). The Data Protection Officer cannot manage your case, but can answer questions pertaining to legal issues regarding your rights etc. Questions directed at the Data Protection Officer will be handled confidentially. You may contact the DPO via e-mail on dpo@metroservice.dk or by regular mail addressed to the above address and marked “DPO”. Please note, that if you send an e-mail, it should not contain confidential or sensitive information, as we cannot guarantee that the connection is encrypted.

Metro Service processes your personal data for the following purposes

When you travel on the metro, personal information is registered for different purposes. In the following, you will find descriptions of the specific purposes where personal data is processed, and on which legal basis, for how long it is kept etc. The processing purposes mentioned below are all processes in which Metro Service acts as independent data controller.

Video surveillance

For railway safety and crime prevention purposes, there are video surveillance cameras mounted in trains and on stations. Recordings from these cameras are not viewed unless the police ask for specific footage or if it is necessary to support internal operations regarding railway safety or rulings on insurance cases.  

Purpose:
To live up to our obligations regarding railway safety and to prevent criminal activities.

Basis for processing:
We are subject to an array of legal demands to carry out safety measures in the metro and on the stations. Data is processed in accordance with GDPR article 6.1.c, as the processing of personal data is necessary to meet the demands of our safety obligations.

Recipients:
We may share your personal data with:
- The police
- Insurance companies
- Other authorities, for instance the Accident Investigation Board Denmark.

Data retention:
Video surveillance recordings are kept for 14 to 30 days, after which they are automatically deleted. In certain instances, and only in connection with specific cases, the footage may be kept for longer.

Specifics regarding the right of access:

According to GDPR chapter III, a registered person’s rights may be limited with reference to GDPR article 12.5 and article 23.1, litra c. and d. Therefore, you do not by default have the right of access to video surveillance recordings, as public safety considerations, crime prevention, police investigations, crime exposure and legal prosecution of punishable offences or criminal sanctions, including protection against and prevention of threats to public safety, take precedence over individual rights.

Guided tours or permits for commercial activities

If you wish to go on a guided tour of the metro control and maintenance centers or if you wish to use the metro’s areas for commercial purposes, you must make a formal request.

Purpose:
To monitor who takes part in guided tours and commercial activities.

Basis for processing:                                                                                                        
Our legal basis for data processing is:
- GDPR article 6.1.b
- GDPR article 6.1.f

Recipients:
By default, personal data is not transferred to other parties.

Data retention:
Data about participants on guided tours and in commercial activities are kept for up to 3 years.

Accidents, assaults, or insurance cases

As in all public places, passengers in the metro may experience unfortunate accidents or violent assaults. This can result in insurance cases or matters that will be reported to the police or the Accident Investigation Board Denmark.

Purpose:
To aid authorities and insurance companies to clear up and document incidents in the metro or on the metro’s areas.

Basis for processing:                
Our legal basis for data processing is:
- GDPR article 6.1.a
- GDPR article 6.1.c
- GDPR article 6.1.f

Recipients:
We may share your personal data with:
- The police
- Insurance companies
- Other authorities, for instance the Accident Investigation Board Denmark.

Data retention:
Personal data involved in this type of case is deleted by default 6 months after the authority or insurance company approaches us unless we are ordered by them to retain data for longer.

Purposes not related to use of the metro

Metro Service may also be considered data controller, even if data processing has no direct connection to use of the metro. An example of this is when you apply for a job with Metro Service.

If you would like to know more about this type of data processing, read our personal data policy here: https://www.metroservice.dk/en/gdpr/

Rights of individuals

In accordance with GDPR, individuals have several rights when it comes to processing of their personal data. Both Metroselskabet and Metro Service have a responsibility to make sure that these rights are met. The individual rights are described below.

If you were to make use of your rights, for instance the right of access to the personal data being processed, please contact us via the form here at dinoffentligetransport.dk.

The right of access

Individuals have the right of access to the personal data we are processing. If we are processing personal information, we will supply this data along with information about the purpose of our processing of it and a reference to our legal basis for doing so.

The right to object

Individuals have the right to object if they disagree with the way in which we process their personal data. Compliance with the objection will be determined case by case.

The right to request restriction

Individuals have the right to request restriction of our processing of their personal data. In some cases, restriction can be requested, if the individual does not wish for all registered data to be part of the case handling.

The right to request erasure

Individuals have the right to request erasure (” the right to be forgotten”). This right is not definitive, as certain data might not be erased for legal reasons, or if agreement and purpose lend us the right to keep the personal data.

The right to rectification

If the personal data being processed by us is incorrect, individuals have the right to have the data corrected.

The right to data portability

In certain cases, individuals have the right to receive their personal data in a machine-readable format. Please note that this personal data solely consists of data given to us by the individual.

The right to withdraw consent

If data processing is based on consent, individuals have the right to withdraw consent at any time, which will stop all processing.

The right to complain

If you are not satisfied with our processing of your personal information, we would like for you to contact us. See our contact details above.

You have the right to direct a complaint to the Danish Data Protection Agency, which monitors compliance with GDPR in Denmark. For contact details, see www.datatilsynet.dk.

GDPR data policy version

The present policy is version 2.2 and is valid from 1. april 2021.